Policies and Procedures HIPAA/ Privacy

Notice of Privacy Practices

45 C.P.R. §164.520

Purpose

To ensure that all patients and potential patients are informed about how the Dental Practice uses and discloses PHI and about certain rights they have regarding the PHI pertaining to them.

Policy

The Dental Practice will post the Notice of Privacy Practices (“Notice”) conspicuously within the practice facilities. The Dental Practice will also provide a copy of the Notice to our patients and to anyone else who requests a copy. The Dental Practice will revise the Notice as appropriate and will provide the revised Notice as required by HIPAA.  The Practice will not use or disclose patient information in a manner that is inconsistent with the office, HIPAA, or state law.

Procedures

1. The Dental Practice reception desk personnel will provide the Notice to each new patient at his or her first appointment or to any other person who requests a See Notice of Privacy Practices – (NPP form.)
   • A supply of copies of the Notice will be kept at the reception desk for people who ask for a copy to take with
   • The Notice will also be available in the receptionist’s workstation for printing if a pre-printed hard copy is not
2. When Dental Practice personnel provide a patient or other person with the Notice, they will ask the patient to sign an acknowledgement that they have received See bottom of Health History Form (HHF form) or Acknowledgment of Receipt of Notice of Privacy Practices – (ARNPP form.)
3. If the patient refuses or is otherwise is unable to sign the Health History Form (HHF form) or Acknowledgment of Receipt of Notice of Privacy Practices (ARNPP form), the Dental Practice will document, on the form, the actions that were taken to obtain the patient’s  signature  and  the  reason(s)  why  a  signed acknowledgment was not obtained.
   • If the patient has a personal representative, such as the parent or guardian of a minor, the Dental Practice will provide the Notice to the personal representative and ask the personal representative to sign the bottom of the to sign the Health History Form (HHF form) or Acknowledgment of Receipt of Notice of Privacy Practices – ARNPP form.
   • The Dental Practice will retain each completed acknowledgment form for six years from the date it was created or the date that it was last in effect, whichever is
4. In addition, the Notice will be posted conspicuously on the Dental Practice website, if any, and in an area within the practice that can be easily observed by patients and other persons visiting the Dental
5. The Dental Practice Privacy Official is responsible for:
   • Developing the Notice, keeping it current, and ensuring that patients are provided with the most recent
   • Providing the Notice to patients and others who request it by:
     • Posting the Notice in a clear and  conspicuous location  in the Dental Practice, as appropriate;
     • Posting the Notice prominently on the Dental Practice’s website, if any; and
     • Ensure that there is adequate supply of copies of Notices at the reception desk for people who ask to have a copy of
   • Training workforce members to comply with the
   • Responding to questions that patients or other persons have about the
   • Informing patients that they have the right to file a complaint if they feel that the Dental Practice or the Notice does not comply with
   • Notifying Business Associates of limitations in Notice to the extent that such limitations affect the Business Associate’s
6. Revising the Notice
   • Whenever the Dental Practice’s privacy practices change, or there is a change in the  law or the HIPAA Rules that requires a change to the Notice, the Privacy Official will determine whether the Notice must be revised and consult with legal counsel when
   • If the Notice is revised, the Dental Practice will on or after the effective date of the revision:
     • Provide the revised Notice to new patients on their first appointment and ask them to sign the
     • Have a supply of copies of the revised Notice available in the  Dental Practice Notice and give a copy to anyone who asks fora
     • Post the new Notice in a clear and prominent location in the Dental practice notice.
     • Conspicuously post the new Notice on the Dental Practice website, if
     • Retain at least one copy of both the old and the new Notice for at least six years from the date when the document was created, or the date when the document last was in effect, whichever is
   • The following supporting documents are attached to this Policy and Procedures:
     1. Notice of Privacy Practices – NPP form.
     2. Health History Form – HHF form.
     3. Acknowledgment of Receipt of Notice of Privacy Practices – ARNPP form.
     4. Patient Disclosure Instructions – PDI form.