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FW: HIPAA BA for a CRN?

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  • Denese Foltz
    2ND REQUEST PLEASE Hi, I am asking on behalf of a friend since this is not my arena so please be patient if I don t make sense. She is a CRN-FA and makes her
    Message 1 of 5 , May 1 4:14 PM
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      2ND REQUEST PLEASE



      Hi,

      I am asking on behalf of a friend since this is not my arena so please
      be patient if I don't make sense.

      She is a CRN-FA and makes her living by being on call to physicians as
      an assistant in surgeries for high risk delivery patients. She does not
      get paid by the physicians or the Hospital. She bills the same codes as
      the physician using the modifier 80 for her assist and bills under her
      own Tax ID of which many carriers pay her and she's been doing this for
      many years without incident. She did mention that CRN's now don't get
      the same privileges that she does since some law drew the line some time
      ago (I'm not sure of that areas guidelines).



      The question is this; does she need to sign a BA or something to cover
      PHI of the patients she bills her services for? She is close to
      retirement and basically self employed. Or does she fall into the small
      office category and need to go through all the extra compliance issues
      we do? I'm thinking she just needs to have the physicians that she
      assists (and where she obtains the PHI for her billing) give her a BA to
      sign, yes? Would she need to sign one for each of the physicians who
      are each under separate Tax ID # themselves?



      I hope I made sense and gave enough info to help her get this taken care
      of and is there anything else under HIPAA that she needs to be aware of
      in her scenario?

      Your help is greatly appreciated,

      Denese





      [Non-text portions of this message have been removed]
    • Dionne Wright
      Denese, I would advise her to do a BA-- always better safe than sorry, and they are not that difficult to do. But, if the doctors do not pay her, I don t know
      Message 2 of 5 , May 1 4:31 PM
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        Denese,
        I would advise her to do a BA-- always better safe than sorry, and they
        are not that difficult to do. But, if the doctors do not pay her, I
        don't know if she would qualify as a "vendor". She may just need
        something internally for her own business records showing that she (as
        an independent tax id) is compliant.

        I don't know if this will help, but there are software suites out there
        (you may be able to download one) that talk you through whether or not
        you need to follow HIPAA and who also track your current compliance. I
        used a great software called "HIPAA Says" that had a computerized
        questionnaire that talked me through all of the compliance requirements
        for a clinic where I was the Business Manager, and customized our
        requirements based on number of employees. It also merged your
        information into helpful documents like BA's and Internal Policies.
        Made the process quite easy. I am unsure of the cost, as I did it quite
        a while ago, but I still have a contact number in my files of
        1-866-447-2279. (No promises on if they still are offering this, or are
        even open.) If not, there are a lot of others out there, and many
        online sites offer sample BA's that she can plug her name into.

        Dionne Wright
        Sagebrush Professional Services
        phone 505.922.8980
        fax 505.922.8980
        dwright73@...


        -----Original Message-----
        From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
        Denese Foltz
        Sent: Sunday, May 01, 2005 4:14 PM
        To: codingpro-l@...
        Cc: intelicode@...; CRN-L@yahoogroups.com
        Subject: [CRN-L] FW: HIPAA BA for a CRN?

        2ND REQUEST PLEASE



        Hi,

        I am asking on behalf of a friend since this is not my arena so please
        be patient if I don't make sense.

        She is a CRN-FA and makes her living by being on call to physicians as
        an assistant in surgeries for high risk delivery patients. She does not
        get paid by the physicians or the Hospital. She bills the same codes as
        the physician using the modifier 80 for her assist and bills under her
        own Tax ID of which many carriers pay her and she's been doing this for
        many years without incident. She did mention that CRN's now don't get
        the same privileges that she does since some law drew the line some time
        ago (I'm not sure of that areas guidelines).



        The question is this; does she need to sign a BA or something to cover
        PHI of the patients she bills her services for? She is close to
        retirement and basically self employed. Or does she fall into the small
        office category and need to go through all the extra compliance issues
        we do? I'm thinking she just needs to have the physicians that she
        assists (and where she obtains the PHI for her billing) give her a BA to
        sign, yes? Would she need to sign one for each of the physicians who
        are each under separate Tax ID # themselves?



