Notice of Privacy Practices

As we continue to discuss the Notice of Privacy Practices (NPP), I want you to ask yourself these questions. First, where is your NPP located within your office? Second, where are the copies of the NPP located that you must supply patients with? And third, have you seen the NPP located on your website? If you don’t know the answer to these questions, be sure to take a moment after this course to find the answers.

It’s important to know and understand that as a covered entity, you must make your notice available to any person who asks for it. You must also prominently post and make available its notice on any website you maintain that provides information about your customer services or benefits.

You are required to provide the notice to the individual no later than the date of first service delivery and, except in an emergency treatment situation, make a good faith effort to obtain the individual’s written acknowledgment of receipt of the notice.

If an acknowledgment cannot be obtained, the provider must document his or her efforts to obtain the acknowledgment and the reason why you were not able to obtain it. If communicating with a patient electronically, first ensure that you are using a HIPAA compliant communication system, but also know that you must send an electronic notice automatically in response to an individual’s request for service if you do not have the signed acknowledgment from a previous visit. The provider must make a good faith effort to obtain a return receipt from the individual in response to receiving the notice.

Now, in an emergency situation, which does not happen as often within our industry, you must provide the notice as soon as it is reasonably practical to do so after the emergency situation has ended. Make the latest notice, which is the one that reflects any changes within your privacy policies available at the provider’s office or facility for individuals to take with them, you must also post it in a clear and prominent location within your facility.  A covered entity may email the notice to an individual if the individual agrees to receive an electronic notice.

At the end of this program, we will provide you with a sample NPP for you to review and to compare to your current NPP. We also want to reference the HHS.gov website again, where you can find other models or samples of the NPP that may be helpful in reviewing and revising your Notice of Privacy Practices.