Dr. Fairley,
My firm is recommending that the NPP be developed and implemented as soon as possible
just for the reason you mention: otherwise every patient who walks in the door on
4/15 will need to be provided with this document, any discussion/questions, etc. If
you can implement this part
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