Health Information Management

The privacy rule creates virtual organizations

HIPAA Weekly Advisor, November 12, 2001

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One of the emerging lessons learned from compliance assessments under HIPAA's privacy rule is that protected health information (PHI) is rarely contained within the organizational boundaries envisioned by the law.

Hospitals must share information with physicians on their medical staffs. Providers use PHI in integrated delivery systems like independent provider associations (IPAs) and physician hospital associations (PHOs). Health care holding companies own chains of hospitals that get most of their information systems support from a corporate parent that is not a covered entity. Insurers that own health plans may also offer disability or life insurance products through the same licensed insurer.

Under the privacy rule, the regulatory focal point is the covered entity. Covered entities include health care providers, health plans, and health care clearinghouses. As the privacy rule defines health care providers and health plans, the terms apply to legally distinct, stand-alone organizations. That's because when administrative simplification was conceived in the early 1990's, the health care industry consisted largely of stand-alone providers and health plans.

To read more, go to http://www.himinfo.com/news/feature.cfm?content_id=15966



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