Author: U.S. Centers for Medicare & Medicaid Services

Source: Government (U.S.)

Publication Date: January 03, 2007

Author: U.S. Centers for Medicare & Medicaid Services

Source: Government (U.S.)

Publication Date: August 16, 2004

Please be advised that these FAQs were generated from a database that is updated frequently. For the most up-to-date information, please visit http://questions.cms.hhs.gov.

Date: 9/30/2004

Question #1889: Are covered entities protected when they make disclosures t....

Author: Brown, Stephen C.

Source: Journal of AHIMA

Publication Date: May 2005

By now, every healthcare organization has faced the initial security compliance responsibilities associated with HIPAA. However, the compliance road has not yet been fully traveled. The nature of the rule makes compliance a recursive effort of reassessment, continual auditing, regular educatio....

Author: Ballam, Holly

Source: Journal of AHIMA

Publication Date: March 1999

A recent notice of proposed rule making for an electronic signature standard, if adopted, will affect the way health information is managed for years to come. Here's what you need to know about electronic signature and what the proposed standard may mean for HIM.
The Health....

Author: Smith, Cheryl M.

Source: In Confidence (newsletter) | AHIMA Q and A

Publication Date: November 02, 2001

Question: What does the HIPAA privacy rule mean when it refers to a state law that is “contrary” or “more stringent”?
Answer: The HIPAA privacy rule defines a state law as being contrary to the privacy rule when, in comparing a state law to a standard, requirement, or implementation spe....

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: AHIMA

Source: AHIMA practice brief

Publication Date: November 2010

This practice brief has been retired. It is made available for historical purposes only.

Author: Hjort, Beth M.

Source: AHIMA practice brief

Publication Date: November 2003

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: Hjort, Beth M.

Source: AHIMA practice brief | Journal of AHIMA

Publication Date: April 2002

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: Grant, Karen G.; Adair, Deborah A.

Source: AHIMA Convention

Publication Date: September 23, 2002

Author: Hagland, Mark

Source: In Confidence (newsletter)

Publication Date: May 02, 2003

Most of the chief privacy officers now being appointed to help their hospital-based organizations cope with and comply with HIPAA regulations are working in relative isolation, either toiling on their own to devise solutions to HIPAA’s challenges or laboring with a team to work out answers to....

Author: Humphrey, Heather L.

Source: Journal of AHIMA

Publication Date: February 2005

A few years ago, the Y2K crisis refocused the data world. Suddenly medical device manufacturers saw the inherent risks data brought to the business industry. What began with answering a simple question about date functionality quickly moved to conversations about personal information, its appr....

Author: Reeder, Linda

Source: AHIMA Convention

Publication Date: September 23, 2002

Author: U.S. Centers for Medicare & Medicaid Services

Source: Government (U.S.)

Publication Date: March 27, 2002

Author: Wagg, Dorothy Grandolfi

Source: In Confidence (newsletter)

Publication Date: June 02, 2001

Since Congress passed the Health Insurance Portability and Accountability Act of 1996 (HIPAA), health information management (HIM) professionals have watched and waited for the final rules implementing the statute’s provisions relative to privacy of health information.
The industry has en....

Author: Guilfoy, Helene; Koss, Shannah; Fisher, Micheal

Source: HIPAA Conference 2000

Publication Date: March 14, 2000

2000 HIPAA Conference Presentation
HIPAA Compliance: State of the Art
Presented by Helene Guilfoy, HIPAA Consultant, Insource Management Group
Shannah Koss, HIPAA National Practice Director, IBM Corp.
Micheal Fisher, Director HIPAA Solutions Group, DAOU Systems, Inc. Agenda
....

Author: Roach, Michael C.

Source: Journal of AHIMA

Publication Date: February 2001

If your organization is covered by HIPAA, do you know what’s expected of you-and of your vendors-with regard to privacy of health information? To make sure your organization is in compliance, contracts with business partners will need careful review. The author offers an overview of....

