NPP – What You Need to Know

The next milestone date related to the HITECH Act and the Genetic Information Nondiscrimination Act of 2008 (GINA) is almost here.  By September 23, 2013, the Notice of Privacy Practices (NPPs) are required to include specific information in order to be compliant with the Omnibus final rule.

 

What are NPPs?

NPPs are documents that tell patients:

  • 1.) Their rights with regard to protected health information (PHI)
  • 2.) How and when their information can be shared

 

While your clients should already have an NPP to provide to employees, the Final Rule now specifies the updates that must be included with this document:

Instances when required authorization is needed from participants before disclosing PHI such as:

  • 1.) Most uses and disclosure of psychotherapy notes if the Plan maintains them
  • 2.) Uses and disclosure for marketing
  • 3.) Sale of PHI
  • 4.) Other uses and disclosures not described in the NPP

Additional Participant’s rights such as:

  • 1.) Opting out of fundraising contacts
  • 2.) Being notified by the Plan of any breach of his or her unsecured PHI

The prohibition of disclosing genetic information of an individual for underwriting purposes.

 

We’ve Got You Covered

The good news is BPA has posted a HIPAA compliant NPP template that is perfect for downloading and sharing with clients. Your client can log into our website, download the template, complete the requirements then distribute to their employees in time to meet the deadline.

 

In addition

If your client posts the NPP on their website:

1.) They must also prominently post the material change or the revised notice on the website by the time of the effective date of the material change
2.) Your client must provide the revised notice, or information about the change and how to obtain the revised NPP, in its next annual mailing to the  participants covered by the plan.
3.) If your client does NOT have a website, then it must provide the revised NPP, or information about the updates and how to obtain the revised NPP, to   individuals covered by the plan within 60 days of the material revision

As always, BPA is your first resource for information in helping your clients through the challenges of meeting the Affordable Care Act deadlines.

 

View the Notice of Privacy Practices Template Here