Meaningful Use Stage 2 NPRM Ramps Up HIE With electronic health information exchange (“HIE”) leaping out of the 132-page Meaningful Use Stage 2 Notice of Proposed Rulemaking (“Stage 2 NPRM), it is clear that while Stage 2 will continue to afford flexibility to eligible professionals...
Proposed Rule for Meaningful Use Stage 2 Released Yesterday, the Meaningful Use Stage 2 Proposed Rule was made available on the Office of the Federal Register Electronic Public Inspection Desk. The Proposed Rule will be published March 7 and will be open for public comment for sixty...
Feb 29th is Last Day to Report Breaches of <500 to HHS! For those that have been logging their “small” Breaches (i.e., less than 500 individuals affected) and waiting to report them to HHS at the end of the year, next Wednesday, February 29th is the LAST day to get your information entered into...
HITECH Omnibus and AOD Rules Set for OMB Review Health Data Management reports that the long-awaited HITECH Omnibus Rule as well as the Accounting of Disclosures (AOD) Rule are set for OMB review. Expected also are proposed regulations for Meaningful Use Stage 2. HHS released its...
“Tapping” Apps for Physician Advice: No Waiting Room Necessary This past week, I stumbled across a fascinating article by Michael Millenson on the Health Care Blog (originally on Forbes.com) that I almost bypassed entirely. Described as a “social media darling”, the article focused on...
When DHHS published its Proposed ACO Rule in April 2011 and then the Final ACO Rule in November 2011 (I’ll refer to them as the “ACO Rules”), discussions focused predominately on issues such as who is “qualified” to participate, what the required governance structure should be, what methodology will be used to assign Medicare beneficiaries, and what the payment models will be. However, as I digested the ACO Rules, my reading deliberately slowed down as I zeroed in on the not unremarkable language and comments CMS included with regard to sharing individually identifiable health information in the ACO context.
State AG Brings First HIPAA Lawsuit Against Business Associate Last month, I posted how treatment of business associates during HIPAA investigations remains unclear as well as assignment of liability for breaches of PHI. A final “omnibus rule” is expected to clarify the HITECH business...
CMS Provides Guidance on Meaningful Use Appeals Process CMS has released additional guidance for hospitals and eligible professionals on the Medicare EHR Incentive Program appeals process. The CMS Office of Clinical Standards and Quality (OCSQ), together with Provider Resources, Inc.,...
Over billion paid in Meaningful Use Incentive Payments and Counting In a report submitted to the Health Information Technology Policy Committee on January 10th, CMS highlighted progress in the Medicare and Medicaid EHR Incentive Programs (“Meaningful Use”) and registration and...
Helen Oscislawski Invited to Speak at National HIPAA Summit I attend the annual National HIPAA Summit in Washington D.C. every year to keep on top of developments with HIPAA and related topics, and so I was thrilled to find out that one of the Co-Chairs of the ONC Privacy and Security Tiger Team...
Yet Another Class-Action Filed After Breaches of Patient Data In what appears to be the trend in California for 2011, another class-action lawsuit has been filed, this time by patients of the University of California-Los Angeles (UCLA) Health System affected by a data breach in early...
OIG Releases New Fraud and Abuse Advisory Opinion Involving EHR Data Exchange On December 7, 2011, the Office of the Inspector General (OIG) released an Advisory Opinion regarding a proposed coordination service to facilitate the electronic exchange of data for patient referral...
OCR Director Reaffirms Commitment to Strengthening Privacy and Security of EHRs It’s no secret that since the days of its enactment, HIPAA enforcement has been lacking on both civil and criminal fronts from the Office of Civil Rights (OCR) and the Department of Justice (DOJ). However,...
California HIE Demonstration Projects to Move Ahead with Opt-In Framework This past Wednesday, the California Office of Health Information Integrity (CalOHII) released a comprehensive whitepaper examining patient consent and other HIE framework efforts for entities participating in the...
Federal Government Releases Updated DURSA for NHIN Participants An Amended and Restated DURSA dated May 3, 2011 was released November 30, 2011. The DURSA is an acronym for the “Data Use and Reciprocal Support Agreement.” It is a comprehensive agreement to govern the exchange of health...