Author: Watkins, Larry

Source: HIPAA Conference 2000

Publication Date: March 14, 2000

2000 HIPAA Conference Presentation
HIPAA Compliance: Is Outsourcing the Answer?
Larry Watkins, Director, Electronic Commerce -- Per-Se Technologies EDI in Health Care-HIPAA Legislation
Mandated Standards 9 Electronic Transaction Standards Standardization of Supporting Codes Standard....

Author: McLaughlin, Mark

Source: HIPAA Conference 2000

Publication Date: March 14, 2000

2000 HIPAA Conference Presentation
HIPAA Compliance: Is Outsourcing the Answer?
Mark McLaughlin, Informatics Standards Liaison, McKessonHBOC Compliance Depends on You!: HIPAA Components for Outsourcing
Transactions Processing Auditing Security Disaster Recovery
Consultants and....

Author: Having, Karen; Davis, Diane C.

Source: Perspectives in Health Information Management

Publication Date: November 2005

Abstract


In January 2004, a random sampling of 1,000 U.S. hospitals was surveyed by researchers at a midwestern university to determine perceived level of compliance with the security requirements of the federal Health Insurance Portability and Accountability Act (HIPAA). Exa....

Author: Greene, Adam H

Source: Journal of AHIMA

Publication Date: April 2012

The HIPAA privacy and security rules need not act as an obstacle to efficient communications, but keeping texting compliant requires planning and diligence.

Text (or SMS) messaging has become nearly ubiquitous on mobile devices. According to one survey, approximately 72 perce....

Author: Wisconsin Health Information Management Association

Source: AHIMA Foundation

Publication Date: February 28, 2003

In June 2001, a survey was distributed to healthcare providers by members of the Wisconsin Health and Hospital Association (WHA), Health Financial Managers Association (HFMA), and Rural Wisconsin Health Cooperative. The purpose of the survey was to gather information regarding HIPAA implementa....

Author: Abraham, Prinny

Source: Journal of AHIMA

Publication Date: February 2002

HIPAA privacy regulations will dramatically change how home health and hospice agencies deal with patient health information. Here are some facets HIM professionals working in this area need to understand.


Home health and hospice providers—regardless of license, certifica....

Author: McDavid, Jan P

Source: Journal of AHIMA

Publication Date: May 2013

Business associates (BAs) of HIPAA-covered entities like hospitals and doctor's offices should already be intimately acquainted with HIPAA's privacy and security regulations. BAs should already have business associate agreements with every covered entity with whom they work and assume resp....

Author: Cacciatore, Victoria; Downing, Katherine

Source: Journal of AHIMA

Publication Date: July 2014

Criminal attacks on healthcare systems have risen 100 percent since 2010, according to a recent Ponemon study.1 This makes it obvious that the privacy and security of patient health information is vulnerable and highly susceptible to data breach. The HIPAA Breach Notification Rule became e....

Author: Hofler, Linda D.; Hardee, Joy; Dildy, Kenneth; Burleson, Deeanna; Grady, Jamie

Source: Journal of AHIMA

Publication Date: March 2005

The privacy and security rules require audits and system activity reviews. Here is one health system's process, a systematic approach that focuses on areas of greatest risk.
Ensuring the privacy and confidentiality of patient information is fundamental to HIM, but it has taken on a new le....

Author: Fodor, Joseph

Source: Journal of AHIMA

Publication Date: January 2004

As electronic health records (EHRs) become more commonplace in healthcare, changes, adjustments, and improvements will be inevitable. When designing, implementing, upgrading, or remediating an EHR system, your organization’s implementation team should consider the impact of complying wit....

Author: Mikels, Debbie

Source: AHIMA Convention

Publication Date: October 15, 2004

Abstract

This article reviews successful strategies in preparing for HIPAA Privacy compliance. There are ongoing challenges organizations will face after the compliance date, such as managing research issues, identifying all business associates, and managing the accounting of disclosures....

Author: AHIMA

Source: Journal of AHIMA

Publication Date: June 2009

For those wondering what progress the Office for Civil Rights makes as it works through HIPAA privacy rule complaints, the numbers are easy to find. Each month OCR reports top-line results of the HIPAA cases it has received and resolved.

