NPI - National Provider Identifier (USA)

[Guest guest]

Hi all,

 

In the editorial of the USA trade magazine Acupuncture Today, April

2006, Marilyn Allen mentioned a NPI or 10 digit identifier as

necessary for L.Ac., by May 2007.

 

Having examined the government websites, it's clear that only those

who bill Medicare or Medicaid using electronic transmission (i.e. not

paper, telephone or fax) are required to get this new identifier.

Furthermore, there's an exemption for providers / groups of less than

10 employees (unless you/they do electronic transmissions).

 

This is all under the auspices of the the " Administrative Compliance

Standards " of the HIPPA act. Other requirements, under the " Privacy

and Security Standards " of the same act, do apply to us all (in the

USA), as most are probably aware.

 

I can supply the URL's for this information if anyone wants to take a look.

 

 

[Guest guest]

US members: While the HIPAA regs only apply to those electronically billing

and those with more than 10 employees, EVERY practitioner will need one of

these numbers to print on a bill so that their patients can get insurance

reimbursement ­ REGARDLESS of billing and group size. This number will be

required by insurance companies.

 

The Url is https://nppes.cms.hhs.gov/

 

Valerie Hobbs

 

 

On 4/29/06 4:11 AM, " " < wrote:

 

> Hi all,

>

> In the editorial of the USA trade magazine Acupuncture Today, April

> 2006, Marilyn Allen mentioned a NPI or 10 digit identifier as

> necessary for L.Ac., by May 2007.

>

> Having examined the government websites, it's clear that only those

> who bill Medicare or Medicaid using electronic transmission (i.e. not

> paper, telephone or fax) are required to get this new identifier.

> Furthermore, there's an exemption for providers / groups of less than

> 10 employees (unless you/they do electronic transmissions).

>

> This is all under the auspices of the the " Administrative Compliance

> Standards " of the HIPPA act. Other requirements, under the " Privacy

> and Security Standards " of the same act, do apply to us all (in the

> USA), as most are probably aware.

>

> I can supply the URL's for this information if anyone wants to take a look.

>

>

>

>

>

> Subscribe to the new FREE online journal for TCM at Times

> http://www.chinesemedicinetimes.com

>

> Download the all new TCM Forum Toolbar, click,

> http://toolbar.thebizplace.com/LandingPage.aspx/CT145145

>

>

> and adjust

> accordingly.

>

> Messages are the property of the author. Any duplication outside the group

> requires prior permission from the author.

>

> Please consider the environment and only print this message if absolutely

> necessary.

>

>

>

>

>

[Guest guest]

At 08:15 AM 4/29/2006, Valerie Hobbs <valeriehobbs wrote:

 

>US members: While the HIPAA regs only apply to those electronically billing

>and those with more than 10 employees, EVERY practitioner will need one of

>these numbers to print on a bill so that their patients can get insurance

>reimbursement ­ REGARDLESS of billing and group size. This number will be

>required by insurance companies.

>

>The Url is https://nppes.cms.hhs.gov/

 

Valerie,

 

How do you know insurance companies will require the NPI?

 

After extensive broswing last week, there was

nothing I found in the websites that mandates this.

 

Is there something there I overlooked? Or have

you seen some policy being adapted by an insurance co. trade organization?

 

 

[Guest guest]

A quick google search with ³national provider number + insurance

requirement² yielded several examples. Here is a link to a FAQ section from

Securian insurance company which deals with dental insurance.

http://www.securiandental.com/npiFaq.jsp

 

It directs even those who are doing paper filing to obtain a National

Provider Number. It really isn¹t much of a leap to see this evolving within

a short period of time to great difficulty for your patients to get

reimbursement without it.

 

You are right, there is no mandate per se, but mandates are not the only

reason to register your practice. There is good reason to recognize that

these numbers will become standard operating procedure very, very quickly.

The vast majority of health professionals in the US do electronic billing,

and this is what insurance companies will use as their default in

recognizing a provider. To deal with insurance on any level will be

streamlined by meeting this requirement. Even if the individual practitioner

chooses not to bill insurance, when your patients submit paperwork for

reimbursement, companies will clearly be looking for this number.

 

Valerie

 

 

On 4/29/06 7:52 PM, " " < wrote:

 

> At 08:15 AM 4/29/2006, Valerie Hobbs <valeriehobbs wrote:

>

>> >US members: While the HIPAA regs only apply to those electronically billing

>> >and those with more than 10 employees, EVERY practitioner will need one of

>> >these numbers to print on a bill so that their patients can get insurance

>> >reimbursement ­ REGARDLESS of billing and group size. This number will be

>> >required by insurance companies.

