Practical Implementation of HIPAA-Compliant Consents and 对符合HIPAA同意实施与.ppt

Practical Implementation of HIPAA-Compliant Consents and Authorizations Becky Buegel, RHIA HIPAA Summit West II March 14, 2002 Overview Determine if you qualify as an OHCA. Develop Notice of Privacy Practices. Develop the consent form. Develop authorization forms. Identify all “ports of entry”. Develop policies and procedures. Train the staff. Organized Health Care Arrangements Is your organization part of an Organized Health Care Arrangement (OHCA)? HHS recognized there are arrangements in which legally separate, covered entities (CEs) need to share protected health information (PHI). While the focus of this presentation is on hospitals, CEs that may need to share PHI include hospitals, IPAs, HMOs and other group health plans. OHCAs Defined §164.501 OHCAs include: clinically integrated care settings in which individuals typically receive health care from more than one provider; or systems in which several covered entities participate and they participate in joint activities such as UR, QA and/or payment; or group health plans/insurers/HMOs. Notice of Privacy Practices §164.520 A Joint Notice of Privacy Practices may be issued by an OHCA if: participants agree to abide by the terms of the notice with respect to PHI created or received as part of their participation in the OHCA; the joint notice reflects that it covers more than one covered entity; it describes with reasonable specificity the CEs or class of entities to which the notice applies; Notice of Privacy Practices (con’t.) it describes with reasonable specificity the service delivery sites to which the joint notice applies; and (if applicable) it states that the CEs in the OHCA will share PHI with each other to carry out TPO. The header for all notices of privacy practices must prominently display the following information: Notice Elements (con’t) THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT