I cited the response that follows regarding
12-point type requirements for notices and forms in California. Would you happen
to have the citation for that?
Thanks.
-----Original Message-----
From: Stanton, Clark
[mailto:[EMAIL PROTECTED]]
Sent: Monday, February 03, 2003 8:27 AM
To: Health
Information and Technology List
Subject: [hit] RE: Privacy Notice/Font
Size
I have not seen anything at the federal level. California
passed a law last year that requires notices and forms given to patients be in
at least 12 point type.
Clark Stanton
Davis Wright Tremaine LLP
San
Francisco
-----Original Message-----
From: Keith Tularaksa
[mailto:[EMAIL PROTECTED]]
Sent:
Tuesday, March 18, 2003 1:26 PM
To: WEDI SNIP Privacy Workgroup
List
Subject: RE: NPP type size?
I'm sorry to beat this one to
death, but is there a citation for California stating that the font size has to
be 12 pt for NPP?
Thanks,
Keith Tularaksa
HIPAA Project
Manager
Star HRG
(602) 749-7600, ext. 1490
email:
[EMAIL PROTECTED]
-----Original Message-----
From:
Sherry Neuman [mailto:[EMAIL PROTECTED]]
Sent: Friday, March 14, 2003 11:29
AM
To: WEDI SNIP Privacy Workgroup
List
Subject: RE: NPP type
size?
This question was asked recently, and the answer was that in
California the type size must be 12 pt.
Also:
From the final Privacy
Regulation Preamble:
"Plain Language
As in the
proposed rule, we require the notice to be written in plain language. A covered
entity can satisfy the plain language requirement if it makes a reasonable
effort to: organize material to serve the needs of the reader; write short
sentences in the active voice, using ``you'' and other pronouns; use common,
everyday words in sentences; and divide material into short
sections.
[[Page 82549]]
We do not require
particular formatting specifications, such as easy-to-read design features
(e.g., lists, tables, graphics, contrasting colors, and white space), TYPE FACE,
AND FONT SIZE. However, the purpose of the notice is to inform the recipients
about their rights and how protected health information collected about them may
be used or disclosed. Recipients who cannot understand the covered entity's
notice will miss important information about their rights under this rule and
about how the covered entity is protecting health information about them. One of
the goals of this rule is to create an environment of open communication and
transparency with respect to the use and disclosure of protected health
information. A lack of clarity in the notice could undermine this goal and
create misunderstandings. Covered entities have an incentive to make their
notice statements clear and concise. We believe that the more understandable the
notice is, the more confidence the public will have in the covered entity's
commitment to protecting the privacy of health
information...."
and
"Comment: We received many comments on the
model notice provided in the proposed rule....A few commenters recommended
specific formatting requirements, such as FONT SIZE OR
TYPE.
Response: On the whole, we found commenters'
arguments for flexibility in the regulation more persuasive than those arguing
for more standardization. We agree that a uniform notice would not capture the
wide variation in information practices across covered entities. We therefore do
not include a model notice in the final rule, and do not require inclusion of
specific language in the notice (except for a standard header). We also do not
require particular formatting. We do, however, require the notice to be written
in plain language. (See above for guidance on writing documents in plain
language.) We also agree with commenters that the notice should contain a
standard header to draw the individual's attention to the notice and facilitate
the individual's ability to recognize the notice across covered entities...."
(emphases added)
-----Original Message-----
From:
Musser, Marilyn J [mailto:[EMAIL PROTECTED]]
Sent:
Friday, March 14, 2003 10:16 AM
To: Sherry Neuman; WEDI SNIP Privacy
Workgroup List
Subject: RE: NPP type size?
Hi- the body type for
our NOPP is 10 pt - see it on our web site: http://www.wellmark.com/e_business/pdf/T-2601.pdf
Marilyn Musser
Provider Relations Manager
HIPAA-AS
Communications Office
Wellmark, Inc.
phone: 515.248.5588
fax:
515.245.4620
[EMAIL PROTECTED]
-----Original
Message-----
From: Sherry Neuman [mailto:[EMAIL PROTECTED]]
Sent: Friday, March 14, 2003 10:55
AM
To: WEDI SNIP Privacy Workgroup
List
Subject: RE: NPP type
size?
Please reply to all.
-----Original
Message-----
From: Beth Cole [mailto:[EMAIL PROTECTED]]
Sent:
Friday, March 14, 2003 7:23 AM
To: WEDI SNIP Privacy Workgroup
List
Subject: NPP type size?
I've seen several references on
various mailing lists to something said
at one of the OCR regional
conferences regarding the mandated font size
of the NPP. What I'm
seeing indicates that attendees at the conference
were told that in order to
comply with other Medicare regulations, the
type size had to be no less than
12 point.
If we take it to 12 point, our NPP is at 8 pages. If we
put it at
either 9 or 10 point, it's a 4. So, this is slightly
worrisome to us.
Can anyone give me a black-letter law or regulation
citation on this, or
was this someone talking at a conference who didn't know
what he was
talking about?
Thanks!
Beth
--
Beth
Cole
Information Services Support Specialist
Newman Regional
Health
Emporia, Kansas
---
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
---
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
