Q. Our notice of privacy practices (NPP) is several pages long. Does HIPAA require us to post each page on the wall in our waiting room?
A. No, the HIPAA final rule does not require physicians to post the entire NPP on the wall. In final rule published in the Federal Register Vol. 78, No. 17 / Friday, January 25, 2013 / Rules and Regulations, page 5625, the U.S. Department of Health and Human Services says:
In response to several comments expressing concern about printing costs for new NPPs, we clarify that providers are not required to print and hand out a revised NPP to all individuals seeking treatment; providers must post the revised NPP in a clear and prominent location and have copies of the NPP at the delivery site for individuals to request to take with them. … We also clarify that while health care providers are required to post the NPP in a clear and prominent location at the delivery site, providers may post a summary of the notice in such a location as long as the full notice is immediately available (such as on a table directly under the posted summary) for individuals to pick up without any additional burden on their part. It would not be appropriate, however, to require the individual to have to ask the receptionist for a copy of the full NPP. (Emphasis added)
TMA members can download a sample notice of privacy practices from the TMA website (log-in required).
NOTICE: The Texas Medical Association provides this information with the express understanding that 1) no attorney-client relationship exists, 2) neither TMA nor its attorneys are engaged in providing legal advice and 3) that the information is of a general character. This is not a substitute for the advice of an attorney. While every effort is made to ensure that content is complete, accurate and timely, TMA cannot guarantee the accuracy and totality of the information contained in this publication and assumes no legal responsibility for loss or damages resulting from the use of this content. You should not rely on this information when dealing with personal legal matters; rather legal advice from retained legal counsel should be sought.
Published Nov. 22, 2013
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