Overview
The Health Insurance
Portability and accountability Act of 1996 was intended to provide for the
waiver of pre-existing provisios for persons who move from one employer to
another. In the enacted law, "Administrative Simplification" provisions
were added. These include: Transaction Code Sets, Security, and Privacy.
Transaction Code Sets Provisions
Transaction provisions
require standardization of electronic formats for the transmission of clains,
electronic remittance advice, eligibility, authorization, pharmacy information,
enrollment information, benefits, and first notice of claim. Eventually, reimbursement
will also be made electronically which should facilitate the efficiency of
your office. Electronic eligibility information will simplify claims submission
and help to insure payment. Insurers report that 30-40% of rejected claims
are for missing or inaccurate member ID numbers. Physicians will soon be able
to track claims submitted electronically in real time.
Transaction Codes Sets
provisions were recently extended to October, 2003.
To get the extension,
you must apply for it by October 16, 2002.
Privacy Regulations
Regulations governing
privacy of patient identifiable health information become effect on April
14, 2003. You need to take reasonable measures to control the privacy of patient's
healthcare information under these new regulations. Physicians do not need
to remodel their offices to meet the privacy requirements. The U.S. Dept.
of Health and Human Services recognizes that privacy of health information
cannot be absolutely guaranteed. The privacy regulations state that whatever
administrative processes are used by the physician to implement this regulation
can be flexible and fit the physician's individual circumstances. Not all
privacy programs will be the same. The AOA HIPAA privacy manal provides a
more detailed discussion of these requirements.
Beginning a compliance program
-
Appoint a privacy
official
-
Conduct a risk assessment
and gap analysis for current privacy policies and procedures
- Inventory the protected
health information in your practice.
- Inventory your business
associates - attorneys, accountants, data processing, transcription, billing
companies, and practice management companies.
- Conduct an assessment
of applicable state law.
- Gather and compare
existing confidentiality agreements.
- Coordinate employee
education and begin privacy awareness training.
- Gather and compare
your existing privacy policies and procedures
A free HIPAA privacy compliance
manual is available on DO-Online and
contains a step-by-step approach to compliance. It also contains a plan to
review a practice's current privacy procedures for patient's medical records
and other patient health information to determine what additional procedures
need to be implemented to be in compliance. Model forms for patient consent
and autorization, forms to track releases of patient information and a model
business associate contract are also included in the manual; all materials
can be downloaded and printed with the name of your practice.
Becoming more aware of
how health information is currently handled in your office is a start. You
and your staff probably can handle any modifications needed to comply with
the privacy regulations. Hiring a consultant to bring your office into compliance
with HIPAA should only be done after a review of the free AOA manual. At this
time the AOA manual covers only the HIPAA privacy regulations, but when the
HIPAA security regulations are issued in final form, a security supplement
will be issued.
For questions about the
AOA HIPAA manual, contact Janet Horan, JD, Director, AOA Division of Socioeconomic
Affairs at (800) 621-1773, extension 8187 or by email at
jhoran@aoa-net.org
General questions about
HIPAA may be posted to the DO-Online Practice Management Discussion Board
and will be answered by the AOA staff.