HHS Data Council

Appendix G: American Psychiatric Association

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Appendix G: American Psychiatric Association Minimum Necessary Guidelines for Third Party Payers for Psychiatric Treatment

The following American Psychiatric Association position statement has been developed in response to the HHS final Privacy Rule's provision that health-care "providers" (health-care professionals and facilities) disclose only the "minimum necessary" information for a given purpose.

Appendix F: Personal Health Information Requested

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Appendix F: Personal Health Information Requested by Local and National MCOS

Patient Health Information Commonly Requested in Outpatient Treatment Request Forms, By Type of Response Local Managed Care Firms Only - Total Examined – 6 Requested Information (1) Categorical Narrative Both Demographic/Administrative Information Patient’s Name 6

Appendix E: Personal Health Information Requested

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Appendix E: Personal Health Information Requested by MCOs and MBHOs

Appendix D Summary of All Patient Health

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Appendix D Summary of All Patient Health Information Requested in Outpatient Treatment Request Forms

Summary of All Patient Health Information Requested in Outpatient Treatment Request Forms

APPENDIX C: MAGELLAN TREATMENT REQUEST FORM

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Appendix C: Magellan Treatment Request Form

APPENDIX B: MARYLAND UNIFORM TREATMENT PLAN FORM

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Appendix B: Maryland Uniform Treatment Plan Form

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. References

Acuff, Catherine, Patricia Bricklin, Samuel Knapp, Bruce Bennett, Mathilda Canter, Stanley Moldawsky, Randy Phelps. "Considerations for Ethical Practice in Managed Care" Professional Psychology: Research and Practice , vol. 30, no. 6, pp. 563-575, 1999. American Health Line. "Privacy: Kids' Mental Health Records Posted Online" National Journal

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Conclusion

This literature review demonstrates that the need of patients for confidentiality of their personal health information conflicts with the need of managed care firms to ensure that the services they are paying for are appropriate.

C. Models for Alternative Review Systems

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. C. Models for Alternative Review Systems

In contrast to the previous models, which proposed ways MCOs might protect patient information after they collect it, several providers have put forward models for reforming the payment review system that would minimize the physician's obligation to disclose treatment information in order to receive payment.

B. Models for Handling of Personal Health

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. B. Models for Handling of Personal Health Information by the MCO

In addition to concerns about the amount of sensitive information being shared with the MCO, many consumer advocates have expressed concern about the security of the information once it is in the possession of the managed care firm. Numerous advocacy groups have developed guidelines and recommendations to ensure that such personal information is r

A. Models for Disclosure of Personal Health

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. A. Models for Disclosure of Personal Health Information

Several managed care entities have developed models for determining what types of mental health information should be included in the medical record.

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Suggested Proposals/Models

In an attempt to resolve the conflicts between the information needs of MCOs and the privacy needs of mental health and substance abuse patients, numerous stakeholders have developed recommendations defining which types of patient information should be shared with the MCO and guidelines for how MCO should handle the information once they receive i

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. D. Interference with Treatment

Concern over health care privacy can have adverse effects on the treatment process. It can create conflict-of-interest concerns for providers, who want to advocate for their patients, but know that if the patient does not authorize disclosure, the treatment may not be approved by the MCO, and the provider may not be paid. In one example, two psych

C. Risks of Disclosure of Personal Health

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. C. Risks of Disclosure of Personal Health Information

Personal health information, in the wrong hands, could have disastrous consequences for an individual's future. As Jay Pomerantz points out, the wealth of information contained in the computer files of the major MBHO's could have significant value to private detectives, opposing parties in lawsuits, political opponents, and blackmailers, just to n

B. Number of People With Access to Records

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. B. Number of People With Access to Records

In a large managed care firm, more than one hundred people may have access to an individual's medical record. In the early 1980s, when most people were still enrolled in fee-for-service, one study found that up to 100 people had access to an individual's inpatient medical record (Siegler 1982). As payment and delivery systems have grown more compl

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. A. Lack of Consumer Awareness

Despite the federal and state laws designed to protect patient confidentiality, there are numerous problems associated with the ways patient information is disclosed to managed care firms today. The first is that consumers are often unaware of the significance of the consent forms that they sign upon enrollment (Davidson and Davidson, 1995). Becau

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. Other privacy issues

Many concerns were reviewed in the literature regarding privacy and confidentiality of mental health and substance abuse records. While these issues were beyond the scope of the study, we discuss them briefly below. The HIPAA privacy regulations may help to address some of these issues.

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. D. Utilization Review Process

The most common purpose for MCOs to collect personal information on clients is for utilization review. This is a process where the MCO determines the client's need, the medical necessity of the request, and the appropriate level of care. Utilization review processes vary from company to company, but generally consist of a request from the client f

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. C. Rise in Managed Care

In the 1980s, health care costs in general began to rise, and mental health and substance abuse costs rose even faster. From 1986 to 1988, spending on all health care rose 13%, but mental health care costs rose 20% and substance abuse care costs rose 32% (Hennessy and Green-Hennessy, 1997).

Privacy Issues in Mental Health and Substance Abuse Treatment: Information Sharing Between Providers and Managed Care Organizations: Final Report. B. History of Information Exchange

The practice of third-party insurers demanding information on mental health treatment before paying for services is not a recent phenomenon. Even under fee-for-service arrangements, insurers generally required mental health providers to share the patient's diagnosis, and sometimes even the treatment plan, before reimbursing for these services (Acu

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