OCR has logged approximately 43,700 complaints....

Author: AHIMA

Source: Journal of AHIMA

Publication Date: April 2013

Healthcare claims auditors have inundated release of information staff and vendors this year with record requests, in part due to the aggressive Centers for Medicare and Medicaid Services’ (CMS) Recovery Audit Contractor (RAC) initiative. RACs review provider bills and medical records to....

Author: Hrehor, Kimberly; Osterberg, Carol; Shearry, Joyce

Source: AHIMA Convention

Publication Date: September 23, 2002

Author: Rhodes, Harry B.

Source: In Confidence (newsletter)

Publication Date: January 02, 2001

Cost: how much money needs to be invested? By now, most of us have discussed the implementation of the Health Insurance Portability and Accountability Act (HIPAA) final rules with our administrators, and naturally the question has been raised, “Just how much is this going to cost me?”Most lik....

Author: Greene, Adam H

Source: Journal of AHIMA

Publication Date: October 2011

Now Is the Time to Review Security Policies and Procedures

In June 2011 the Department of Health and Human Services awarded KPMG a $9.2-million contract to create an audit protocol and audit organizational compliance with the HIPAA privacy and security requirements.1 The co....

Author: Frawley, Kathleen A.; Asmonga, Donald D.

Source: Journal of AHIMA

Publication Date: January 1998

On October 29, 1997, the Department of Health and Human Services (HHS) published its semi-annual regulatory agenda. There are several notices of interest to health information management professionals.

Under the proposed rule stage, the Health Care Financing Administration ....

Author: U.S. Department of Health and Human Services

Source: Federal Register

Publication Date: April 17, 2003

Author:

Source: External web site

Publication Date: 2014

The HIPAA COW website provides resources for covered entities, business associates, and trading partners under HIPAA, as well as any other organization impacted by HIPAA regulations.

Author: U.S. Government Accountability Office

Source: Government (U.S.)

Publication Date: September 03, 2004

Author: Gregg, Cheryl A.

Source: Brief Encounter

Publication Date: January 02, 2001

In 2000, the Health Care Financing Administration (HCFA) announced the new Provider Education Project, a multiyear educational component of the Medicare Integrity Program. HCFA will work in partnership with practitioners, providers, and billing professionals to ensure they have the resources t....

Author: Gradle, Brian D.

Source: In Confidence (newsletter)

Publication Date: August 02, 2003

If you were to ask health information managers for a one-word response to HIPAA, the majority of the replies would likely be “privacy.”However, simply because the compliance date for the final security rule (which was published by the government in February and applies to electronic informati....

Author: AHIMA; American Medical Informatics Association (AMIA)

Source: AHIMA practice brief

Publication Date: June 2010

Editor’s note: This update replaces content presented in the November 2003 practice brief “Handling Complaints and Mitigation.”


Many HIM professionals are experienced at managing various types of complaints that arise in day-to-day health information operations.....

Author: Burrington-Brown, Jill

Source: AHIMA practice brief | Journal of AHIMA

Publication Date: November 2003

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: AHIMA e-HIM Work Group: Guidelines for EHR Documentation Practice

Source: AHIMA web extra

Publication Date: January 02, 2007

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: AHIMA e-HIM Work Group: Guidelines for EHR Documentation Practice

Source: AHIMA practice brief | Journal of AHIMA

Publication Date: January 2007

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: Thomason, Mary

Source: AHIMA sample form

Publication Date: November 21, 2002

Author: Siren, Bill

Source: Brief Encounter

Publication Date: July 02, 2001

Most of us are acutely aware of the events that took place on December 31, 1999, at midnight. There were some who thought that in five seconds, the lights would go off and all computer systems would cease to function. In the healthcare world, concerns were prevalent regarding whether medical e....

Author: AHIMA

Source: AHIMA practice brief

Publication Date: November 2013

This 2013 practice brief version has been retired and is retained here for historical purposes. Read the 2016 updated version of this Practice Brief here.



