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Notice of new Privacy Policy requirements

July 23, 2013

Question:

Jennifer,

Thank you for providing the free webinar on the HIPAA changes and for providing my practice with our new Privacy Policy in advance of the September 23rd deadline.  My question is, now what do I do with the new policy?  Do I just hand it out to patients as they come in?

Thanks,
Dr. A

Answer:

Good question!  Promulgation requirements for your new Privacy Policy have not changed under HIPAA.  You are still required to have the notice available at your practice for individuals to request to take with them.  The practice is also required to post the notice in a "clear and prominent location where it is reasonable to expect individuals seeking services from the [practice] to be able to read the notice.  45 CFR 164.520. 

If patients are accessing their forms online on your website or through a portal, you should also post or make available for download or viewing your new Privacy Policy online.  This requirement is not set forth in the Final Rule, however, this advice should be followed if you are receiving patient information via the internet.  With that recommendation it is imperative to also note no communications should be received or transmitted via the internet unless you have proper security measures in place to ensure the confidentiality of such transmissions.  Each practice utilizing computers, let alone the internet, are required to have a Security Policy in place.

For those of you involved in a Hospital based practice, please be advised that the practitioner creating and responsible for maintaining patient information will be responsible should HIPAA not be abided by.  So, from the government's perspective, the argument "i didn't update my policies because I work for the hospital", is not going to fly should you be investigated or audited as a result of complaint or routine review.  All practitioners are required to employ modified Privacy Policies prior to September 23, 2013.  For more information, view our free webinar below and to purchase HIPAA compliant Privacy Policies, click here.   

 
 

Looking for HIPAA forms prior to September's deadline?  
Check out our order form below or our website.
Not sure why you need new forms? 
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