>> >

>> >The Url is https://nppes.cms.hhs.gov/

>

> Valerie,

>

> How do you know insurance companies will require the NPI?

>

> After extensive broswing last week, there was

> nothing I found in the websites that mandates this.

>

> Is there something there I overlooked? Or have

> you seen some policy being adapted by an insurance co. trade organization?

>

>

>

>

>

> Subscribe to the new FREE online journal for TCM at Times

> http://www.chinesemedicinetimes.com

>

> Download the all new TCM Forum Toolbar, click,

> http://toolbar.thebizplace.com/LandingPage.aspx/CT145145

>

>

> and adjust

> accordingly.

>

> Messages are the property of the author. Any duplication outside the group

> requires prior permission from the author.

>

> Please consider the environment and only print this message if absolutely

> necessary.

>

>

>

>

>

[Guest guest]

Chris,

I went to the NPPES site and will share what their info mentions.

 

" The Administrative Simplification provisions of the Health Insurance

Portability and Accountability Act of 1996 (HIPAA) mandated the adoption of

standard unique identifiers for health care providers, as well as the adoption

of standard unique identifiers for health plans. The purpose of these provisions

is to improve the efficiency and effectiveness of the electronic transmission of

health information. The Centers for Medicare & Medicaid Services (CMS) has

developed the National Plan and Provider Enumeration System (NPPES) to assign

these unique identifiers. "

 

It sure sounds to me that the US govt is mandating a numbering system for

healthcare providers. My concern is whether or not our profession intends to

move forward and participate or continue to lose ground.

 

MB

 

 

 

: : Sat,

29 Apr 2006 18:52:02 -0700Re: NPI - National Provider Identifier

(USA)At 08:15 AM 4/29/2006, Valerie Hobbs <valeriehobbs wrote:>US

members: While the HIPAA regs only apply to those electronically billing>and

those with more than 10 employees, EVERY practitioner will need one of>these

numbers to print on a bill so that their patients can get

insurance>reimbursement ­ REGARDLESS of billing and group size. This number will

be>required by insurance companies.>>The Url is

https://nppes.cms.hhs.gov/Valerie,How do you know insurance companies will

require the NPI?After extensive broswing last week, there was nothing I found in

the websites that mandates this.Is there something there I overlooked? Or have

you seen some policy being adapted by an insurance co. trade organization?Chris

Macie Subscribe to the new FREE online journal for TCM at Times

http://www.chinesemedicinetimes.com Download the all new TCM Forum

Toolbar, click, http://toolbar.thebizplace.com/LandingPage.aspx/CT145145To

change your email delivery settings, click,

and adjust

accordingly. Messages are the property of the author. Any duplication outside

the group requires prior permission from the author.Please consider the

environment and only print this message if absolutely necessary.

 

[Guest guest]

Mike, Valerie, all,

 

A colleague of mine asked me to help research the

requirements of the NPI situation, after reading

Marilyn Allen's heads-up in Acu-Today, and coming

across some mention of exemptions. This colleague

is MD of 34 years, L.Ac. of 27 years, MBA

Stanford, former administrator of a health plan,

and now in a private practice which bills

entirely out-of-network, and does all billing,

including medicare, by paper. The issue

originally concerning me was: what does the HIPPA

Administrative Simplification Compliance Standard really say.

I spent several hours on Wednesday at the NPPES

website and related ones; read and downloaded

everything that looked relevant. Notably:

 

1) NPI_rule_04-1149.pdf complete text of " 45 CFR

Part 162 HIPPA Administrative Simplification:

Standard Unique Health Identifier for Health Care

Providers; Final Rule " (from the Federal Register, DHHS)

 

37 pages, blow-by-blow history of considerations,

alternatives, and the decision making process and

rationale for the NPI ruling, as well as the final results.

 

2) The website takes pains to help interested

parties decide if the Standard applies to them

(if they are " covered entities " ):

a) 06_AreYouaCoveredEntity.asp.htm " Covered Entity Decision Tools "

b) CoveredEntitycharts.pdf flow-charts and detailed definitions

 

Providers who do not submit electronically are

NOT required to obtain an NPI, although they are " encouraged " to do so.