The Privacy Rule portion of the Health Insurance Portability and Accountability Act (HIPAA) of 1996 defines a "business....

Author: AHIMA Work Group

Source: AHIMA practice brief

Publication Date: October 2016

This update supersedes the November 2013 practice brief, Guidelines for a Compliant Business Associate Agreement.



The Privacy Rule portion of the Health Insurance Portability and Accountability Act (HIPAA) defines a "business associate (BA) as a person or entity that performs....

Author: U.S. Office for Civil Rights

Source: Government (U.S.) | U.S. Department of Health & Human Services

Publication Date: September 04, 2012

Author: U.S. Office for Civil Rights

Source: Government (U.S.) | U.S. Department of Health & Human Services

Publication Date: July 15, 2010

Author: U.S. Centers for Medicare & Medicaid Services

Source: Government (U.S.)

Publication Date: July 24, 2003

Author: U.S. Office for Civil Rights

Source: Government (U.S.)

Publication Date: December 02, 2002

Author: Walker, Trevor Hight

Source: In Confidence (newsletter)

Publication Date: July 02, 2000

HIPAA: even the acronym sounds threatening. Ask your neighbors what they think it means.When I asked mine the most common response was “a multibillion dollar military operation.” They really weren’t that far off.
Seriously, just when CIOs thought it was safe to pack up their IT fatigues....

Author: AHIMA

Source: AHIMA toolkit

Publication Date: December 02, 2011

This toolkit is designed to provide guidance to HIM professionals on how to prepare for and ensure compliance in managing governmental audits.

Author: Roth, Julie A.

Source: Journal of AHIMA

Publication Date: March 2004

The HIPAA privacy rule is just one of several federal laws that protect the privacy of non-public information. But privacy is not a new concept in healthcare. Healthcare workers have long protected medical information under a varety of state and federal laws, accreditation standards, and rules....

Author: Amatayakul, Margret

Source: HIPAA Conference 2000

Publication Date: March 14, 2000

2000 HIPAA Conference Presentation
Fundamentals for the Newly Initiated
Margret Amatayakul, Margret\A Consulting, LLC Session Objectives
Get an overview of the original legislation, processes, and timelines Examine the scope and impact of the new regulations Review ongoing HIPAA impl....

Author: Kloss, Linda L

Source: Journal of AHIMA

Publication Date: March 2006

The financial losses from healthcare fraud in the US are staggering...and growing. Fraud was estimated to be between 3 and 10 percent of total health expenditures in 2003, or $51 to $170 billion, according to the National Health Care Anti-Fraud Association. Whether an interconnected health IT....

Author: U.S. Congress

Source: Government (U.S.)

Publication Date: May 20, 2009

Author: Hanson, Susan P.; Cassidy, Bonnie S.

Source: Journal of AHIMA

Publication Date: March 2006

With the right planning, health IT and nationwide health data exchange can deter healthcare fraud.
Fraud is a significant drain on the US healthcare system. The National Health Care Anti-Fraud Association estimates that 3 percent of the nation's annual healthcare outlay--$51 billion--was....

Author: Prophet, Sue

Source: Journal of AHIMA

Publication Date: January 1998

During AHIMA's National Convention, HIM professionals convened to network and share practical ideas on issues pertaining to fraud and abuse. While most of the participants worked in hospitals, other work settings, including colleges, consulting firms, and government agencies were als....

Author: Prophet, Sue

Source: Journal of AHIMA

Publication Date: April 1997

Healthcare Fraud and Abuse Legislation

On August 21, 1996, President Clinton signed into law the Health Insurance Portability and Accountability Act. This law addresses several issues including the creation of a Health Care Fraud and Abuse Control Program. This program is intended to com....

Author: Morris, Lewis

Source: Government (U.S.)

