Health Information Compliance Alert

Don't let amendment requests catch you off guard

Don't wait until it's too late to plan out a policy for streamlining your amendment request process, advises Gina Cavalier, an attorney with Sonnenschein, Nath & Rosenthal in Washington, DC. Tip: Map out how protected health information flows through your office and write a policy "that mirrors the way your PHI moves," she offers.

Because patients' amendment rights are three-fold, Cavalier suggests you develop your policy around these three main components:

1.  How the patient will submit the request. A simple, standardized form will work for each patient in your practice (see Don't Get Stuck In An Amendment Request Rut). Be sure to include a field for patients to write out what they think the mistake is. This way you can filter out problems that can be resolved in other ways.

2.  How you will evaluate the request. This step happens internally. You should start the evaluation by checking the amendment request against the standards for denial set out in the reg.

3.  How you will implement your decision. Create a form letter that outlines how you came to your decision and what steps the patient should take next (see How To Respond To Amendment Requests).