 

3) FAQ (frequently-asked questions) items:

a) " Do the HIPAA transactions and code

sets standards apply to paper claims and other

non-electronic transactions? " (Answer NO…)

b) " Are small providers exempt from HIPAA? "

Answer: " The term 'small providers' originates

in the Administrative Simplification Compliance

Act (ASCA), the law which requires those

providers/submitters who bill Medicare to begin

submitting only electronic claims to Medicare on

October 16, 2003 in the HIPAA format. However,

ASCA does provide an exception to the Medicare

electronic claims submission requirements to

'small providers'. ASCA defines a small provider

or supplier as: a provider of services with fewer

than 25 full-time equivalent employees or a

physician, practitioner, facility or supplier

(other than a provider of services) with fewer

than 10 full-time equivalent employees. "

 

Then I ran a summary of this information by you

folks late Friday night, to check if others could

supply further information, fill in gaps I'd missed, etc.

 

I have a further concern now that the two

responses seemed to me to miss the point of

simply forming a clear understanding of what the

law states, and letting acupuncturists know what their options are.

 

>… EVERY practitioner will need one of

>these numbers to print on a bill so that their patients can get insurance

>reimbursement ­ REGARDLESS of billing and group size. This number will be

>required by insurance companies.

 

On questioning this assertion, the one URL

offered was simply a restatement of info from the

NPPES site, with some additional info for

dentists (their taxonomy categories). This

response asserts things which might be supposed

to eventually pertain, but for which there has

been no conclusive evidence shown that this is

now the case. HIPPA was passed in 1998; the NPI

is going into effect, with limited scope, in

2007. There's a 9-year latency there. That " …

these numbers will become standard operating

procedure very, very quickly " could be seen as something of a leap.

 

2) " >It sure sounds to me that the US govt is

mandating a numbering system for healthcare

providers. My concern is whether or not our

profession intends to move forward and participate or continue to lose ground. "

 

Mandated is an NPI for " covered entities " and

certain transactions electronically transmitted.

I don't see where " moving forward " or " los[ing]

ground " has anything to do with understanding

one's options in terms of the documented facts of the situation.

 

Facit:

 

1) At the moment, providers who do not transmit

forms electronically (and Medicare/Medical forms

from small providers don't have to be) are not required to obtain an NPI.

 

2) Assertions that insurance plans will require

use of NPI by all are, so far, long on rhetoric

and short on evidence. Arguably it will take some

time, advance preparation, and perhaps even a

more comprehensive legal mandate. Compare how

long it takes for ICD-9 code assignments.

 

3) " >The vast majority of health professionals

in the US do electronic billing… " I don't. I

don't know of an acupuncturist who does. There

are, doubtless, some, maybe many that do. My

sense of HIPPA (from reading the " final rule " and

its careful consideration and allowance for

exceptions) is that pluralism and legacy

practices are respected. The phasing-out of paper

documents has been forecast in the " electronic

revolution " for decades now, and the use of paper

(as well as recycling) has in fact been steadily increasing.

 

4) " Covered Entities " are to obtain NPI

assignment by that May 23, 2007. Clearly anyone

who is not required, or who does become such an

" entity " after that date, will be able to obtain

an NPI later. They're not going to run out of

numbers (the 9-digit code plus check-sum digit,

has a data space of some 280 million numbers

(999,999,999 minus some sets of unusable or

reserved numbers)). " The Centers for Medicare &

Medicaid Services (CMS) has developed the

National Plan and Provider Enumeration

System. " The NPI replaces Medicare/Medicaid

numbers. If and when the Hinkley bill becomes

law, this issue will be of more immediate concern to acupuncturists.

 

If an insurance plan notifies of requiring NPI

id, it is said to take about 20 days after

application to receive a number, well within the

window of time for submitting claims.

 

5) I believe we deserve to know all the legal

options and exemptions, as well as mandates and

requirements. We all might find it easier to

communicate if we would specify what we write as,

on the one hand, knowledge based on evidence, as

in legal or regulatory, and, on the other hand,

our own attachments, interpretations, suppositions, agendas, etc.

 

 

 

 

[Guest guest]

wrote:

<snip>

> If and when the Hinkley bill becomes law

 

Hi Chris!

 

The *Hinchey* bill is under consideration. It is important that we never

refer to it as " Hinkley " as there is a very negative connotation to the

latter.

