©2002 by the National Committee for Quality Assurance NCQA: HIPAA Business Associate Presentation...
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Transcript of ©2002 by the National Committee for Quality Assurance NCQA: HIPAA Business Associate Presentation...
![Page 1: ©2002 by the National Committee for Quality Assurance NCQA: HIPAA Business Associate Presentation to the 6th National HIPAA Summit March 28, 2003 Patricia.](https://reader035.fdocuments.net/reader035/viewer/2022070605/5a4d1af47f8b9ab059980644/html5/thumbnails/1.jpg)
©2002 by the National Committee for Quality Assurance
NCQA: HIPAA Business
Associate
Presentation to the 6thNational HIPAA Summit
March 28, 2003
Patricia Pergal, JDDirector, Program Compliance
National Committee for Quality Assurance
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Framework for Discussion• Brief introduction to NCQA• Impact of HIPAA on NCQA
– NCQA: Program Standards – NCQA: Business Associate
& Researcher – NCQA: HIPAA Readiness
Activities• Privacy Certification for
Business Associates
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• Private, non-profit health care quality oversight organization
• Measures and reports on health care quality
• Unites diverse groups around common goal: improving health care quality
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NCQA’s Mission and Vision
Mission: To improve the quality of health care delivered to people everywhere
Vision: To become the most widely trusted source of information driving health care quality improvement
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Achieving the Mission• Half the nation’s 500 HMOs participate
in an NCQA program
• More than 90 percent of health plans report HEDIS
• 67 percent of Fortune 500 companies request or require accreditation
• 25 States and the Federal government rely on NCQA Accreditation and HEDIS
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NCQA: Quality Assessment Systems
• Two main methodologies used in NCQA’s quality assessment activities:– Accreditation, Certification & Recognition
Programs – Data Collection and Analysis
• NCQA Customers:
Health Plans
Health Care Providers
Health Care Clearinghouses
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Impact of HIPAA on NCQA: Program Standards
Alignment of Accreditation Standards with HIPAA, including:
• Removed requirements for organizations to obtain routine consent
• Members must have rights to Access, Amend and Receive an Accounting of Disclosures
• Incorporated protections concerning disclosure of PHI to employers
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Impact of HIPAA on NCQA: Business Associate
• Accreditation organizations are business associates under HIPAA (HHS HIPAA Q&As - Answer ID 238)
• Quality improvement activities fall under the definition of Health Care Operations (45 CFR 164.501) - patient authorization not required
• Business Associate contract required
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Impact of HIPAA on NCQA: Researcher
• NCQA quality measures development and data analysis activities considered “Research” under HIPAA (45 CFR 164.501)
• Requires use of Limited Data Set • Data Use Agreement required
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NCQA HIPAA Readiness: Business Associate Contract
Business Associate Contract Addendum Addresses:
• Business Associate Contract Provisions Required by the Privacy Regulation
• Data aggregation • Permission to create a Limited Data Set• Permission to de-identify PHI• Data Use Agreement incorporated
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NCQA HIPAA Readiness: Internal Operations
• Development and implementation of a Privacy and Security Policy and Procedure Manual
• Capability to track and execute requests for Access, Amendments and Accounting of Disclosures
• Organization-wide staff training
• Focused training for surveyors
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Privacy Certification for Business Associates
• Need created by HIPAA privacy regulations
• Demonstrates good faith effort to provide “appropriate safeguards” to prevent impermissible uses and disclosures
• Limited on-site review• Pass/fail; report “passes” only• Final standards released in mid-May;
program to launch shortly thereafter