        I hope I made sense and gave enough info to help her get this taken care
        of and is there anything else under HIPAA that she needs to be aware of
        in her scenario?

        Your help is greatly appreciated,

        Denese





        [Non-text portions of this message have been removed]



        ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
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        ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

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      • mbbielinsk@aol.com
        Since she s providing care and billing for her own services, it appears to me that she s a covered entity so I don t think a BA is necessary. The frequently
        Message 3 of 5 , May 1 7:50 PM
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          Since she's providing care and billing for her own services, it appears to
          me that she's a covered entity so I don't think a BA is necessary.

          The frequently asked questions on the HIPAA website might shed some light on
          this.

          _http://www.hhs.gov/ocr/hipaa/_ (http://www.hhs.gov/ocr/hipaa/)

          ~M. Bridget Bielinski, JD, CPC
          Practice Administrator
          Aspen Medical Care, PC

          **************************************************************
          This email and any files transmitted with it are confidential and intended
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          except where the sender specifies and with authority, states them to be the
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          In a message dated 5/1/2005 5:14:50 P.M. Mountain Daylight Time,
          denny623@... writes:

          2ND REQUEST PLEASE



          Hi,

          I am asking on behalf of a friend since this is not my arena so please
          be patient if I don't make sense.

          She is a CRN-FA and makes her living by being on call to physicians as
          an assistant in surgeries for high risk delivery patients. She does not
          get paid by the physicians or the Hospital. She bills the same codes as
          the physician using the modifier 80 for her assist and bills under her
          own Tax ID of which many carriers pay her and she's been doing this for
          many years without incident. She did mention that CRN's now don't get
          the same privileges that she does since some law drew the line some time
          ago (I'm not sure of that areas guidelines).



          The question is this; does she need to sign a BA or something to cover
          PHI of the patients she bills her services for? She is close to
          retirement and basically self employed. Or does she fall into the small
          office category and need to go through all the extra compliance issues
          we do? I'm thinking she just needs to have the physicians that she
          assists (and where she obtains the PHI for her billing) give her a BA to
          sign, yes? Would she need to sign one for each of the physicians who
          are each under separate Tax ID # themselves?



          I hope I made sense and gave enough info to help her get this taken care
          of and is there anything else under HIPAA that she needs to be aware of
          in her scenario?

          Your help is greatly appreciated,

          Denese





          [Non-text portions of this message have been removed]



          ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
          CLICK ME LINKS:
          CodeCorrect 10% off for CRN Members when you sign up at
          http://crn.codecorrect.com 15% off for Gold Members - contact Laureen@...
          for details.

          Optimize physician service reimbursement compliantly: http://www.cfs-billi
          ng.com

          CEU TeleCourseTM Training & Videos
          http://www.crn-institute.com

          ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

          CRN Homepage:
          http://www.codingandreimbursement.net
          Become a CRN Gold Member!
          http://www.codingandreimbursement.net/GoGold.htm
          Advertiser Options
          http://www.codingandreimbursement.net/advertising.htm

          ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

          Yahoo! Groups Links
















          [Non-text portions of this message have been removed]
        • CPCBONES@aol.com
          I agree with Bridgett, the DHS FAQ s on HIPAA state that if a provier is provding treatment there is no BA necessary. Treatment is an exemption from the
          Message 4 of 5 , May 1 8:17 PM
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            I agree with Bridgett,

            the DHS FAQ's on HIPAA state that if a provier is provding "treatment" there
            is no BA necessary. Treatment is an exemption from the Rule and meets the
            requirement. The question was asked of Medical Device Companies. As we know and
            as DHHS has answered, if the the Medical Device Company is in the providers
            office reviewing records/x-rays and consulting with the physician/provider and
            even going into surgery with the provider then this is considered to be
            "treatment" and no BA or Authorization is required.