 

http://www.law.umkc.edu/faculty/projects/ftrials/hinckley/HBIO.HTM

 

Regards,

 

Pete

[Guest guest]

Chris,

It seems to me that you are relying upon the often quoted phrase about

electronic insr billing but fail to mention that if we store any patient info

(in a computer) that this also means we are covered entities. The mentioning of

superbills for patients brings up one very good reason to consider as well

(patients do want their money also). Lastly, as we hopefully become more

mainstream in hospitals (and Medicare) this argument will be for naught as we

will need to register. I have often found it interesting when some

professionals will look for ways to get out of something. I find it odd that

some decisions need to be made on behalf of what is best for the profession and

the patient, and not simply about us (related to moving fwd as a profession).

All other healthcare professions, that I am aware of, are covered entities. So

why are we even trying to avoid getting ourselves ready? Take care and good

topic.

MB

 

 

: : Mon,

1 May 2006 01:39:41 -0700RE: Re: NPI - National Provider

Identifier (USA)Mike, Valerie, all,A colleague of mine asked me to help research

the requirements of the NPI situation, after reading Marilyn Allen's heads-up in

Acu-Today, and coming across some mention of exemptions. This colleague is MD of

34 years, L.Ac. of 27 years, MBA Stanford, former administrator of a health

plan, and now in a private practice which bills entirely out-of-network, and

does all billing, including medicare, by paper. The issue originally concerning

me was: what does the HIPPA Administrative Simplification Compliance Standard

really say.I spent several hours on Wednesday at the NPPES website and related

ones; read and downloaded everything that looked relevant. Notably:1)

NPI_rule_04-1149.pdf complete text of " 45 CFR Part 162 HIPPA Administrative

Simplification: Standard Unique Health Identifier for Health Care Providers;

Final Rule " (from the Federal Register, DHHS)37 pages, blow-by-blow history of

considerations, alternatives, and the decision making process and rationale for

the NPI ruling, as well as the final results.2) The website takes pains to help

interested parties decide if the Standard applies to them (if they are " covered

entities " ): a) 06_AreYouaCoveredEntity.asp.htm " Covered Entity Decision

Tools " b) CoveredEntitycharts.pdf flow-charts and detailed

definitionsProviders who do not submit electronically are NOT required to obtain

an NPI, although they are " encouraged " to do so.3) FAQ (frequently-asked

questions) items: a) " Do the HIPAA transactions and code sets standards

apply to paper claims and other non-electronic transactions? " (Answer NO…)

b) " Are small providers exempt from HIPAA? " Answer: " The term 'small providers'

originates in the Administrative Simplification Compliance Act (ASCA), the law

which requires those providers/submitters who bill Medicare to begin submitting

only electronic claims to Medicare on October 16, 2003 in the HIPAA format.

However, ASCA does provide an exception to the Medicare electronic claims

submission requirements to 'small providers'. ASCA defines a small provider or

supplier as: a provider of services with fewer than 25 full-time equivalent

employees or a physician, practitioner, facility or supplier (other than a

provider of services) with fewer than 10 full-time equivalent employees. " Then I

ran a summary of this information by you folks late Friday night, to check if

others could supply further information, fill in gaps I'd missed, etc.I have a

further concern now that the two responses seemed to me to miss the point of

simply forming a clear understanding of what the law states, and letting

acupuncturists know what their options are.>… EVERY practitioner will need one

of>these numbers to print on a bill so that their patients can get

insurance>reimbursement ­ REGARDLESS of billing and group size. This number will

be>required by insurance companies.On questioning this assertion, the one URL

offered was simply a restatement of info from the NPPES site, with some

additional info for dentists (their taxonomy categories). This response asserts

things which might be supposed to eventually pertain, but for which there has

been no conclusive evidence shown that this is now the case. HIPPA was passed in

1998; the NPI is going into effect, with limited scope, in 2007. There's a

9-year latency there. That " … these numbers will become standard operating

procedure very, very quickly " could be seen as something of a leap.2) " >It sure

sounds to me that the US govt is mandating a numbering system for healthcare

providers. My concern is whether or not our profession intends to move forward

and participate or continue to lose ground. " Mandated is an NPI for " covered

entities " and certain transactions electronically transmitted. I don't see where

" moving forward " or " los[ing] ground " has anything to do with understanding

one's options in terms of the documented facts of the situation.Facit:1) At the

moment, providers who do not transmit forms electronically (and Medicare/Medical

forms from small providers don't have to be) are not required to obtain an

NPI.2) Assertions that insurance plans will require use of NPI by all are, so

far, long on rhetoric and short on evidence. Arguably it will take some time,

advance preparation, and perhaps even a more comprehensive legal mandate.

