|
|
|
|
This one I can't predict...... I agree that the resource requirements will be significant. However, I have many concerns and did participate with AHIMA and my own organization and provided comments to the proposed rule. This will require an educational component for patients. I do hope that if it does pass there that it has a carve out for the organization to review and decline. In some cases where unstable patients are involved, it would seem like a risk to the staff members. I guess we wil have to wait and see. ------------------------------------------- NancyDavisMS, RHIA Director of Privacy/Security Officer Ministry Health Care Sturgeon BayWI -------------------------------------------
Show Original Message
-------------------------------------------
Original Message:
Sent: 05-01-2012 11:25 AM
From: Frank Ruelas
Subject: First Request For an Accounting of Disclosures...
Nancy,
My opinion after speaking with folks is that if the final rule on Access Reports remains as is...then the resources needed to compile one of the access reports as compared to what was needed to compile an Accounting of Disclosures is significantly more involved.
...and why would anyone imagine that there will be any different demand from individuals for these types of reports as well?
-------------------------------------------
Frank Ruelas 623 308 1307
Principal
HIPAA College
Casa GrandeAZ
-------------------------------------------
-------------------------------------------
Original Message:
Sent: 05-01-2012 07:06 AM
From: Nancy Davis
Subject: First Request For an Accounting of Disclosures...
Here is what bothers me about this. Back when this first came out, covered entities scrambled to try and develop or purchase systems to accommodate these requests in compliance with the Privacy Rule. I remember sitting a Catholic Health Association meeting roundtable of privacy officers where we all discussed our strategies. For some it was purchased software packages at considerable expense, for others is was internally created documentation systems in things like Lotus notes or new forms that nurses and providers would have to complete when making a disclosure to public health, law enforcement, etc. As we all shared essentially how we were going to expend resources to meet this standard, one very WISE privacy officer said he was going to do nothing......... he was going to wait and see what happened and when he did receive a request, he was going to just abstract the record to determine disclosures. His rationale: 1) cost of software; 2) cost of implementation resources; 3) concern that asking providers to "double-document" could result in deficit documentation in the actual patient record; 4) provider compliance to completing forms, software; 5) the actual record shoudl be the true source, etc....
Boy, was he right. This was not a value-added standard and I fear that the proposed EHR access report may create many more problems than value to the consumer. This spring I did my annual high school careers presentation and the facilitating teacher asked me out of curiosity just how many people would potentially "see" her PHI/record if she came in for a visit. It was a good question, but one that made me uncomfortable and later when I answered I think many others were uncomfortable. Appointment clerk, registration clerk, medical assistant, nurse, provider, appointment clerk for return visit, transcriptionist, transcription clerk, coder, biller x 2, etc.... In small communities, these are clearly people that are known to the patient. The point is that the average patient has no idea how many individuals have reason to interact with their PHI/records and this will be disconcerting to many.
-------------------------------------------
NancyDavisMS, RHIA
Director of Privacy/Security Officer
Ministry Health Care
Sturgeon BayWI
-------------------------------------------
-------------------------------------------
Original Message:
Sent: 04-30-2012 09:04 AM
From: Jill Choi
Subject: First Request For an Accounting of Disclosures...
At Nationwide Children's Hospital in Columbus, we have had only 1 accounting request since 2003.
-------------------------------------------
JillChoiMBA, RHIA
Dir HIM & Privacy Officer
Nationwide Children's Hospital
ColumbusOH
-------------------------------------------
-------------------------------------------
Original Message:
Sent: 04-30-2012 12:40 AM
From: Matt Frederiksen
Subject: First Request For an Accounting of Disclosures...
Frank,
Having worked in compliance and privacy for several years, I believe I've only had one request for an accounting of disclosures maybe once in the last five years.
-------------------------------------------
MattFrederiksenCHC, CHPC,MBA, BSHA
Chief Compliance Officer
Wyoming Medical Center
CasperWY
-------------------------------------------
-------------------------------------------
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
-------------------------------------------
|
|
|