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Privacy
Notice
Notice of Privacy Practices, or NPP, is a formal document
that explains how, when, and why a patient’s health
information may be disclosed. It answers questions regarding
protected health information, or PHI, and acts as your
practice’s guide to handling PHI.
 Privacy
Notice Elements
Prepare
a standing written privacy notice that is tailored to your
practice and on your practice stationery. Have all
your patients, both new and existing, review and sign. The
Notice should be:
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In plain
language
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Provided in patient's own native language
(ie.,
Spanish, Chinese)
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Educate
patients on their rights as patients
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Specify
who in the practice is the privacy contact
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On practice or facility
stationery
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Distributed
to and acknowledged by both new and existing patients
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Should state that you have the right to amend or
revise the policy
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You must inform the patient of right to:
Receive a copy of notice.
Authorize disclosure of health information.
Restrict certain uses and disclosures of PHI.
Receive confidential communications.
Inspect, copy and amend PHI.
What the accounting procedure is for PHI disclosures (for other than
treatment, payment, and health care operations.)
How to complain about alleged privacy violations by your
practice.
It
is not required that each patient have a hard copy of the
privacy notice itself, only that you have documented that
they have reviewed the notice. Documentation can either be a
log, where patients would sign that they have reviewed the
policy, or a simple form that they can sign and you can
retain in their chart. Web
Link: Plain
Language Principles and Thesaurus for Making HIPAA Privacy
Notices More Readable, DHHS Tip:
Checking for
documentation of review should become part of your
daily chart review or new patient registration materials.
For all initial encounters your front office staff can hand
the patient a privacy notice when they arrive. For existing
patients, staff can hand them the notice on their next visit
to the office. Tip:
In order to avert misunderstanding and complaint
lodging, avoid the use of the word correction in your
Notice of Privacy Practices. Also, when the original record
is used or disclosed, the new amended statement will
accompany any released copies. Source AHIMA Other things to consider: You
must prominently post your privacy policy in your office. An
abbreviated version of policy is fine. If you have a web
site, it must be on your web site. You may distribute it
via e-mail with a return receipt. If you forget to
distribute the notice to patients, you should mail one to
the patient the same day and document why it was not
distributed at the time of service and that the notice was
mailed. Web
Links Sample
Privacy Policy (Source: OHIC)
HIPAA
Notice of Privacy Practices (Source: AMA)
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