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Hipaa Compliance
- 1. Health Insurance Portability and Accountability Act HIPAA PROGRESSIVE CORPORATE SERVICES 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015
- 2. HIPAA It is a Federal law passed in 1996. It specifies what is required to protect the privacy of personally identifiable health care information. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 3. Time Lines for HIPAA Compliance Three separate and independent timelines required for HIPAA compliance. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 4. Time Lines for HIPAA Compliance Three separate and independent timelines required for HIPAA compliance. Privacy Rule compliance required by April 14, 2003 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 5. Time Lines for HIPAA Compliance Transaction Code Set Rules (TCS) compliance required by October 16, 2002 or October 16, 2003 if you filed for an extension Three separate and independent timelines required for HIPAA compliance. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 6. Time Lines for HIPAA Compliance Security Rule compliance deadline April 21, 2005 Three separate and independent timelines required for HIPAA compliance. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 7. Covered Entities To be considered a covered entity, the organization must be either a health care provider, a health plan, or a health care clearinghouse. Covered entities provide services directly to the patient. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 8. An ambulance service is considered to be a health care provider. Covered Entities 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 9. Covered Entities To be considered a covered entity, you must engage in electronic transactions. This includes billing. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 10. Protected Health Information (PHI) When PHI enters an organization, whether it is from a patient, a bystander, a friend, a family member or a dispatch agency, all privacy and security rules apply. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 11. What is PHI? Individually identifiable information Information regarding past, present, or future physical or mental health 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 12. What is PHI? Information regarding provision or payment of care to an individual. Includes any material that is written, verbal, electronic, scanned, photographic, etc. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 13. Examples of PHI Patient care reports (PCRs) Dispatch records Billing information Incident reports with patient information. Physician Certifications 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 14. Three Allowed Uses of PHI Treatment Payment Health Care Operations These are allowed without prior patient authorization. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 15. Treatment You may share PHI with other health care providers involved in treating the patient. First Responders may share patient information while on the scene. You may share information with emergency department personnel without the patient’s permission. Facilities may share information to providers for treatment purposes. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 16. Payment Providers may use PHI to send invoices and file claims. Emergency Departments may supply “face sheet” information to services for billing purposes. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 17. Operations QA/CQI, Internal Audits Patient names and addresses must be omitted if using PHI for research or education. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 18. Business Associates A business associate is a person or an entity that performs certain functions or activities that involve the use or disclosure of PHI on behalf of, or provides services to, a covered entity. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 19. Business Associates Covered entities must have formal “business associate” agreements in place with business associates to meet compliance guidelines under HIPAA. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 20. Business Associates Examples of business associates are: Collection Agencies Billing Companies Computer Software Companies that may have access to PHI Legal Counsel, etc. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 21. Business Associates In other words, business associates are those entities that do not perform services directly to the patient but instead provide services to covered entities 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 22. Privacy Rule-What Is Required? • Designation of a privacy officer • Securing of patient records and limiting access so that they are not available to those personnel who do not have a “need to know” 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 23. Examples of Security Safeguards Include a confidentiality statement on all e-mails, fax cover sheets and web pages. Web page notices must be printable. Keep patient care reports restricted. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 24. Keep fax machines which receive PHI in a secure location and limit access. Obtain reasonable assurances that those who receive your faxes do the same. Examples of Security Safeguards 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 25. What is the Transaction Code Set Rule? (TCS) Requires providers to submit electronic claims in an approved format. Requires payers to accept transactions that are submitted in the standard formats. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 26. The Steps to HIPAA Compliance Conduct a “gap analysis”. Identify existing privacy related policies and procedures and review them for accuracy and compliance. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 27. The Steps to HIPAA Compliance Adopt a formal privacy practice. You may use samples from any source, but make sure you have all policies, forms, and agreements reviewed by your attorney. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 28. The Steps to HIPAA Compliance Develop and provide a notice to each patient concerning your privacy practices and make good faith effort to obtain a signed acknowledgement from the patient that he or she has received it. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 29. The Steps to HIPAA Compliance Develop a policy that protects PHI and distribute only the necessary parts of the PHI to entities that have a “need to know”. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 30. The Steps to HIPAA Compliance Identify all members of your organization who need to access Protected Health Information (PHI) by their job descriptions and identify what parts of PHI they need to access. Develop a policy that contains this specific information. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 31. The Steps to HIPAA Compliance Develop a policy that allows patients or their designated representatives access to their PHI 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 32. The Steps to HIPAA Compliance Develop a Designated Record Set which will determine what information is released when it is requested. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 33. The Steps to HIPAA Compliance Develop a policy that identifies the method by which a patient or designee may amend their PHI. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 34. The Steps to HIPAA Compliance Identify business associates. Develop and execute business associate agreements. Coordinate with vendors. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 35. The Steps to HIPAA Compliance Appoint a privacy officer. This person may have other duties within the organization. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 36. The Steps to HIPAA Compliance Ensure that all required HIPAA policies, procedures and agreements have been developed. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 37. The Steps to HIPAA Compliance Provide HIPAA training to all members of the organization by April 14, 2003. These members may include, but are not limited to: crew members, office personnel, board of directors, administrative personnel, etc. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 38. Continued Compliance Monitor and revise policies as needed. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 39. Very Important You must not only safeguard written PHI, but also verbal PHI! There must be a written policy banning all inappropriate banter about specific patients. Penalties for such behavior must be included in the policy. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 40. What You Must Have! 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 41. - Notice of Privacy Practices - Business Associate Agreements - Accounting Log -“Minimum Necessary” Policies - Who needs access to what? You MUST Have 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 42. - Designated Record Set Policy - Policy regarding uses and disclosures - Training documents You MUST Have 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 43. - Amendment forms - Written designation of privacy officials - Documents regarding any penalties given for privacy violations You MUST Have 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 44. What Would It Be Nice to Have? 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 45. - Privacy Officer Job Description - Request for Access form - Request for Amendment form - Request for Restriction form You Should Have 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 46. You Should Have -Complaint Policy -Password Authorization form -Record Release Policy -Confidentiality Policy 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
- 47. If you choose to use sample forms, agreements or policies from any source, review each of them with your attorney. 101-102, Sheraton House, Ambavadi, Ahmedabad, Gujarat, India - 380015 PROGRESSIVE CORPORATE SERVICES
Notes de l'éditeur
- QRS services are not usually considered covered entities because they do not bill.
- The name of the patient The social security number of the patient Information about your treatment of the patient
- You may give patient information to a police officer or fire person if he or she is helping you with patient care. You may not give a copy of your PCR or other protected information after the call to an officer or fire person who was not on the call. You may not give patient information to a reporter or other persons on the scene who are not assisting in patient care or transport. Although it is best to give your patient care report to a doctor or nurse, you may relay information to a ward or unit clerk who will relay the information to the person responsible for the patient’s care. You must make a good faith effort to protect your patient’s privacy when assessing and treating your patient. That means you should lower your voice when speaking to the patient, if there are bystanders close by.
- A provider does not need to have a business associates agreement with a hospital unless the hospital carries out functions not related to patient care, such as billing.
- You do not need the patient’s signature that you have provided the Notice of Privacy Practices before you treat him or her.
- If a patient or designee comes to your station and asks for a copy of a patient care record, you should inform the person of your organization’s privacy practices and direct him or her to the appropriate individual.
- The privacy officer oversees the privacy policies and procedures and complaints concerning privacy.