Vicki,

In the preamble to the Modifications to the Final Rule that was published in 
August of 2002 (Federal Register/ Vol. 67, No. 157) on page 53240 there is a 
discussion about service that is delivered by phone.  Here is where HHS has 
suggested that for service delivered by phone, the NPP must be mailed to the 
patient "no later than the day of that service delivery".

They clarify that if the initial phone contact is simply to schedule an 
appointment, then the Notice does not have to be mailed but can be given to 
the patient when they arrive for their appointment.  Unfortunately, that is 
the only scenario they specifically address so I would infer from that that 
any other service conducted by phone (such as refilling a prescription) would 
require you to mail the NPP to the patient that day.

Noel Chang
Integral Practice Solutions
--
Open WebMail Project (http://openwebmail.org)


---------- Original Message -----------
From: [EMAIL PROTECTED]
To: "WEDI SNIP Privacy Workgroup List" <[EMAIL PROTECTED]>
Sent: Wed, 26 Mar 2003 16:54:53 -0500
Subject: Patient Phone Calls and NPP

> After 4/14, when a patient calls for a prescription refill, or to 
> ask a medical question, are we obligated to then mail them a copy of 
> the NPP and ask them to send us a signed acknowledgement? A question 
> like this was asked regarding prescriptions at the Atlanta OCR 
> conference in February and the answer that day was no, the next 
> visit would be the occasion to give the NPP. Today, on the OCR 
> conference call, a similar question was asked and the answer was 
> that the NPP needed to be mailed. Can anyone direct me to a 
> reference or guidance on this?
> 
> Vicki Saunders
> Compliance Manager/Privacy Officer
> [EMAIL PROTECTED]
> 
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