Chris,
I understand where you are going with this but I think you may be mixing
apples and oranges.  JCAHO Accreditation does have real meaning and the
threat of losing accreditation does have real world implications. It is
the recognized standard for healthcare quality and patient safety. 

Under the proposed security rule there is something called self
certification which is maybe where the privacy certification will lead.
There probably needs to be something like ISO9000 in the healthcare
vertical to have industry accepted standards for privacy and security.

Regards,

David Frenkel
Business Development
GEFEG USA
Global Leader in Ecommerce Tools
www.gefeg.com
425-260-5030

-----Original Message-----
From: [EMAIL PROTECTED]
[mailto:[EMAIL PROTECTED]] 
Sent: Wednesday, December 18, 2002 4:49 PM
To: WEDI SNIP Testing Subworkgroup List
Subject: RE: FW: Public Comment: NCQA Releases Draft Standards for
Privacy Certification Program For Business Associates


Respected colleauges: 

(I am not clear if this a conversational thread on the topic and if it
is
proper that I respond with comments here. If not, please let me know and
beg your indulgence.)

I am concerned how a provider discerns between what ClarEDI
certifcation,
Mercator certified, ENHAC certified, Microsoft certified, NCQA
certification, JCAHO...etc... truly means? An uninformed provider can,
does
and will pay a higher price for a "certified" system/covered entity.
Clearly, not the intent of HIPAA, but a true blue, time tested, economic
phenomonon. At some point, all the alphabet soup of certifications loses
signifiance to the very people it was intended to help make an informed
choices.

I think Privacy "certifcation" is uncessary because a federal statue now
exists that holds culpable covered entities criminally for their
actions.
Ergo, covered entities and vendors are accountable at the most
fundemental
of levels, their businesses are at significant risk. I certainly don't
want
to be the test case for enforcement.

In contrast,certification of for security and transaction standards are
tangible in value to the both vendor and covered entity. They provide
some
defined (debateable, I know) benchmark that the vendor/covered entity
took
steps to bring their systems and practices in line with a "standard".
They
go beyond policy and procedure. Security technology is deployed or it
isn't. Each certification holds each coverd entity to having to meet a
minimum level. These standards have been evolving for years and are
widely
adopted and accepted in other industries. The transactions are
transmited
in the standard format, or they are rejected. (I know that's simplistic)

I welcome a alternate point of view.

With best regards and warmest holiday blessings and wishes for all who
read
this.

Chris Brancato
Compliance Officer
Director-Development/Product Management
Health Data Services
Suite 3a
503 Faulconer Drive
Charlottesville, VA 22903
434-817-9000


Original Message:
-----------------
From: Miriam Paramore [EMAIL PROTECTED]
Date: Wed, 18 Dec 2002 18:47:51 -0500
To: [EMAIL PROTECTED]
Subject: FW: Public Comment: NCQA Releases Draft Standards for Privacy
Certification Program For Business Associates


In a recent post during the discussion of certification, I mentioned
this
program that NCQA is doing.  Notice they use the word "certification".
Even
though this is for Privacy, it shows that groups like WEDI are trying to
set
the bar.

Best Regards,

Miriam J. Paramore
President & CEO
PCI: e-commerce for healthcare
9001 Shelbyville Road
iTRC Building
Louisville, KY 40222
502-429-8555
www.hipaasurvival.com
===========================================
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-----Original Message-----
From: PCBAPUBCOM [mailto:[EMAIL PROTECTED]]
Sent: Monday, December 16, 2002 4:51 PM
Subject: Public Comment: NCQA Releases Draft Standards for Privacy
Certification Program For Business Associates



> NCQA is pleased to release its new Privacy Certification for Business
> Associates evaluation program for a 45-day public comment period and
> invites your comments and suggestions. The draft requirements were
posted
> on NCQA's Web site, www.ncqa.org, on December 16, and they will be
> available through the conclusion of the public comment period on
January
> 31.
>
> With the compliance deadline for new Health Insurance Portability and
> Accountability Act (HIPAA)-mandated privacy regulations rapidly
> approaching, business associates will want to ensure their privacy
> practices are in line with the tough new privacy standards.
>
> Privacy Certification standards closely track with the final HIPAA
privacy
> regulations. Specific requirements relate to:
>
> *     Privacy protections for oral, written and electronic PHI
> *     Processes and practices for the storage, use and disclosure of
PHI
> *     Employee training on PHI protections
> *     Consumer access to PHI
> *     Contracts between covered entities and their business associates
> *     Protection of PHI by business associate subcontractors and
agents.
>
>
> Please take this opportunity to offer your insights, and help shape
NCQA's
> new Privacy Certification program!
>
> Public Comment: December 16, 2002 -January 31, 2003
>
>
>


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not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If 
you wish to receive an official opinion, post your question to the WEDI SNIP Issues 
Database at http://snip.wedi.org/tracking/.   These listservs should not be used for 
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