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A
number of ICAEL accreditation applicants, along with applicants
to other Intersocietal Accreditation Commission (IAC) sister
organizations, have recently inquired into what steps they should
be taking now in order to comply with the privacy standards
that have been promulgated under the Administrative Simplification
Provisions of the Health Insurance Portability and Accountability
Act (HIPAA). As many of you know, on April 12, 2001, Tommy Thompson,
Secretary of Health and Human Services (HHS) announced that
these standards would proceed to an implementation stage beginning
April 14, 2001. However, it is important to remember a couple
of points before considering any changes in the way information
is used, including in the provision of information to the IAC.
First,
although the standards have been finalized, entities covered
by the standards, such as vascular, echocardiography, nuclear
medicine and magnetic resonance imaging laboratories which engage
in electronic standard transactions, have two years from
the effective date to come into compliance with the standards.
This means that covered entities have until April 14, 2003
to comply with the standards. HHS indicated in the Preamble
to the standards that it will not seek the imposition
of penalties prior to the compliance date.
Second,
in his announcement, Mr. Thompson referred to the possibility
of further changes to the privacy standards when he stated that
HHS will be issuing guidelines which "...will allow us
to clarify some of the confusion regarding the impact this rule
might have on health care delivery and access." He also
added that "...we will consider any necessary modifications
that will ensure the quality of care does not suffer inadvertently
from this rule." In fact, the IAC is currently working
with representatives of HHS to see that certain clarifications
or modifications are made to the standards to ensure that the
standards do not undermine accreditation functions and jeopardize
quality of care.
So,
in considering compliance with HIPAA's privacy standards, accreditation
applicants should realize in determining how and what information
to provide the ICAEL and other accrediting bodies of the IAC
that they are not required to meet the privacy standards
prior to April 14, 2003.
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