Compare how long it takes for ICD-9 code assignments.3) " >The vast majority of

health professionals in the US do electronic billing… " I don't. I don't know of

an acupuncturist who does. There are, doubtless, some, maybe many that do. My

sense of HIPPA (from reading the " final rule " and its careful consideration and

allowance for exceptions) is that pluralism and legacy practices are respected.

The phasing-out of paper documents has been forecast in the " electronic

revolution " for decades now, and the use of paper (as well as recycling) has in

fact been steadily increasing.4) " Covered Entities " are to obtain NPI assignment

by that May 23, 2007. Clearly anyone who is not required, or who does become

such an " entity " after that date, will be able to obtain an NPI later. They're

not going to run out of numbers (the 9-digit code plus check-sum digit, has a

data space of some 280 million numbers (999,999,999 minus some sets of unusable

or reserved numbers)). " The Centers for Medicare & Medicaid Services (CMS) has

developed the National Plan and Provider Enumeration System. " The NPI replaces

Medicare/Medicaid numbers. If and when the Hinkley bill becomes law, this issue

will be of more immediate concern to acupuncturists.If an insurance plan

notifies of requiring NPI id, it is said to take about 20 days after application

to receive a number, well within the window of time for submitting claims.5) I

believe we deserve to know all the legal options and exemptions, as well as

mandates and requirements. We all might find it easier to communicate if we

would specify what we write as, on the one hand, knowledge based on evidence, as

in legal or regulatory, and, on the other hand, our own attachments,

interpretations, suppositions, agendas, etc. [Non-text portions of

this message have been removed]Subscribe to the new FREE online journal for TCM

at Times http://www.chinesemedicinetimes.com Download the all

new TCM Forum Toolbar, click,

http://toolbar.thebizplace.com/LandingPage.aspx/CT145145To change your email

delivery settings, click,

and adjust

accordingly. Messages are the property of the author. Any duplication outside

the group requires prior permission from the author.Please consider the

environment and only print this message if absolutely necessary.

 

[Guest guest]

Mon, 1 May 2006 13:30:38 +0000, " mike Bowser " <naturaldoc1 wrote:

 

> It seems to me that you are relying upon the often quoted phrase

about electronic insr billing but fail to mention that if we store

any patient info (in a computer) that this also means we are covered entities.

 

It's the electronic transmission which defines " covered entity " , not

storage or other use on computer. Transmission between distinct

parties electronically means digitally, over the internet (via email,

FTP, through a website, etc. ). (source: NPPES website, Covered

Entity Decision Tools)

 

>All other healthcare professions, that I am aware of, are covered entities.

 

'Small providers', of any modality, brain surgeons to horse doctors,

who do not transmit (certain) data electronically are NOT NPPES

covered entities. They are free, however, to get an NPI. (See the

footnote definitions in the NPPES Decision Tool document.)

 

> I have often found it interesting when some professionals will

look for ways to get out of something.

> So why are we even trying to avoid getting ourselves ready?

 

Why are some here apparently threatened by my pursuing factual

information? How does that imply I am trying to get out of something,

or trying to convince anyone to not register for theNPI?

 

>I find it odd that some decisions need to be made on behalf of what

is best for the profession and the patient, and not simply about us

(related to moving fwd as a profession).

 

In the USA, this is an ethical issue. I don't know your (Mike's)

nationality, as this is an international forum. I once taught an

ethics course in an acupuncture school here in California. The

students, though many were American citizens, were of various Asian,

European and other national backgrounds (none was a native-born

American). Let me tell you, that was an eye-opener: one culture's

ethical virtue was another culture's criminality. Ethics cannot

apriori assumed to be shared across cultures.

 

In contemporary American medical ethics, however, making decisions

for patients, in the absence of full disclosure and informed consent,

is considered ethically wrong, and possibly legally liable. (This has

not always been so, but the trend in attitudes and the law have moved

strongly in this direction over the past couple of decades.) So, in

this context, Mike's instinct in finding it " odd " is appropriate.

 

Professionalism also implies full disclosure, understanding and

informed consent. In my opinion, fostering this is the duty of those

who would lead the profession.

 

 

 

 

[Guest guest]

Chris,

 

I took the following info off a website to further clarify my understanding of

HIPAA.

