Mr. Fairley,
in response to your question #2:
I am not an attorney, but I would advise that any time you are
taking an action that you realize is probably against the intent of the law,
even if it may successfully be argued to technically meet the requirements
of the law, is bad policy. Especially if there is an alternative that can
cost-effectively meet the requirement.
I have worked with clients who have taken their proposal, also approximately
6 pages, and had it turned into a poster format. It contained all the same
information, and even in the same order, but headings, fonts, and column
sizes were modified to make a convenient & professional looking poster.
This option may or may not solve your space issue, but it will clearly meet
the posting requirement in a manner which is not "trashy."
Regards,
Jay Astle
HIPAA Consultant
Unisys Corporation
703-556-5946
-----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
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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.
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