JO - Health Care Compliance Association

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The Health Care Compliance Association has moved to its new headquarters, located at: 6500 Barrie Road, Suite 250 Minneapolis, MN 55435 Our address has changed, our telephone and fax numbers remain the same: Toll-free phone: 888/580-8373 Local phone: 952/988-0141 Fax: 952/988-0146 And you can always reach us via e-mail at info@hcca-info.org or on our Web site at www.hcca-info.org Health Care Auditing & Monitoring Tools Buy Now and Receive One Year of Updates Free! The Health Care Auditing & Monitoring Tools manual is a compilation of excellent resources donated by HCCA members to help others with their compliance programs. This valuable resource assists health care compliance professionals who want to save time and money by offering examples of what their colleagues are doing to address similar auditing and monitoring issues. Just as auditing and monitoring are ongoing activities, this manual is an evolving resource that will be updated twice a year to reflect new regulations and additional compliance concerns. Subscribers to updates will receive more auditing and monitoring tools, policies, and advice. The original purchase of Health Care Auditing & Monitoring Tools is $395, which includes the first two updates free. Afterwards, HCCA members can subscribe to annual updates for $195. 6500 Barrie Road, Suite 250 Minneapolis, MN 55435 Phone 888-580-8373 FAX 952-988-0146 September 2006 Health Care Compliance Association • 888-580-8373 • www.hcca-info.org
ASK John asks the leadership your questions Editors note: John Falcetano is Chief Audit/Compliance Officer for University Health Systems of Eastern Carolina and a long-time member of HCCA. This column has been created to give members the opportunity to submit their questions by e-mail to Jfalcetano@cox.net and have John contact members of HCCA leadership for their response. L E A D E R S H I P John Falcetano Is it okay for a health care facility to leave a message for a patient on the answering machine at their home or with a family member to remind them of an appointment, or would that be a violation of HIPAA? The Answer was provided by Marti Arvin, JD, CHC, CIPP/G CPC Privacy Officer, University of Louisville: As a general rule, calling a patient to leave an appointment reminder is not a violation of HIPAA. An appointment reminder can be left on an answering machine, with a family member, or with another person who answers the phone. When these types of calls are made, the concept of minimum necessary should always be kept in mind. The Office of Civil Rights addressed this issue in its Frequently Asked Questions which can be found at http://www.hhs.gov/ocr/hipaa/. The FAQ answer #198 indicated that “... a covered entity might want to consider leaving only its name and number and other information necessary to confirm an appointment, or ask the individual to call back.” HIPAA does require the covered entity to put the patient on notice that protected health information might be disclosed for this purpose. See 45 CFR 164.520(b)(1)(iii)(A). This means the covered entity’s notice of privacy practices must specifically state this as a potential disclosure. It would be a HIPAA violation to leave this type of message on the patient’s answering machine if the covered entity’s notice of privacy practices did not specifically address this situation. Finally, if a patient has made a reasonable request for a confidential communication, a message may not be left on the individual’s answering machine if this would violate the confidential communication request. For example, if the patient has asked that all communications be done through a cell phone number, then leaving a message on the home answering machine would be a violation of the confidential communication request. See 45 CFR 164.522(b). n Health Care Compliance Association 2006 Conferences (by state): San Francisco, CA ■ Physician Practice Compliance Conference October 1-3 Orlando, FL ■ Audit & Compliance Committee Academy September 20-22 ■ Compliance Academy November 6-9 Honolulu, HI ■ Hawaii Area Meeting October 19-20 Chicago, IL ■ North Central Area Meeting October 6 Louisville, KY ■ Tri-State Area Compliance Conference November 3 Baltimore, MD ■ Medicare Part D September 10-12 ON ■ Fraud & Compliance Forum September 25-27 Boston, MA ■ New England Area Meeting September 8 Minneapolis, MN ■ Upper Midwest Area Meeting September 15 T H E C A L E N D A R Las Vegas, NV ■ 3rd Annual Research Conference September 17-19 ■ Advanced Academy October 23-26 Pittsburgh, PA ■ Mid Atlantic Area Meeting September 29 Nashville, TN ■ South Central Area Meeting November 10 2007 Chicago, IL ■ Compliance Institute April 22-25 ■ National Corporate Compliance Week May 20-26 INSIDE 3 Ask leadership 4 HIPAA compliance recipe 5 Go local 10 Corporate Integrity Agreement 14 Meet Lea Cobb 18 President & CEO letter 20 Medical marketing compliance 22 FYI 24 New Medicare enrollment regulations 32 Using mental health records for research 36 Compliance investigations 44 New members 888-580-8373 • www.hcca-info.org September 2006
Page 1: Volume Eight Number Nine September
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Page 25 and 26: those that have already enrolled in
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