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Organized Health Care Arrangements allow physician practices to share cost of HIPAA-compliance

HIM Connection, January 28, 2003

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Dear Colleagues:

Providers that are part of a larger organized health care arrangement (OHCA, such as a health maintenance organization, a health system, or a clinically integrated care setting, may be able to save some of the time and expense of implementing some of the privacy regulations. OHCA members are all allowed to use some of the same forms, and don't have to establish formal agreements with one another.

HIPAA defines an OHCA as either of the following:

1. A clinically integrated care setting, such as a health maintenance organization, in which individuals typically receive health care from more than one provider
2. An organized system of health care in which more than one covered entity participates (such as if a practice is part of a larger health care delivery system that includes hospitals, medical clinics, and other service delivery sites), and in which the participating covered entities do both of the following:
   • Hold themselves out to the public as participating in a joint arrangement
   • Participate in joint activities that include at least one of the following:
     • Utilization review, in which health care decisions by participating facilities are reviewed by other participating facilities (or by a third party on their behalf)
     • Quality assessment and improvement activities, in which treatment provided by participating covered entities is assessed by other participating covered entities or by a third party on their behalf
     • Payment activities, if the financial risk for delivering health care is shared, in part or in whole, by participating covered entities through the joint arrangement, and if protected health information created or received by a covered entity is reviewed by other participating covered entities or by a third party on their behalf for the purpose of administering their share of financial risk

So, if a practice isn't part of an HMO or some other clinically-integrated setting, your group has to jointly do one of the things listed above in order to qualify as an OHCA. If you do, be sure to have documentation such as board resolution to demonstrate your participation.

This week's HIM Connection was adapted from the book, Fast Lane to HIPAA Compliance: Easy-to-use Tools and Solutions for your Physician Practice. The book and companion CD-ROM is a cost-effective guide that provides easy-to-use training vehicles and every final form, policy, and procedure necessary to comply with HIPAA. Other resources that were published before the government released the final privacy rule are now outdated; Fast Lane to HIPAA Compliance reflects all of the final HIPAA rule changes. Click here for more information or to order your copy.

Sincerely,

Kim Raines
Managing Editor

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