Resolution Agreement Stuff

  • 1.  Resolution Agreement Stuff

    Posted 09-19-2020 08:17 AM
    A Resolution Agreement (RA) can provide a useful source of insight as to issues of non compliance that the OCR is encountering.  It also gives some information on how the OCR enforces its position on the obligation of covered entities or business associates to comply with such requirements.  Below are 8 items listed in the recently posted Resolution Agreement at  (https://www.hhs.gov/sites/default/files/aims-resolution-agreement.pdf)

    There are two areas within the Privacy Rules that are particularly noted in the RA: Notice of privacy practices, Access of individuals to protected health information.  As shown below, 3 are associated with the Notice requirements and 5 with Access to PHI.

    I am posting the list below so those interested can take a look and see if any of these may be areas they may want to compare their own state of compliance with these specific requirements. As we have come to see...Access to PHI is one area that the OCR jumps on and often jumps on hard when it learns of non compliance in this area.

    To learn more and to get more context, check out the RA.

    164.520 Notice of privacy practices for protected health information.

    1. Right to Notice – 45 C.F.R. §164.520(a)(1)
    2. Content of Notice – 45 C.F.R. §164.520(b)(1)
    3. Provision of Notice – 45 C.F.R. §164.520(c)

    164.524 Access of individuals to protected health information.

    1. Right of Access – 45 C.F.R. §164.524(a)(1)
    2. Timely Action by the Covered Entity – 45 C.F.R. §164.524(b)(2)
    3. Time and Manner of Access – 45 C.F.R. §164.524(c)(3)
    4. Fees – 45 C.F.R. §164.524(c)(4)
    5. Documentation – 45. C.F.R.§ 164.524(e)
    Probably a good idea to check on your Access to PHI policies and processes...as we've seen in a number of RAs and announcements by the OCR...this is a hot button that gets OCR's attention!

    Posted: Saturday

    -------------Frank "Snake Bite Leader" Ruelas--------------
    ► We don't fail unless we quit! ◄
    Next Up:

    ░ Pass the Exam Group for 2020 ░
    Melissa Singleton - Jan - CHPC
    Julie Clutter - Jan - CHPC
    Tanisha Grant - Feb - CHC
    Lisa Bibby - Jan - CHPC
    Kelly Puida - Mar - CHPC
    Christina Serrano - Mar - CHC
    Rachel Anderson - May - CHC
    Melissa Alexander - June - CHC
    Theresa Veazey - June - CHC
    Barbara Zubeck - June - CHPC
    Patricia Radatz - June - CHC
    Anthony Fleming - July - CHC
    Laura Chaney - July - CHC
    James Maruyama - July - CHC
    Namrita Notani - July - CHC
    Lisa Campbell - August - CHC
    Susan Hammerschmidt - August - CHC
    Brandi Brooks - August - CHC
    Shari Singleton - August - CHC
    Rebecca Crane - August - CHC
    Meagan Bottrell - August - CHC
    Jill Lyons - August - CHC
    Camille Walton - September - CHC
    Danique Flax - September - CHC
    Melanie Schoonover - September - CHPC
    Meghan Smith - September - CHC
    Mandi Quigley - September - CHPC

  • 2.  RE: Resolution Agreement Stuff

    Posted 09-22-2020 09:00 AM

    It's a good idea to review these and the corporate integrity agreements to know what is expected!  Thank you Frank!


    ******************************************* This message and any attachments to it may be confidential and are intended solely for the use of the individual to whom it is addressed. If you are not the named addressee you should not disseminate, distribute or copy this e-mail. Please notify the sender immediately by e-mail if you have received this e-mail by mistake and delete this e-mail from your system.