My non-legal opinion is that this is overkill...and that patients will annoyed. I don't believe that was the intent of the privacy regulations.
1. Why do you expect your NPP to change frequently? Is it so specific that every new request for data (such as from a new accreditation agency) will cause it to be updated? 2. Could you date or letter your NPP so it is easier to recognize which edition/version was given? If your application can accomodate a yes/no to show they received it, why could it not accomodate a date or letter? 3. Think of the costs of this practice. Will you be keeping paper copies, which must be filed, or electronic copies, which take up disk space? My personal opinion only. Mimi Mimi Hart Ó¿Õ* Research Analyst, HIPAA Iowa Health System 319-369-7767 (phone) 319-369-8365 (fax) 319-490-0637 (pager) [EMAIL PROTECTED] >>> "Matthew Rosenblum" <[EMAIL PROTECTED]> 01/29/03 18:56 PM >>> Traci, You will still need to maintain (and track) those signed-acknowledgements. In the Committee's plan, it seems that there will be many more acknowledgements to maintain. I hope that this helps. Your questions are always welcome. Matt Matthew Rosenblum Chief Operations Officer Privacy, Quality Management & Regulatory Affairs http://www.CPIdirections.com <http://www.cpidirections.com/> CPI Directions, Inc. 10 West 15th Street, Suite 1922 New York, NY 10011 (212) 675-6367 [EMAIL PROTECTED] CONFIDENTIALITY NOTICE: This E-Mail is intended only for the use of the individual or entity to which it is addressed and may contain information that is privileged, confidential and exempt from disclosure under applicable law. If you have received this communication in error, please do not distribute it. Please notify the sender by E-Mail at the address shown and delete the original message. Thank you. AVISO DEL CONFIDENCIALIDAD: Este email es solamente para el uso del individuo o la entidad a la cual se dirige y puede contener información privilegiada, confidencial y exenta de acceso bajo la ley aplicable. Si usted ha recibido esta comunicación por error, por favor no lo distribuya. Favor notificar al remitente del E-Mail a la dirección mostrada y elimine el mensaje original. Gracias. -----Original Message----- From: Noel, Linda A. [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 3:15 PM To: WEDI SNIP Privacy Workgroup List Subject: RE: NPP revisions Expense. Linda Noel Corporate Privacy Officer Corporate Compliance Orlando Regional Healthcare 321-843-8693 -----Original Message----- From: Traci Winter [mailto:[EMAIL PROTECTED]] Sent: Wednesday, January 29, 2003 2:27 PM To: WEDI SNIP Privacy Workgroup List Subject: NPP revisions 164.520 [c][2][iv] Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision and promptly comply with the requirements of paragraph [c][2][iii] of this section, if applicable. I just want to run this by everyone, in our HIPAA committee meeting today we have decided to provide a NPP and get a signed acknowledgement of receipt with each admission to home care services, even if the patient was previously receiving services from our agency. The reasoning is, with the rapid turnover of our patients it would be extremely difficult to track which "edition" of our NPP a patient had received, and since our patients sometimes are re-admitted to our services years down the road it would allow us to make sure we had documentation that the NPP had been given. We may put a section on our acknowledgement form for the patient to check/sign if they are refusing a copy due to previous receipt. I think this should cover us pretty well**. any cons to the plan? Traci Winter Hospitals Home Health Care, Inc. --- The WEDI SNIP listserv to which you are subscribed is not moderated. 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