I have to admit that I agree with William on the fact that I think few
recipients will read or care about the NPP unless or until they perceive a
problem. I work with GHPs. The NPP is one of dozens of disclosures
mandated by various federal regulations. Of course, each federal agency
thinks that the disclosure that it mandates is the most important. We (the
people who actually bring all the mandates together and write the materials
to be distributed to GHP participants) can't emphasize all of them. And,
frankly, when it comes down to what needs an employee's attention and
action, I'd pick, e.g., COBRA over the NPP any day.
-Original Message-
From: William J. Kammerer [mailto:[EMAIL PROTECTED]]
Sent: Monday, January 27, 2003 9:17 AM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP and illiterate population
It looks like I've touched a live wire here! I certainly have no problem
with the NPP as a pedagogical tool to inform patients and members of their
HIPAA privacy protections. The few that I've seen seem to be short and
readable re-hashes of the privacy rule. For example: We may disclose for
TPO, Where Required by Law or for Public Health Activities, To Avert a
Serious Threat to Health or Safety, For Law Enforcement or Specific
Government Functions, etc. And that we'll get a written authorization from
you for certain other things not allowed by the law - and you have a right
to inspect and amend records, get disclosures, file complaints, and so on.
Since distributing the NPP and gathering acknowledgements is expensive, I
doubt many (providers or payers) would have done it unless compelled by the
law. But at the end of the day, how would a patient be harmed by not
having received the NPP on her first visit? Even if the patient is not (now)
familiar with the law, the provider (or insurance company) is! She's still
protected (somewhat) by the law, whether or not she knows of its existence.
And most anyone has some intuition that she's been wronged if the hospital
gives away her most intimate health information to just anyone (the press?)
- which explains why Congress thought it was important to codify this stuff
into law. Now when she complains, her lawyer has an additional tool to work
with. But her HIPAA privacy protections don't simply disappear because she
couldn't read the notice. And, assuming the provider (or insurance company)
is otherwise diligent in obeying the law (e.g., he actually protects PHI),
how is he more vulnerable because he didn't have the notice printed in 16
different languages and Braille?
William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320
- Original Message -
From: Ribelin, Donald [EMAIL PROTECTED]
To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
Sent: Monday, 27 January, 2003 08:11 AM
Subject: RE: NPP and illiterate population
Yes William I do believe that some will read my company's NPP. Let me list
a few.
* Some patients
* Some patient's lawyer
* OCR after some patient files a complaint with HHS
* The jurors at the trial over the harm caused to some patient
* Some employee who also becomes a some patient
Donald L. Ribelin
HIPAA Project Manager
Firsthealth of the Carolinas
(910) 215-2668
[EMAIL PROTECTED]
-Original Message-
From: William J. Kammerer [mailto:[EMAIL PROTECTED]]
Sent: Friday, January 24, 2003 6:25 PM
To: WEDI SNIP Privacy Workgroup List
Subject: Re: NPP and illiterate population
Why agonize over it? Do you really believe anyone is going to read these
things? I'm literate - with full command of the English language - yet I've
never read one of those stupid GLB privacy notices from banks and credit
card companies, and probably would not have the patience to keep track of
all the subparts and insofar as'es. And what's with that tiny type they
always use?
William J. Kammerer
Novannet, LLC.
Columbus, US-OH 43221-3859
+1 (614) 487-0320
- Original Message -
From: Jennifer Peters [EMAIL PROTECTED]
To: WEDI SNIP Privacy Workgroup List [EMAIL PROTECTED]
Sent: Friday, 24 January, 2003 05:49 PM
Subject: RE: NPP and illiterate population
How is everyone handling a situation where a patient is literate, but unable
to comprehend the NPP?
-Original Message-
From: Bentz-Miller, Judith [mailto:[EMAIL PROTECTED]]
Sent: Friday, January 24, 2003 11:10 AM
To: WEDI SNIP Privacy Workgroup List
Subject: RE: NPP and illiterate population
We will be RECORDING it as a voice mail message (our system handles over 12
minutes!) and having an extension, with access on both
the local line and 800 line. We are also having a privacy (800
number) hotline set up and both numbers will be listed on business cards.
Business cards will be located at each receptionist desk.
-Original Message-
From: Traci Winter [mailto:[EMAIL PROTECTED]]
Sent: Friday, January 24, 2003 10:38 AM
To: WEDI SNIP Privacy Workgroup List
Subject: NPP and illiterate population
I know our NPP is supposed to be
