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HIPAA News and Info

October, 2002, seems to be a month of significant activity for the HIPAA Privacy Rule. Note the following four documents:

DHHS Office of Civil Rights has issued a new FAQ. New Privacy October 2002 FAQ

CFR Parts 160 and 164 combined language form OCR (Unofficial) New Combined CFR Privacy Language This is a large doucment, 2.55 MB in size!


The NCVHS, after initial hearings, has sent a letter to DHHS Secretary Thompson indiciating great concerns over the HIPAA implementation. NCVHS September, 2002, Letter

CMS has issued a FR entry in the October 7, 2002, Federal Register. This make interesting reading relative to systems for accunting for disclosures under the Privacy Rule! CMS System of Records FR Entry

On December 12, 2001, the US Senate passed the House version of H.R. 3323. A legislative conference was avoided, and the Bill was sent to President Bush for signature.

The provisions of this Bill need to be studied with great care by all providers! This is not a blanket extension of the implementation date from October 16, 2002 to October 16, 2003. It does provide for certain conditions under which a covered entity (excluding small health plans as usual) may extend the implementation of the Transaction Standards and Standard Data Sets until October 16, 2003. Providers will need to proactively take action if they are to delay. There are also additional requirements placed on the Secretary of HHS (Health and Human Services) regarding implementation and support for the compliance date extension process and associated procedures.

Understanding the HIPAA Transaction Standards Delay. Take a look at the provisions and Dr. Abbey's Comments here! [.doc]

Enrolled H.R. 3323 from Congressional Site [.pdf]

A Brief Summary of HIPAA's Status

HIPAA for health care providers has several different aspects.  The implementation of various HIPAA rules is in state of confusion with very different implementation dates and sometimes conflicting guidance.  We anticipate that there will be extensive subregulatory guidance so that HHS can explain what they really meant to say when they developed the rules.


HIPAA Consulting

Abbey & Abbey, Consultants, Inc. offers a variety of educational and consulting oriented services for all types of health care providers for HIPAA related activities.

  • Education & Training
    • Public Workshops
    • Public Teleconference/Webinars
    • Health Care Provider Sponsored Training & Education
    • Assistance In Developing HIPAA Training For Health Care Providers
  • HIPAA Advisory Services
    • Project Planning
    • Evaluation Of Alternative Implementations
    • Cost-Benefit Analyses

The main areas for all health care providers to address include:

v    Privacy – This area was an add-on at the last minute to the original legislation.  It has taken on a life of its own with extensive rules for which significant preparation must be made.

v    Security – This is part of the Administrative Simplification section of the legislation.  This is a highly technical computer and telecommunications area.  It appears to be the last of the three main areas to be implemented.

v    Electronic Data Interchange – This is E-Commerce for health care and involves the area of Standard Transactions and Standard Data Sets.  This is a technical area with significant implications for coding, billing and reimbursement.

v    Additional Areas – There are several other areas in which proposed rules have been provided such as electronic signatures, identification numbers and the like.  While these areas must be watched, there is not a great deal of activity currently taking place.


HIPAA Links

To see how the AACI consultants can assist you, review our HIPAA Advisory Services.

HIPAA topics are also regularly discussed in our “Medical Reimbursement Newsletter”.  Click here to learn more about our monthly newsletter.

More links and related material will appear as HIPAA evolves.


Downloads

December 2001:

Understanding the HIPAA Transaction Standards Delay. Take a look at the provisions and Dr. Abbey's Comments here! [.doc]

Enrolled H.R. 3323 from Congressional Site [.pdf]


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