Title: RE: named Privacy officer on NPP, posting

1) yes, you can just list the title of the Privacy Officer. That is what we are doing. Otherwise you have to redistribute every time your Privacy Officer changes.

2) I don't think this meets the requirements. But I'd see what everyone else says.
Deborah Campbell
Compliance Coordinator

Dominion Dental Services, Inc.
115 South Union Street, Suite 300
Alexandria, Virginia 22314

Phn: (703) 518-5000 ext. 3035
Fax: (703) 518-8849
Toll Free:  888-518-5338
Email: [EMAIL PROTECTED]

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-----Original Message-----
From: [EMAIL PROTECTED] [mailto:[EMAIL PROTECTED]]
Sent: Monday, March 10, 2003 12:39 PM
To: WEDI SNIP Privacy Workgroup List
Subject: named Privacy officer on NPP, posting


I have two quick questions for the group:
1.   When your Notice of Privacy Practices (NPP) says to contact the Privacy Officer for such and such, does the Privacy Officer need to be a NAMED individual  or can you just list the title of the contact person (e.g., the Privacy Officer)?

2.    Since the law calls for a "posting" of the NPP, can we display a stapled copy of our 6 page NPP in a locked bulletin board (which would then just show the first page of the NPP) and then have a sign next to this "displayed" NPP that tells the inquisitive patient where in our office they can get a complete copy of the NPP if they wish?  I realize that this proposal probably goes against the intent of this provision of the law but would it be technically be sufficient to meet the requirements of this provision?

Reasons behind such a proposal are 1.  Space is a problem, 2.  Hanging up a 6-8 page NPP looks trashy.  3.  All patient's will be personally handed the NPP so what's the point of posting it anyway?  4.  And we would be "posting" it, it's just that you could not read all the pages of the posted version!

Thanks for all advice provided.
Rich Fairley

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