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Question For The HIPPAA Experts


retmar
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I need the Pros to put their "Thinking Caps" on for this one.

Let's say a Medical Provider refuses to deal with a consumer and states in writing that the consumer can only communicate with the CA in regards to the debt. This includes ALL monies due and to obtain validation of debt. In short, they will not discuss, in any fashion, any part of the debt. To include, the Insurance Carrier stipulates in their Rules and Regulations that all Medical Providers who agree to accept Assignment from beneficiaries of this carrier, are FORBIDDEN to turn any beneficiary's claim over to collection for any reason.

To me, this constitutes a violation as they are forcing the consumer to forfeit their rights under HIPPAA to satisfy the obligation. Do not look at this by considering the use of the HIPPAA letter we have discussed on this site. Look at it in itself.

Are we in agreement? If not, what are your thoughts?

Also, where does one file a HIPPAA complaint?

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Every medical provider has to have a HIPAA Compliance officer and Privacy officials. If you have a HIPAA complaint, file it with the provider's Compliance officer - and with the feds who oversee HIPAA:

http://www.cms.hhs.gov/hipaa/hipaa1/content/cons.asp

When it comes to collections, any CA that a provider does business with MUST have a valid Business Associates Agreement (BAA) in order to be in compliance. So, demand proof of the CA's BAA with the medical provider. HIPAA violations come with some VERY stiff fines - 100k is the MINIMUM penalty and they only go up from there. No hospital or Dr's office is going to take the chance of getting slammed for violations with that kind of pricetag attached.

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That's my thought and is the reason why I posed the question.

I cannot see this involved consumer filing a complaint if what the OC is saying in their letter is legal. Myself, it is illegal as it is telling the consumer they can only resolve the matter by contacting the CA. My reasoning is:

It has been stated in many previous posts that if a consumer DV's a CA on a Medical account, they forfeit their rights under HIPAA. Therefore, if the consumer's only avenue of resolving the debt is to deal ONLY with the CA, then the OC is forcing them to forfeit their rights.

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