Today I had to pick up a script and was handed a NPP by the clerk at CVS. It's quite a thing, in small type, and manages to fit on an 8.5 X 11 sheet. It is printed on the back side of the usual medication info. In addition, on this back side, is a short explanation of the NPP and a tear-off box for a signature acknowledging receipt of the NPP. Seems people are actually signing and turning them in. The person I spoke to said CVS was alphabetizing and storing the signed return slips. Not sure how they will make sure people don't get multiple copies or none at all...CVS has revamped its medication sheet where you used to initial that you don't need to speak to the pharmacist (which was never explained)and now it's an acknowledgment that you got the NPP (this wasn't explained either, I just read it).
The notice seems OK, lists lots of uses for PHI, rights and way to complain. However, it is worth noting that the notice does not provide anything more than the name HHS. The notice says "If you believe your privacy rights have been violated, you can file a complaint with the CVS/Privacy Office at the address above or the Secretary of the United States Department of Health and Human Services. All complaints must be in writing. You will not be penalized in any way for filing a complaint."
I scanned this and can send it if anyone wants to see a copy. E-mail off list. Have to say after living with HIPAA for years it was frankly a little thrilling to get the notice. CVS staff seemed to be pretty well trained on what it all meant, too, and ahead of the game. I have a feeling we may find this to be the exception come April 14.
Theresa Defino
Health Care Writing and Communications
Rockville, MD
301-738-3721
[EMAIL PROTECTED]
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