I agree with Deborah's response to both questions. At the HHS/OCR conference in Atlanta a few weeks ago, Richard Campanelli (Director of OCR) made it very clear that: If you don't get a Notice you haven't been provided with your rights. Also, that "Notice on the wall is not enough." He stated that the Privacy Rule's intention is that a direct treatment provider would provide each patient with a copy of the NPP - it has contact information on it and the individual should be able to take it home and read it. Mr. Campanelli was quite clear as to a CE's obligations relative to the NPP and that OCR would not look kindly on a CE who tried to cut corners. Jean Acevedo, LHRM, CPC, CHC.
In a message dated 3/10/2003 12:51:32 PM Eastern Standard Time, [EMAIL PROTECTED] writes: > 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] > ******************************************* > The information in this email is confidential and may be legally privileged. It is > intended solely for the addressee. Access to this email by anyone else is > unauthorized. > If you are not the intended recipient, any disclosure, copying, distribution or any > action taken or omitted to be taken in reliance on it is prohibited and may be > unlawful. > ********************************************************************* > > > > -----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 > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions > on this listserv therefore represent the views of the individual participants, and > do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. > If you wish to receive an official opinion, post your question to the WEDI SNIP > Issues Database at http://snip.wedi.org/tracking/. These listservs should not be > used for commercial marketing purposes or discussion of specific vendor products and > services. They also are not intended to be used as a forum for personal > disagreements or unprofessional communication at any time. > You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] > To unsubscribe from this list, go to the Subscribe/Unsubscribe form at > http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] > If you need to unsubscribe but your current email address is not the same as the > address subscribed to the list, please use the Subscribe/Unsubscribe form at > http://subscribe.wedi.org > --- > The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions > on this listserv therefore represent the views of the individual participants, and > do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. > If you wish to receive an official opinion, post your question to the WEDI SNIP > Issues Database at http://snip.wedi.org/tracking/. These listservs should not be > used for commercial marketing purposes or discussion of specific vendor products and > services. They also are not intended to be used as a forum for personal > disagreements or unprofessional communication at any time. > > You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] > To unsubscribe from this list, go to the Subscribe/Unsubscribe form at > http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] > If you need to unsubscribe but your current email address is not the same as the > address subscribed to the list, please use the Subscribe/Unsubscribe form at > http://subscribe.wedi.org --- The WEDI SNIP listserv to which you are subscribed is not moderated. The discussions on this listserv therefore represent the views of the individual participants, and do not necessarily represent the views of the WEDI Board of Directors nor WEDI SNIP. If you wish to receive an official opinion, post your question to the WEDI SNIP Issues Database at http://snip.wedi.org/tracking/. These listservs should not be used for commercial marketing purposes or discussion of specific vendor products and services. They also are not intended to be used as a forum for personal disagreements or unprofessional communication at any time. You are currently subscribed to wedi-privacy as: [EMAIL PROTECTED] To unsubscribe from this list, go to the Subscribe/Unsubscribe form at http://subscribe.wedi.org or send a blank email to [EMAIL PROTECTED] If you need to unsubscribe but your current email address is not the same as the address subscribed to the list, please use the Subscribe/Unsubscribe form at http://subscribe.wedi.org
