HIPAA Final Rule: More on Uses and Disclosures of Protected Health Information of Decedents

Today, we continue going through the HIPAA Privacy Rule, section by section, as modified in the Final Rule:  Modifications to the HIPAA Privacy, Security, Enforcement, and Breach Notification Rules Under the Health Information Technology for Economic and Clinical Health Act [HITECH Act] and the Genetic Information Nondiscrimination Act; Other Modifications of the HIPAA Rules, which was published in the Federal Register on January 25, 2013.  The effective date of the Final Rule is March 26, 2013, and covered entities and business associates must comply by September 23, 2013. Our focus yesterday was on the modified rule: 45 CFR 164.502(f): Standard:  Deceased individuals. Today, we finish up with a related modified…

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ARRA Stimulus Funds

On Thursday, May 28, 2009, the Office of the National Coordinator released guidance on the new Health IT Regional Extension Centers (HITRC). Section 3012 of the Public Health Service Act (PHSA), as added by the HITECH Act, authorizes a Health Information Technology Extension Program to make assistance available to all providers, but with priority access to Health IT for the uninsured, underinsured, historically underserved and other special-needs populations, and use of that technology to achieve reduction in health disparities. The major focus for the Centers’ work with most of the providers that they serve will be to help to select and successfully implement certified electronic health records (EHRs). Assistance is…

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ARRA’s HITECH Privacy Provisions Apply HIPAA Security Rule to Business Associates

President Obama signed into law the American Recovery and Reinvestment Act of 2009 (ARRA) on Tuesday, February 17, 2009. The Health Information Technology for Economic and Clinical Health Act (HITECH) provisions of ARRA in Title XIII include important changes in Privacy (Subtitle D). Our focus in this posting is the change related to business associates under HIPAA Administrative Simplification that is specified in Section 13401: Application of Security Provisions and Penalties to Business Associates of Covered Entities. In this section, administrative, physical, and technical safeguards, and policy, procedure, and documentation requirements of the HIPAA Administrative Simplification Security Rule “shall apply to a business associate of a covered entity in the…

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What Should I Know About Interfaces?

A key quality of care benefit of an EHR is its ability to create, send out and track the provider’s orders and then electronically review and route the results of those orders into the patient’s record. Due to many national efforts, HL7 standard language is used to create these interfaces. When the interfaces communicate back and forth with your EMR, results can be provided to the clinician for review prior to posting into the patient record. Some specialties receive as much as 70 percent of health care information from outside sources, including information from hospitals, labs, diagnostic imaging centers, payers, referring physicians, patients and pharmacies. The most common interfaces to…

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What EMR System is Best for My Practice?

Your most important question in purchasing an EMR is to ask the vendor how many specialties your size and using your practice management system have purchased this software. EMR vendors know who would be a good customer. Some vendors, for example, are better suited for a practice of 25 to 75 physicians. Others specialize in the 3 to 8 physician groups, while others provide a solution for just one specialty. You can quickly learn whether the vendor is a good fit for you by asking them to respond to a one-page Request for Information (RFI). Send the RFI to your top five vendors and ask them to respond within 30…

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Should Our Practice Hire an IT Person to Assist With our HIT Transition?

Vendors will provide you with a list of implementation activities for which you are responsible to complete on time. During the next 24 months as more physicians participate in reimbursement incentives, it will be critical for you to stay on schedule, or even ahead of schedule and keep your go-live date in the queue. The rule of thumb is based on the principle of threes. If there are three or fewer physicians in your practice, you should hire a part time consultant to coach an internal person through the implementation process. After your implementation, the consultant can hand off the day-to-day IT management to an internal person who also should…

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