            Audio Seminars now available from top presenters. AAPC CEU approved.
            Click on "seminars" at the website below!
            Stanley M. Szelazek, CPC, CPC-H, CCP, CMC, CCAT, ACS - OR,
            President
            account ABILITY Practice Management Consulting Services
            http://www.myaccountability.org/
            National Orthopedic Advisory Board/Decision Health
            National Editorial Advisory Board/Coding Institute
            CRN Gold Facilitator
            (561) 432-5035 Office
            (561) 828-0895 Fax

            This email and any attachments may contain confidential information subject
            to protection under the Federal Standards for Privacy of Individually
            Identifiable Health Information (45 C.F.R. Parts 160 and 164). If you or your
            organization is a "Covered Entity" under the above mentioned regulations, you are
            obligated to treat such information in a manner consistent with the regulations. If
            this email was sent to you in error, (1) you are prohibited from utilizing or
            disseminating this email or any attachments; (2) please immediately delete it
            from your computer and any servers or other locations where it might be
            stored and email Stan@... or call (561)951-7083 advising that you
            have done so. We appreciate your cooperation.


            [Non-text portions of this message have been removed]
          • Denese Foltz
            Thank you everyone, you where very helpful. Denese ... From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of CPCBONES@aol.com Sent: Sunday,
            Message 5 of 5 , May 2 1:22 AM
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              Thank you everyone, you where very helpful.
              Denese



              -----Original Message-----
              From: CRN-L@yahoogroups.com [mailto:CRN-L@yahoogroups.com] On Behalf Of
              CPCBONES@...
              Sent: Sunday, May 01, 2005 8:17 PM
              To: CRN-L@yahoogroups.com
              Subject: Re: [CRN-L] FW: HIPAA BA for a CRN?

              I agree with Bridgett,

              the DHS FAQ's on HIPAA state that if a provier is provding "treatment"
              there
              is no BA necessary. Treatment is an exemption from the Rule and meets
              the
              requirement. The question was asked of Medical Device Companies. As we
              know and
              as DHHS has answered, if the the Medical Device Company is in the
              providers
              office reviewing records/x-rays and consulting with the
              physician/provider and
              even going into surgery with the provider then this is considered to be
              "treatment" and no BA or Authorization is required.


              Audio Seminars now available from top presenters. AAPC CEU approved.
              Click on "seminars" at the website below!
              Stanley M. Szelazek, CPC, CPC-H, CCP, CMC, CCAT, ACS - OR,
              President
              account ABILITY Practice Management Consulting Services
              http://www.myaccountability.org/
              National Orthopedic Advisory Board/Decision Health
              National Editorial Advisory Board/Coding Institute
              CRN Gold Facilitator
              (561) 432-5035 Office
              (561) 828-0895 Fax

              This email and any attachments may contain confidential information
              subject
              to protection under the Federal Standards for Privacy of Individually
              Identifiable Health Information (45 C.F.R. Parts 160 and 164). If you or
              your
              organization is a "Covered Entity" under the above mentioned
              regulations, you are
              obligated to treat such information in a manner consistent with the
              regulations. If
              this email was sent to you in error, (1) you are prohibited from
              utilizing or
              disseminating this email or any attachments; (2) please immediately
              delete it
              from your computer and any servers or other locations where it might be
              stored and email Stan@... or call (561)951-7083
              advising that you
              have done so. We appreciate your cooperation.


              [Non-text portions of this message have been removed]



              ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
              CLICK ME LINKS:
              CodeCorrect 10% off for CRN Members when you sign up at
              http://crn.codecorrect.com 15% off for Gold Members - contact
              Laureen@... for details.

              Optimize physician service reimbursement compliantly:
              http://www.cfs-billing.com

              CEU TeleCourseTM Training & Videos
              http://www.crn-institute.com

              ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

              CRN Homepage:
              http://www.codingandreimbursement.net
              Become a CRN Gold Member!
              http://www.codingandreimbursement.net/GoGold.htm
              Advertiser Options
              http://www.codingandreimbursement.net/advertising.htm

              ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~

              Yahoo! Groups Links
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