Direct and indirect treatment relationships
HIPAA Weekly Advisor, May 3, 2004
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Q: Would a covered entity providing services to individuals over the Internet constitute a direct or indirect treatment relationship? Do indirect treatment providers have different HIPAA requirements than direct treatment providers?
A: An "indirect treatment relationship" is defined by HHS regulations as a relationship between an individual and a healthcare provider in which
- the healthcare provider delivers care to the individual based on the orders of another provider
- the healthcare provider typically provides services or products, or reports the diagnosis or results associated with the healthcare, directly to another healthcare provider, who provides the services or products or reports to the individual
Covered healthcare providers that provide services to individuals over the Internet have direct treatment relationships with those individuals, according to the Department of Health and Human Services. As far as HIPAA is concerned, the only difference between the two classifications is that indirect treatment providers are not required to provide each patient with a notice of privacy practices, but are only required to produce the notice upon request.
Visit the following sites for more information:
http://www.bricker.com/legalservices/practice/hcare/hipaa/164.520a.asp
http://www.bricker.com/legalservices/practice/hcare/hipaa/164.501i.asp
http://www.bricker.com/legalservices/practice/hcare/hipaa/164.520c.asp
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