Last year’s passing of the new HIPAA requirements signaled the government’s concern that individually identifiable health information needs stronger protection beyond the borders of the healthcare industry. HIPAA already recognized this need by imposing obligations on covered entities and their business associates in prior versions of the rule. In the latest rule update, however, the US Department of Health and Human Services, among other things, expanded the definition and responsibilities of business associates and now made them directly liable for HIPAA noncompliance.
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New Jersey governor Chris Christie recently signed into law changes to existing legislation that would allow qualified pharmacists to administer influenza vaccines to children seven years of age or older. In August, the New York State Inspector General (OMIG) denied enrollment to a pharmacy after an on-site inspection revealed several deficiencies. An apparent egregious case of non-compliance serves as a vivid reminder of why providers must comply with their professional requirements as well as why they must observe NYS Medicaid rules and regulations at all times. The NYS Medicaid recently informed referring and servicing providers that, effective for services provided on and after October 1, 2013, claims will be denied if they include the NPI of non-enrolled ordering, prescribing, referring or attending provider (OPRA). Below we discuss some of the changes. Providers beware – even an unintentional omission on a New Jersey Medicaid enrollment application can lead to denial of enrollment. Such was the holding of a recent New Jersey Court of Appeals decision. Many of our clients have been unable to contact representatives of the Health Commerce System (HCS) to establish or resolve problems with their Prescription Monitoring Program Registry (Registry) log-in for compliance with the new I-STOP law. Recently, the Department of Health (DOH) commented on the delay. New York’s Internet System for Tracking Over Prescribing (I-STOP) legislation that, among other things, mandates prescribing practitioners to consult with the prescription monitoring registry prior to prescribing a controlled substance, will go into effect on August 27, 2013. Below we discuss some of the I-STOP implications for pharmacists. Certified pharmacists are required to comply with specific reporting requirements. In our third and last article of this series, we discuss some of those requirements below. Pharmacists certified to administer vaccines must comply with specific standards and procedures issued by the Department of Health. In part two of our series analyzing the requirements imposed on pharmacists for vaccine administration, we discuss some of those standards and procedures. Since 2008 certified pharmacists in New York have been authorized to administer vaccines. Today we begin a three part series of articles that examines pharmacists certification requirements for immunization administration, the standards and procedures required for such administration, as well as the State reporting requirements. Provider Alert: New York has a series of drug prescription laws that impact medical and pharmaceutical providers. We highlight those provisions below in chronological order. Pharmacies registered with the New York Education Department Office of the State Board of Pharmacy (Board) have a duty to report certain changes in their business operations. We briefly discuss these requirements below. |
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