Publication Date: April 22, 2009

Author: Sonnenschein Nath & Rosenthal LLP

Source: External web site

Publication Date: October 07, 2008

Author: Wilson, Donna D

Source: Journal of AHIMA - Coding Notes

Publication Date: May 2009

The Centers for Medicare and Medicaid Services (CMS) expects to have four Recovery Audit Contractors (RACs) operating by 2010. Each RAC will be responsible for identifying overpayments and underpayments in a region of the country. Based on the results of the demonstration program, the permanen....

Author: Jeffries, Jane

Source: Journal of AHIMA

Publication Date: February 2002

Though the Office for Civil Rights (OCR) has played an active role in the Department of Health and Human Services (HHS) since the early 1980s, it has only recently moved to the forefront of HIM professionals’ minds. Charged with enforcing the HIPAA privacy rule, OCR has become the leading....

Author: Amatayakul, Margret

Source: Journal of AHIMA

Publication Date: October 2002

Every healthcare provider has experienced managing patient complaints, whether they are about cold food, unresponsive staff, or missed medication. However, when it comes to privacy and confidentiality, complaints need to be handled a bit differently. In this article, we'll explore how to handl....

Author: AHIMA

Source: AHIMA Advantage

Publication Date: June 2008

Author: Amatayakul, Margret

Source: Journal of AHIMA

Publication Date: January 2004

Many of us struggled to understand the HIPAA privacy rule and initially had few resources to turn to for help. As your organization begins planning for security rule compliance, however, many of you may be finding that you’re overwhelmed with the volume of potential resources available.....

Author: Rode, Dan

Source: Journal of AHIMA

Publication Date: February 2001

Amid much fanfare that included a ceremony with AHIMA representatives as invited guests, the Department of Health and Human Services (HHS) released the HIPAA standards for privacy of individually identifiable health information on December 20, 2000. The rule was published in the Feder....

Author: U.S. Federal Trade Commission

Source: Government (U.S.)

Publication Date: April 07, 2009

Author: Garvin, Jennifer Hornung; Watzlaf, Valerie J.M.; Moeini, Sohrab

Source: Journal of AHIMA

Publication Date: March 2006

Automation helps streamline the coding process. When combined with sophisticated analytic software, it can reduce fraud, too.

Automating coding software is generating interest for many reasons--an important one is its ability to speed the turnaround time between patient enco....

Author: Heubusch, Kevin

Source: Journal of AHIMA

Publication Date: November 2011

Perhaps one of the biggest jobs related to implementing the ARRA provisions right now is keeping track of the moving parts. Publication of the act in 2009 was a kind of Big Bang-an explosion of provisions that rocked the healthcare universe. Since then, however, the pieces have traveled at dif....

Author: Blevins, Alicia; Davis, Nancy; Hjort, Beth M.; Lemery, Chrisann; Mangin, Wendy L; Mikels, Debra A; Nicholas, Cindy

Source: AHIMA practice brief | Journal of AHIMA

Publication Date: August 2006

This practice brief has been retired. It is made available for historical purposes only.

Author: Hughes, Gwen

Source: AHIMA practice brief | Journal of AHIMA

Publication Date: June 2001

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: Brandt, Mary D.

Source: AHIMA practice brief

Publication Date: July 1996

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: Mancilla, Desla; Moczygemba, Jackie

Source: Perspectives in Health Information Management

Publication Date: September 2009

Author: Ruano, Michael

Source: In Confidence (newsletter)

Publication Date: March 02, 2003

Part one in a 10-part series.


This article is the first of a 10-part series that introduces the domains of information security and relates them to federal HIPAA regulations. This first domain of security management practices is the most general and introduces some topics t....

Author: Putt, Stephanie H.

Source: In Confidence (newsletter)

Publication Date: November 02, 2001

Being the privacy officer for one of the world’s largest healthcare delivery systems is often a daunting responsibility, yet it offers an opportunity to make a difference and face new challenges. The Veterans Health Administration, or VHA, is part of the Department of Veterans Affairs (VA). T....

