As part of the process of rule making for the new HIPAA provisions under the HITECH Act of 2009, the Department of Health and Human Services (HHS) Office of Civil Rights published a draft and explanation of proposed rules in July 2010, soliciting public comment on these rules. In response, AHDI and MTIA filed formal comments, expressing support for some aspects of the rules and requesting clarification on others. These and all public comments can be found at www.regulations.gov (search HIPAA). AHIMA also submitted a formal response addressing the rule, which can be read here.
After noting their long-term commitment to the safety and reliability of healthcare documents, AHDI and MTIA commented specifically regarding the definition of "subcontractors," offering "our strong support for bringing clarity to the definition of ’subcontractor’…" and requesting "additional guidance with respect to the defined term subcontractor, as well as the scope of review a business associate must undertake in order to ensure that a subcontractor… continues to comply with HIPAA and the HITECH Act." The associations requested the Secretary of HHS offer a few more examples of the subcontractor relationship within the healthcare industry in order to further clarify the nature of those relationships. Finally, the associations pointed out that for our members, some issues of concern relate to "holding accountable offshore subcontractors and home-based independent contractors working for multiple business associates." Read the full statement at the AHDI and MTIA websites.
Thank you to the following content experts for their contributions:
Holly Woemmel, Outsourcing Solutions, Inc.
Susan Lucci, Webmedx
Kristin Hagen, TRSi
Helle Richards, MedQuist, Inc.
Russ Adkins, Spheris
Debbie Bright-Chunn, Bright Consulting
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