Hipaa in the field of Dev. Disabilities

116169 · April 2004

I am unclear as to what Hipaa regulations pertain to our clientele. Does anyone else work in the field of Developmental Disabilities?

I have established that as an employer we are "Hands off" of employees PHI, but we do help our clients pay medical premiums, attend doctors appointments, assist them with medications, and recieve faxes of doctors orders etc... What do we need to have in place inorder to stay in Hipaa compliance?

gateway · April 2004

We are an ICF/MR provider, and we are doing a notification to our residents. We also have signed business associate agreements with our consultants (pharmacist, dietician, psych.) We have also come up with a policy that deals with use and disclosure of health information.

116169 · April 2004

Would you mind sharing a copy of the forms you use and the policy you created? Any help is appreciated.

My email is [email]kplandel@residentialresources.org[/email]
and the fax is 360-577-9093

SMace · April 2004

Although you say your "hand-off" to your ee's, you sound "hands-on" to your clients and in my opinion must be HIPAA compliant. It sounds like it would be the same as a health care provider minus the transmission of claims. You need to contact an attorney. Although this is a great place to get info, your not going to get enough information to cover your aXX.

KathiHR · April 2004

We are in VR/MR/DD. In addition to the above, part of our intake assessment includes a sheet where they (or guardian) sign off on all the parties that may end up with access to confidential info in the course of their duties, such as staff who work with them, case managers, potential employers (in the case of VR), etc. We also have a very stringent confidentiality policy in place that employees are trained in & sign a confidentiality statement.

We do get into some gray areas - particularly with VR. We're trying to place them in employment & our staff have to be able to discuss the clients' situations with an employer when trying to place.

116169 · April 2004

We have confidentiality in general very well covered, I was unclear if there needs to be certain language used in order to be in compliance with Hipaa. Sounds like adding some verbage to our current forms may be the simplest route.

Thank you very much for your feedback.

SMace · April 2004

[font size="1" color="#FF0000"]LAST EDITED ON 04-16-04 AT 11:00AM (CST)[/font][br][br]Yes, you need a lot of certain language to be in compliance with HIPAA. I think you will need more than some verbage added to your current forms. Contact your attorneys.

SMace · April 2004

I just found a website that will give you all the language. Place a pillow below your jaw before you open it. x:D [url]http://aspe.os.dhhs.gov/admnsimp/index.shtml[/url]

Nina I · April 2004

I would be very interested in hearing how you comply with the act - we are a non-profit that puts disabled individuals into jobs - we handle medical information on a regular basis, but we do not fit the definition of a covered entity, per se. We have protocols in place to safeguard the information, but wonder if we need to do anything else for HIPAA, in our situation? Any help would be appreciated.

catlady · May 2004

I don't know if you got an answer yet - but I just left an org just like yours in Michigan. We did extensive research into this and ended up purchasing a manual that had all the sample documents, forms, etc that we needed. It was a lifesaver! We did consider ourselves to be a covered entity because we were engaged in rehabilitation (by training disabled people for and placing them into jobs). If you look in the HIPAA regs, you will see the definition of health care includes "rehabilitation". If you participate with CARF, you can get the name of the attorney (I don't remember it) who did conferences for them on this topic and who sold the manual. It was about $800 but well worth every penny!! If you aren't a CARF agency, email me back and I will try to find out the name from my old company. I think he was located in Alexandria VA.

Nina I · May 2004

Thanks so much for the info - no other answers yet...we are not CARF'd, as we don't actually perform rehabilitation - it's more placing disabled into supported employment work. Any info or resources you could give me would be really appreciated!

Nina I · May 2004

Thanks so much for the info - no other answers yet...we are not CARF'd, as we don't actually perform rehabilitation - it's more placing disabled into supported employment work. Any info or resources you could give me would be really appreciated!

Nat · May 2004

We are also an ICF/MR facility. We are also hands off for employee PHI but have authorization forms just in case. We are in a unique position regarding clients in that Do we really a provide health services or are we habilitation? There has been a big debate in North Carolina. This is what we have in place:

* Business Associate Agreements with those deemed necessary.
* Authorization Forms (we use these when we are trying to find other placement for clients and need to give and/or receive PHI)
* Notice of Privacy Practices (we give this to new clients and yearly at IPP and to new employees)
* Policies and procedures on how we, as a provider, will handle PHI.

The only electronic claims we file are medicaid and they provided the compliance information and software.

Hipaa in the field of Dev. Disabilities

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