Author: Redd, Andrew; Pickard, Steve; Meystre, Stephane; Scehnet, Jeffrey; Bolton, Dan; Heavirland, Julia; Weaver, Allison Lynn ; Hope, Carol; Garvin, Jennifer Hornung

Source: Perspectives in Health Information Management

Publication Date: January 2015

Abstract


Objectives: We introduce and evaluate a new, easily accessible tool using a common statistical analysis and business analytics software suite, SAS, which can be programmed to remove specific protected health information (PHI) from a text document. Removal of PHI is import....

Author: Datskovsky, Galina; Hedges, Ron; Empel, Sofia; Washington, Lydia

Source: Journal of AHIMA

Publication Date: June 2015

Editor’s Note: This is the third in a series of four articles that discuss the eight Information Governance Principles for Healthcare.


AHIMA’s new Information Governance Principles for Healthcare (IGPHC) provide a framework for healthcare organizations to leverage informati....

Author: Mandell, Steve; Manny, Barbara

Source: AHIMA Convention

Publication Date: September 23, 2002

Author: Gallagher, Lisa; Yale, Ken

Source: In Confidence (newsletter)

Publication Date: August 02, 2003

The HIPAA privacy rule requires that a covered entity (CE) institute appropriate administrative, technical, and physical measures to reasonably safeguard the privacy of protected health information (PHI). In order to keep information “private,” it must be kept safe or secure. Therefore, logic....

Author: Brennan, Marjorie

Source: Brief Encounter

Publication Date: July 02, 1999

The May 10 suspension of all federally funded clinical research at the Duke University Medical Center was recently reported by The Washington Post, the New York Times, and Health News. The suspension was carried out by the National Institute of Health's (NIH's) Office for Protection from Rese....

Author: Cassidy, Bonnie S.

Source: Journal of AHIMA

Publication Date: June 2000

When the Health Insurance Portability and Accountability Act (HIPAA) became effective in 1996, many hospitals and physicians mistakenly assumed that its provisions did not apply to them. Similarly, many e-health vendors have yet to wake up to the fact that HIPAA applies to them as well.
....

Author: U.S. Centers for Medicare & Medicaid Services

Source: Government (U.S.) | External web site

Publication Date: November 01, 2007

In 1986, Congress enacted the Emergency Medical Treatment & Labor Act (EMTALA) to ensure public access to emergency services regardless of ability to pay. Section 1867 of the Social Security Act imposes specific obligations on Medicare-participating hospitals that offer emergency services to provide a medical screening examination (MSE) when a request is made for examination or treatment for an emergency medical condition (EMC), including active labor, regardless of an individual's ability to pay. Hospitals are then required to provide stabilizing treatment for patients with EMCs. If a hospital is unable to stabilize a patient within its capability, or if the patient requests, an appropriate transfer should be implemented.

Author: Cox, William G.

Source: Journal of AHIMA - Coding Notes

Publication Date: June 2004

Effective January 1, 1988, a provision of the Balanced Budget Act of 1977 (Section 4511) removed restrictions on settings where nurse practitioners, physician assistants, and clinical nurse specialists provide services. The definition of a clinical nurse specialist was also modified to requir....

Author: AHIMA e-HIM Work Group: Best Practices for Electronic Signature and Attestation

Source: AHIMA practice brief | Journal of AHIMA

Publication Date: November 2009

This practice brief has been updated. See the latest version here. This version is made available for historical purposes only.

Author: U.S. Department of Health and Human Services. Office of the Inspector General

Source: Government (U.S.)

Publication Date: April 07, 2004

Author: Amatayakul, Margret

Source: Journal of AHIMA

Publication Date: September 2003

Direct caregivers have long been concerned about balancing patient protections with “customer” relations: Who do you talk to and how much do you tell? This was an issue long before HIPAA, and has only become more complex with HIPAA. And while HIPAA provides guidance, there are still....

Author: Zender, Anne

Source: Journal of AHIMA

Publication Date: February 2000

While most HIM professionals are acquainted with participating in a facility's Joint Commission accreditation processes, a small but significant number work in facilities that are also accredited by the American Osteopathic Association (AOA). Though the organizations have....