 

" Care Providers who choose to conduct certain financial and administrative

transactions electronically – a provider of medical or health services and any

other person or organization who furnishes, bills, or is paid for health care in

the normal course of business. "

 

What this in essence is saying is that if you conduct electronic healthcare

transactions, and yes this includes storage/retrieval of patient info

(administrative actions). I seem to remember Marilyn Allen referring to this as

well (not sure when). These two things are intimately tied together.

 

I have found that most surgeons use a hospital (usage of EMR's) and both will

need to have a number if they want to get paid by the insr. The hospital

submits a UB92 (think that is still its designation) and the provider now uses a

CMS-1500.

 

I applaud you for seeking out info but some within the profession are instead

seeking a loophole, which I think you can still find as long as you do not

conduct your business as mentioned above. I have often noted that many within

our profession tend to look for ways to avoid being a mainstream practitioner

and this includes the way we conduct our practices. It sounds like you are

looking for inclusion.

 

I am also a CA trained pracitioner who has served as an instructor for two TCM

colleges in the midwest. Like Chris, I have been dismayed by the relative lack

of ethics.

 

I think we have a long way to go in order to raise our standards.

 

MB

_______________

Enter the Windows Live Mail beta sweepstakes

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[Guest guest]

At 01:33 PM 5/2/2006, " mike Bowser " <naturaldoc1 wrote:

 

> " Care Providers who choose to conduct certain

>financial and administrative transactions

>electronically ­ a provider of medical or health

>services and any other person or organization

>who furnishes, bills, or is paid for health care

>in the normal course of business. "

>

>What this in essence is saying is that if you

>conduct electronic healthcare transactions, and

>yes this includes storage/retrieval of patient

>info (administrative actions). I seem to

>remember Marilyn Allen referring to this as well (not sure when).

 

I'm sorry, but you'll have to provide more

concrete evidence to support your interpretation

( " in essence is saying " ). Maybe having heard

Marilyn Allen mention something related is not evidence.

 

Local (in house/clinic) storage/retrieval is not

transmission, which, in the framework of this law

refers to transfer of information between

distinct covered entities (as in the definitions

on the website). The whole point of HIPPA, in

case you haven't noticed, is the

COMMUNICATION/TRANSMISSION (and privacy,

security, administrative simplification, etc.) of patient data.

 

Local patient data computer files need to be

secure, just like chart-files etc. But this is

part of the Privacy Standard aspect of HIPPA.

 

 

[Guest guest]

Chris,

You seem to be quite hung up with trying to separate the actual transmission

from storage and that is not a distinction that I have seen as I had quoted

previously. I am unaware of any entity that only stores data, so I think this

issue might be mute. Again, I am not sure why you are pursuing this line of

thought as opposed to finding out how to sign up and become mainstream. Let me

know what you find out. Later

MB

 

 

: : Tue,

2 May 2006 14:22:10 -0700RE: Re: NPI - National Provider

Identifier (USA)At 01:33 PM 5/2/2006, " mike Bowser " <naturaldoc1

wrote:> " Care Providers who choose to conduct certain >financial and

administrative transactions >electronically ­ a provider of medical or health

>services and any other person or organization >who furnishes, bills, or is paid

for health care >in the normal course of business. " >>What this in essence is

saying is that if you >conduct electronic healthcare transactions, and >yes this

includes storage/retrieval of patient >info (administrative actions). I seem to

>remember Marilyn Allen referring to this as well (not sure when).I'm sorry, but

you'll have to provide more concrete evidence to support your interpretation

( " in essence is saying " ). Maybe having heard Marilyn Allen mention something

related is not evidence.Local (in house/clinic) storage/retrieval is not

transmission, which, in the framework of this law refers to transfer of

information between distinct covered entities (as in the definitions on the

website). The whole point of HIPPA, in case you haven't noticed, is the

COMMUNICATION/TRANSMISSION (and privacy, security, administrative

simplification, etc.) of patient data.Local patient data computer files need to

be secure, just like chart-files etc. But this is part of the Privacy Standard

aspect of HIPPA.Subscribe to the new FREE online journal for TCM at

Times http://www.chinesemedicinetimes.com Download the all new

TCM Forum Toolbar, click,

http://toolbar.thebizplace.com/LandingPage.aspx/CT145145To change your email

delivery settings, click,

and adjust

accordingly. Messages are the property of the author. Any duplication outside

the group requires prior permission from the author.Please consider the

environment and only print this message if absolutely necessary.