HIPAA

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

We have recieved requests for AoD information sent to a specific party, but none for all information sent.  I would imagine this number will increase as access to the record increases.

-------------------------------------------
AnthonyBryanLeadership
Director of Risk Management and Corporate Compliance
Family Service and Guidance Center
TopekaKS
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

Anthony,

Thanks!

On what scale have the request you described been received?  Are we talking small numbers?

In the early days of HIPAA, I was one of a few compliance officers at the time back in 2003 and 2004 that guessed (because unlike some folks who just happen to guess correctly and then conclude they had some innate level of expertise on a topic)...

and publicly stated at venues such as the HIPAA Summit in DC and other HIPAA conferences and in newsletters that I thought covered entities were going to invest a disproportionately large amount of resources to create processes to support and produce Accounting of Disclosures compared to how many requests they ultimately received.

8+ years later....this same viewpoint is holding true.

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-26-2012 09:09 AM
From: Anthony Bryan
Subject: First Request For an Accounting of Disclosures...

We have recieved requests for AoD information sent to a specific party, but none for all information sent.  I would imagine this number will increase as access to the record increases.

-------------------------------------------
AnthonyBryanLeadership
Director of Risk Management and Corporate Compliance
Family Service and Guidance Center
TopekaKS
-------------------------------------------





-------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

These requests are very rare across our system as well.  I doub we average more than 2-3 year over 13 hospitals and multiple clinics.

-------------------------------------------
NancyDavisMS, RHIA
Director of Privacy/Security Officer
Ministry Health Care
Sturgeon BayWI
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

Since HIPAA began, we have not had a single home health patient ask for an accounting - that's for 75 agencies in 3 states

-------------------------------------------
David Brown JD, FACHE, MHA
Gen.Counsel/Chief Compliance/Privacy Officer
EnCompass Home Health
DallasTX
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

We've had an annual average of..(drum roll)...  2! 
-------------------------------------------
StephenLeibold
Priv Ofcr/Corp Compliance Mgr
National Jewish Health
DenverCO
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-27-2012 02:01 PM
From: David Brown
Subject: First Request For an Accounting of Disclosures...

Since HIPAA began, we have not had a single home health patient ask for an accounting - that's for 75 agencies in 3 states

-------------------------------------------
David Brown JD, FACHE, MHA
Gen.Counsel/Chief Compliance/Privacy Officer
EnCompass Home Health
DallasTX
-------------------------------------------





-------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

Stephen,

I was going to start editing the record books and calling the press as I thought you wrote:
21

After the confetti settled and the band stopped playimg...I realized you wrote 2 with an exclamation mark.

-------------------------------------------
Frank Ruelas 623 308 1307
Principal
HIPAA College
Casa Grande AZ
frank@hipaacollege.com
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-27-2012 02:28 PM
From: Stephen Leibold
Subject: First Request For an Accounting of Disclosures...


We've had an annual average of..(drum roll)...  2! 
-------------------------------------------
StephenLeibold
Priv Ofcr/Corp Compliance Mgr
National Jewish Health
DenverCO
-------------------------------------------





-------------------------------------------
Original Message:
Sent: 04-27-2012 02:01 PM
From: David Brown
Subject: First Request For an Accounting of Disclosures...

Since HIPAA began, we have not had a single home health patient ask for an accounting - that's for 75 agencies in 3 states

-------------------------------------------
David Brown JD, FACHE, MHA
Gen.Counsel/Chief Compliance/Privacy Officer
EnCompass Home Health
DallasTX
-------------------------------------------





-------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

We have never received an accounting of disclosure request.
-------------------------------------------
ElizabethDeSisto
Director HIM/Privacy and Compliance Officer
East Boston Neighborhood Health Center
East BostonMA
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

Elizabeth,

Is this since April 2003?  If so...I'll bet you folks as did others invested some level of resource or process planning so that you could support any such requests.  True?

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 05-04-2012 10:41 AM
From: Elizabeth DeSisto
Subject: First Request For an Accounting of Disclosures...


We have never received an accounting of disclosure request.
-------------------------------------------
ElizabethDeSisto
Director HIM/Privacy and Compliance Officer
East Boston Neighborhood Health Center
East BostonMA
-------------------------------------------





-------------------------------------------
Original Message:
Sent: 04-26-2012 07:56 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...

This message has been cross posted to the following eGroups: HIPAA: Health Insurance Portability and Accountability Act Forum and Privacy Officer's Roundtable .
-------------------------------------------
Yesterday I was informed by the medical records staff of a nearby hospital that....drum roll...the first request for an Accounting of Disclosures (AoD) was received.

The AoD was produced literally in minutes and provided to the patient later that day when the patient came by the hospital and picked it up at the medical records department.

Here's my question....and guesstimates are welcome...on an annual basis, how many requests for an Accounting of Disclosures have you received?

I am interested to see if the annual number of requests continues to be exceptionally low, often in the range of single digits, as is my experience.

Thanks!

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

Hi, Frank.
I am fairly new to this group so could you tell me the process for posting questions to the list serve?
In the meantime, I would appreciate your input on the following:
We are considering an arrangement for lab testing services whereby we send out patient samples for testing and the lab bills the patient directly but if the patient does not pay then my client would be ultimately responsible. To enable the provider to bill directly, my client would provide the necessary information EXCEPT the provider insists that in this situation a business associate agreement is unnecessary. In my view my client is sharing information for payment, as well as treatment (which is explicitly excepted from the BAA), so BAA needs to be in place, what do you think?
Thanks for your assistance,
Shainoor
On May 4, 2012, at 11:07 AM, "Frank Ruelas" wrote:
Elizabeth,
Is this since April 2003? If so...I'll bet you folks as did others invested some level of resource or process planning so that you could support any such requests. True?
-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------

Show Original Message -------------------------------------------
Original Message:
Sent: 05-04-2012 10:41 AM
From: Elizabeth DeSisto
Subject: First Request For an Accounting of Disclosures...
We have never received an accounting of disclosure request.
-------------------------------------------
ElizabethDeSisto
Director HIM/Privacy and Compliance Officer
East Boston Neighborhood Health Center
East BostonMA
-------------------------------------------

Welcome to the group.  I am confident you will find this group exceptionally helpful in providing responses to a wide range of questions that are presented online.

In addition, there is the option to reply to the sender of a post which I will show you by doing so to your question below.

-------------------------------------------
Frank Ruelas 623.308.1307
Principal
HIPAA College
Casa Grande AZ
frank@hipaacollege.com
-------------------------------------------






Show Original Message -------------------------------------------
Original Message:
Sent: 05-07-2012 07:35 AM
From: Shainoor Ladha-Karmali
Subject: Health Insurance Portability and Accountability Act Forum: Business Associate Agreement

Hi, Frank.

I am fairly new to this group so could you tell me the process for posting questions to the list serve?

In the meantime, I would appreciate your input on the following:

We are considering an arrangement for lab testing services whereby we send out patient samples for testing and the lab bills the patient directly but if the patient does not pay then my client would be ultimately responsible. To enable the provider to bill directly, my client would provide the necessary information EXCEPT the provider insists that in this situation a business associate agreement is unnecessary. In my view my client is sharing information for payment, as well as treatment (which is explicitly excepted from the BAA), so BAA needs to be in place, what do you think?

Thanks for your assistance,
Shainoor

On May 4, 2012, at 11:07 AM, "Frank Ruelas" wrote:



Elizabeth,

Is this since April 2003? If so...I'll bet you folks as did others invested some level of resource or process planning so that you could support any such requests. True?

-------------------------------------------
Frank Ruelas
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------