Privacy Officer's Roundtable

Notice of Privacy Practices

  • 1.  Notice of Privacy Practices

    Posted 12-04-2018 03:30 PM
    A quick poll regarding your Notice of Privacy Practices. Do you…

    1. Ask patients to re-acknowledge receipt on a periodic basis?

    2. If #1 is yes, what is your timeframe for re-acknowledgement (e.g., one year)?

    3. If #1 is no, do you just provide at first visit and then if changed/new date is published?

    4. Are there any other considerations in terms of your timeframe for issuing your NPP?

    Thanks in advance for your responses

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    Andy Reeder, CHPC, CISSP
    Director, HIPAA Privacy and Security
    Rush University Medical Center
    Chicago, IL
    andrew_reeder@rush.edu
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    2020 SCCE Membership


  • 2.  RE: Notice of Privacy Practices

    Posted 12-04-2018 03:41 PM
    1. Ask patients to re-acknowledge receipt on a periodic basis?  NO

    2. If #1 is yes, what is your timeframe for re-acknowledgement (e.g., one year)?

    3. If #1 is no, do you just provide at first visit and then if changed/new date is published? ONLY PROVIDE AT FIRST VISIT - WE DO NOT ASK PATIENTS TO SIGN AN ACKNOWLEDGEMENT THAT THEY WERE OFFERED A COPY  OF THE REVISED NPP

    4. Are there any other considerations in terms of your timeframe for issuing your NPP? NO

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  • 3.  RE: Notice of Privacy Practices

    Posted 12-04-2018 04:02 PM
    We only offer the NoPP and get an acknowledgement on their first visit (or ASAP after if unique circumstances).  We will provide/post revised NoPP's, but do not get an acknowledgement again.

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    David Garrison CHC,CHPC
    Compliance/Privacy Officer
    SEARHC
    Juneau,AK
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    2020 SCCE Membership


  • 4.  RE: Notice of Privacy Practices

    Posted 12-04-2018 04:06 PM
    ​A quick poll regarding your Notice of Privacy Practices. Do you…

    1. Ask patients to re-acknowledge receipt on a periodic basis?  No

    2. If #1 is yes, what is your timeframe for re-acknowledgement (e.g., one year)?

    3. If #1 is no, do you just provide at first visit and then if changed/new date is published?  We provide at first visit and then offer again if the NoPP has changed.

    4. Are there any other considerations in terms of your timeframe for  No

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    Malinda Turner CHC
    Compliance/Privacy Officer
    Grant Memorial Hospital
    Petersburg,WV
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    2020 SCCE Membership


  • 5.  RE: Notice of Privacy Practices

    Posted 12-05-2018 08:55 AM
    Good Morning Andy,

    My organization does not ask patients to re-acknowledge receipt of their NPP on a periodic basis. The NPP is provided during the initial visit. Any changes that occur to the NPP are posted in a prominent place within the office for patients who have already received a copy of the original NPP. I do not believe it is necessary to resend an updated NPP to a patient who has already received it if it is posted in a prominent area in patient view (ex. office waiting room).  Any new patients coming into the office would receive the updated version.

    Timeframe for issuing NPP

    - Upon patients initial visit
    - If the patient is not able to acknowledge the receipt of the NPP at the time of admission/visit, this is documented in the chart and a copy is provided to the patient ASAP


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    Kelly Kutchak CHC
    Compliance Analyst
    Pittsburgh, PA

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    2020 SCCE Membership


  • 6.  RE: Notice of Privacy Practices

    Posted 12-05-2018 11:19 AM

    We have clients sign the acknowledgement once, upon admission.  On the form is a line that asks if they want to be notified if there any changes in the notice. 

     

    They can answer yes or no.   The overwhelming majority check no.

     

    A little off this path, but when I train staff in HIPAA, I ask if they've received a notice from their doctor and they'll state yes. 

     

    When I ask if they've read it, most say no  L 

     




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  • 7.  RE: Notice of Privacy Practices

    Posted 12-05-2018 02:51 PM
    1. Ask patients to re-acknowledge receipt on a periodic basis?- yes

    2. If #1 is yes, what is your timeframe for re-acknowledgement (e.g., one year)?-Every 3 years

    3. If #1 is no, do you just provide at first visit and then if changed/new date is published?- We provide if revisions are made and/or every 3 years. 

    4. Are there any other considerations in terms of your timeframe for issuing your NPP? We felt like it was good for the patient to receive again as a refresher.

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    Savannah Knuettel CHC
    Compliance Coordinator
    Galen Medical Group
    Hixson,TN

    The views expressed herein are my own and do not represent those of my employer or clients. They are not meant to constitute legal advice or create an attorney-client relationship.
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    2020 SCCE Membership


  • 8.  RE: Notice of Privacy Practices

    Posted 12-07-2018 10:25 AM
    ​Thanks everyone for your feedback!

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    Andy Reeder, CHPC, CISSP
    Director, HIPAA Privacy and Security
    Rush University Medical Center
    Chicago, IL
    andrew_reeder@rush.edu
    ------------------------------

    2020 SCCE Membership


  • 9.  RE: Notice of Privacy Practices

    Posted 12-07-2018 01:41 PM
    1. Ask patients to re-acknowledge receipt on a periodic basis?  NO

    2. If #1 is yes, what is your timeframe for re-acknowledgement (e.g., one year)?

    3. If #1 is no, do you just provide at first visit and then if changed/new date is published? YES

    4. Are there any other considerations in terms of your timeframe for issuing your NPP?

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    Carmen Camara , MS, CHC
    Compliance Generalist
    Greater Baltimore Medical Center
    Baltimore,MD
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  • 10.  RE: Notice of Privacy Practices

    Posted 06-16-2020 11:29 AM
    Hey Andy

    Sorry I'm a little late in my response:

    1. Ask patients to re-acknowledge receipt on a periodic basis?   Not required by the rule.  Only initially when they are first seen or soon after an emergency.  Make a good faith attempt to obtain the acknowledgement, or annotate the patient's refusal to sign and date it.

    2. If #1 is yes, what is your time frame for re-acknowledgement (e.g., one year)?  This is N/A and not required.

    3. If #1 is no, do you just provide at first visit and then if changed/new date is published?  Yes, publish the new NPP, make it available at your facility, and post it on your website.  

    4. Are there any other considerations in terms of your time frame for issuing your NPP?
    a.  If you are a health plan (I think Savannah's situation is?), the Heath Plan must provide the NPP to individuals initially, and every three years must notify individuals of the NPP and how to obtain one.
    b. If you are a Health Plan who does not post the NPP on your website, you must send out notification of the change within 60 days to all your clients.


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    Hernan Serrano
    St. Louis Metro Area
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    2020 SCCE Membership