I think this is mixing apples and oranges. The definition of "Electronic Media" does not change the definition of "Covered Entity". Also, I went back and ran this scenario through the decision support tool and a provider that does NOT perform any of the transactions electronically (despite how the information is stored in their office) still comes up as NOT being a covered entity. My interpretation of the regulations is that storing PHI in electronic form on a PC is not considered transmitting a standard transaction electronically and in and of it's self does not make a provider a covered entity.
Kris Owens
Senior IS Project Manager - HIPAA Project
Presbyterian Healthcare Services
Albuquerque, NM
505.923.8108
[EMAIL PROTECTED]
"God made the earth, the sky and the water, the moon and the sun. He
made man and the bird and beast. But He didn't make the dog. He already
had one." - Native American saying
-----Original Message-----
From: Scott Kimbel [mailto:[EMAIL PROTECTED]]
Sent: Thursday, February 13, 2003 3:27 PM
To: WEDI SNIP Transactions Workgroup List
Subject: RE: New Definition of "Electronic Media" in Security Rule
I would say it does, this is the Same definition that the CMS decision
support tool was changed to, I think this definition extremely broadens the
scope of who is a "Covered Entity"
-----Original Message-----
From: Scott Wellwood [mailto:[EMAIL PROTECTED]]
Sent: Thursday, February 13, 2003 2:08 PM
To: WEDI SNIP Transactions Workgroup List
Subject: Re: New Definition of "Electronic Media" in Security Rule
Does this mean that providers that store PHI on their PC, but do not utilize
covered transactions (for example, they print and mail their own claims)
will be considered covered entities?
Scott Wellwood
Electronic Insurance Svc., Inc
(800) 576-6412
[EMAIL PROTECTED] <mailto:[EMAIL PROTECTED]>
----- Original Message -----
From: Zon Owen <mailto:[EMAIL PROTECTED]>
To: WEDI SNIP Transactions <mailto:[EMAIL PROTECTED]>
Workgroup List
Sent: Thursday, February 13, 2003 1:17 PM
Subject: New Definition of "Electronic Media" in Security Rule
Aloha!
The pending Final Security rule, which is supposed to be published on
02/20/2003, contains the following definition of "electronic media" in
160.103:
<< Begin Final 02/2003 Security Rule Quote >>
Electronic media means:
(1) Electronic storage media including memory devices in computers (hard
drives) and any removable/transportable digital memory medium, such as
magnetic tape or disk, optical disk, or digital memory card; or
(2) Transmission media used to exchange information already in electronic
storage media. Transmission media include, for example, the internet
(wide-open), extranet (using internet technology to link a business with
information accessible only to collaborating parties), leased lines, dial-up
lines, private networks, and the physical movement of
removable/transportable electronic storage media. Certain transmissions,
including of paper, via facsimile, and of voice, via telephone, are not
considered to be transmissions via electronic media, because the information
being exchanged did not exist in electronic form before the transmission.
<< End Final 02/2003 Security Rule Quote >>
I would particularly note the discussion of fax and voice in subparagraph
(2).
Since this section is common to all of the Admin Simp rules, this definition
replaces the definition in the original TCS rule of 08/2000. For
comparison, here is the definition used in the 08/2000 final TCS rule:
<< Begin 08/2000 Final TCS Rule Quote >>
Electronic media means the mode of electronic transmission. It includes the
Internet (wide-open), Extranet (using Internet technology to link a business
with information only accessible to collaborating parties), leased lines,
dial-up lines, private networks, and those transmissions that are physically
moved from one location to another using magnetic tape, disk, or compact
disk media.
<< End 08/2000 Final TCS Rule Quote >>
- Zon Owen -
(808)597-8493
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