Confidentiality, Privacy and Security

42 CFR Part 2 Changes - TPO

  • 1.  42 CFR Part 2 Changes - TPO

    Posted 26 days ago
    Hello Everyone,

    In reading the changes to 42 CFR Part 2 regarding TPO, I would like you input. Would it be acceptable to create an authorization or consent form that is general enough to say that the patient agrees for us to release their PHI (SUD) for the purpose of TPO? Let me know your thoughts on what others will be doing.

    ------------------------------
    Sherry Curtis
    Health Information Manager
    ------------------------------


  • 2.  RE: 42 CFR Part 2 Changes - TPO

    Posted 26 days ago
    As a part 2 provider disclosing patient information.

    ------------------------------
    Sherry Curtis
    Health Information Manager
    ------------------------------



  • 3.  RE: 42 CFR Part 2 Changes - TPO

    Posted 25 days ago
    I definitely think so. This will make it easy for staff to release necessary documents. 
    Our facility ask the patient to complete a release form.  

    Victoria Maans 





  • 4.  RE: 42 CFR Part 2 Changes - TPO

    Posted 23 days ago
    Hi,

    We currently have the client sign an auth to release a separate auth to release information for benefit purposes (claims, eligibility, etc).  We also include in the privacy notice that we will use the information for TPO.  We obtain separate authorization for release to other providers for tx purposes.  Is this new rule saying we need to have authorization to release information for tx purposes to other staff within the same Part 2 facility.

    I am unclear what is specifically different with this revision to Part 2.

    Would love some clarification.

    Thank you,

    ------------------------------
    Kathryn Boyes
    Director, HIM
    ------------------------------



  • 5.  RE: 42 CFR Part 2 Changes - TPO

    Posted 23 days ago
    My first sentence should read....We currently have the client sign a separate auth to release information for benefit purposes (claims, eligibility, etc).  We also include in the privacy notice that we will use the information for TPO

    ------------------------------
    Kathryn Boyes
    Director, HIM
    ------------------------------



  • 6.  RE: 42 CFR Part 2 Changes - TPO

    Posted 23 days ago
    Looking at this question, in my opinion, reminds us to be mindful that there are separate considerations that need to be made with respect to Treatment, Payment and Operations (health care operations) between 42 Part 2 and HIPAA.  For example, there are different sections in the most recent guidance in the Fed Reg for 42 Part 2 which speak to consents with respect to treatment and with respect to consents for payment and operations.

    Be careful not to approach TPO and the idea of consents from a HIPAA perspective and try to apply it the same way to 42 Part 2 as there are differences.

    ------------------------------
    Frank Ruelas
    Compliance Professional
    Arizona
    ------------------------------



  • 7.  RE: 42 CFR Part 2 Changes - TPO

    Posted 23 days ago
    Check out the thread posted to the  Care Coordination and Maintenance Group

    HHS adopts changes to improve care coordination for substance abuse patients:

    Wanted to share this article from Fierce Healthcare with you. I welcome your thoughts and feedback.
    HHS adopts changes to improve care coordination for substance abuse patients

    FierceHealthcare

    remove preview

    HHS adopts changes to improve care coordination for substance abuse patients

    The Trump administration has revised privacy restrictions on patients' substance use treatment records to improve care coordination. The updated rule is designed to support better care coordination and reduce provider burden while maintaining privacy safeguards for patients, HHS officials said.

    View this on FierceHealthcare >

     

    my reply was :




    ------------------------------
    Julianna Perez
    Compliance Specialist
    ------------------------------



  • 8.  RE: 42 CFR Part 2 Changes - TPO

    Posted 22 days ago
    This seems to really help the non Part 2 providers with exchange of information but does not change those who are Part 2 providers.  Is that right?

    ------------------------------
    Kathryn Boyes
    Director, HIM
    ------------------------------



  • 9.  RE: 42 CFR Part 2 Changes - TPO

    Posted 22 days ago
    One big plus I see is that now individuals can consent for their treatment records to go to "ABC Clinic" and no longer need to be directed to a specific individual at that clinic such as "Dr. Smith at the ABC Clinic".  This has been a problem in the past and has caused some delays...and hopefully this will help minimize these delays and get the information to those who can treat the patient.

    ------------------------------
    Frank Ruelas
    Compliance Professional
    Arizona
    ------------------------------



  • 10.  RE: 42 CFR Part 2 Changes - TPO

    Posted 22 days ago
    Correct.. How do we know / determine if the sending facility i a Part 2 provider/





  • 11.  RE: 42 CFR Part 2 Changes - TPO

    Posted 22 days ago
    Do anyone know if the rule has been published in the Federal Register?  If so, do you have a link?
    Thanks,
    Dovie

    ------------------------------
    Dovie Brady
    Manager, Hipaa Compliance
    Woman's Hospital
    ------------------------------



  • 12.  RE: 42 CFR Part 2 Changes - TPO

    Posted 22 days ago
      |   view attached

    I just received a copy today.
    Dovie

    ------------------------------
    Dovie Brady
    Manager, Hipaa Compliance
    Woman's Hospital
    ------------------------------

    Attachment(s)