Barbara,
Anyway you cut it there are about 25-30 areas, not just a few paragraphs, that your organization needs to address in Privacy.  The idea of using the WEDI SNIP white paper on HIPAA policies and procedures to support your case is a good one.  In case you don't have it the URL is http://snip.wedi.org/public/articles/P&sp&p.pdf.
Good luck--John Phelan

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