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HIPAA COORDINATOR CONFERENCE CALL
February 7, 2002
Attending: Ric Weller (AB), Jennifer Jenkins (BM), Deborah Burkybile (NA),
Tony Davis (NAV), George Chiarchiaro and Angela Kihega (OK), Cheryl Bittle (PO),
Sandra Lahi (ITSC), and from HQ Rockville, Bob Harry, Ileane Hawkins, Elmer
Brewster, Godwin Odia and Frank Martin.
Sandra Lahi, the Business Office Liaison working at ITSC reported that the
270 and 271 form for eligibility benefit inquiry and response were now HIPAA
compliant. She said that the 835, payment/advice and 837, health/dental claim
forms were being formatted by a contractor and should be HIPAA compliant by
April. She said that Areas need to assure the HIPAA compliant packages have
been received and installed at the correct locations in the Area. It was reported
that although there are other electronic forms that may be used in the billing
process there were not being formatted in HIPAA compliant format because the
IHS does not use them. Elmer Brewster said that he was in the process of confirming
the non-use with Area Business Office staff. Sandra Lahi said that there was
no change in the way the forms looked so training in their use was not needed.
Cheryl Bittle asked that the Areas be sent a letter from ITSC stating that the
forms IHS uses are/will be HIPAA compliant by the October 16, 2002. This verification
is needed when meeting with Medicaid and Medicare to demonstrate that the IHS
will be HIPAA compliant by the due date.
Bob Harry presented the modification process that is presently going on with
the HIPAA Privacy Standards. He pointed out that with in a one and a half week
period the Office of Civil Rights (OCR) issued three phases of modifications
to the Privacy Standards and the program had 2-3 days to respond to the modifications.
He said that the modification and guidance process would continue until July.
The modifications reduce the requirements to comply with the standards. He
said the IHS would proceed with its HIPAA Privacy forms and policy development
and incorporate the modifications as they were issued.
It was explained that forms and policies were being developed by small groups
mostly with medical records background and privacy background and then reviewed
by lawyers with knowledge of HIPAA requirements. Bob Harry stated that there
was to be another small group meeting in February to determine what additional
forms and policies needed to be developed and to start their development. Based
on their progress, there could be another meeting with the lawyers in March.
Materials developed by these groups will be shared with the Area HIPAA Coordinators.
Bob Harry told the group that he hoped to have a HIPAA training session in
August but with the new changes in meeting requirements he was not sure if it
could be done. He explained that HHS had increased the requirements needed
for meeting approval. The paper work for requesting the meeting has been started
and the coordinators will be informed of the status. The meeting may be for
Area and facility staff or it may have to be reduced in size to be Area staff
only. The Area staff would then have to train facility staff. He asked coordinators
to let him know what they felt would be the best approach to the meeting.
Next was a discussion on the awareness training that has been taking place
in the Areas. Cost varied from $3.00 a person using pamphlets to $120 a person
with outside trainers being used to present to Area facility staff. WEB training
had been used and cost $20 a person. This cost can be reduced if more people
are enrolled. The level of information provided varied with the Area meetings
using outside presenters providing the most in-depth information.
Bob Harry said that he was preparing a memorandum to Area Directors on the
need for HIPAA training. It should be sent by the end of February.
There was a discussion on the Business Associate Agreement (BAA) that is required
by the Privacy Standards. OCR provided guidance on the BAA to be used to develop
ample BAA language for use. Sandra Lahi and Elmer Brewster are also reviewing
the BAA requirements and will inform us of the effect it will have on the Business
Office.
Bob Harry said the HIPAA responsibilities of were discussed with Area lead
negotiators and contract specialists. He encouraged the Area HIPAA coordinators
to discuss this issue with IHS Lead Negotiators and Contract Officers to determine
how they want to approach it. The Bemidji Area reported that they were working
with the tribes in the Area on becoming HIPAA compliant.
Tony Davis stated that at recent HIMSS meeting he attended a session on HIPAA
and they recommended that if an organization has an internal auditor, this person
should be on the HIPAA Committee.
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