HIPAA policy and procedures for your billing office
HIPAA Weekly Advisor, November 12, 2001
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Q: I work in a 59-bed behavioral health hospital. Under HIPAA, will the requests that come from physicians' billing offices need to be dealt with differently?
Will these offices be considered "business associates," and will we need a business associate agreement in order to share the health information that is presently provided at their written request?
A: A physician's billing service would be a business associate acting on the physician's behalf. You need a letter from the physician that confirms that the billing service is operating on his or her behalf and defines the information that the billing service is allowed to receive.
Q: My practice has file cabinets that are open and do not have any doors on them. It is my understanding that all medical and billing charts must be locked in file cabinets at all times. Our charts are not accessible to patients and are located in the administration area. Is this a violation?
A: If it is a small practice and the administrative area is protected from patients and accessible only to persons who need the information to perform their job function, then it may be ok. It is up to the practice to protect the information and comply with the minimum use and disclosure provision. The level of protection required to do that will vary depending on the practice type, size, office layout, etc.
Editor's note: Questions were submitted by readers and answered by Tom Hanks, director of client services for PricewaterhouseCoopers, LLP's Health Care Practice, in Chicago. If you have a question for him, write to HIPAA Weekly Advisor editor Brian Driscoll at bdriscoll@hcpro.com.
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