Attorney Jeff Drummond blogs:
Changing your NoPP? As you know, the original Privacy Rule requried covered entities to adopt a “Notice of Privacy Practices” to tell patients (or beneficiaries if you’re a health plan) how they plan to use and disclose the individuals’ PHI. You get this sheet each time you go to a doctor for the first time (it says, almost always in caps and usually bold, “THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.” That’s because that’s how it was written into the Privacy Rule regs).
The question rattling around the AHLA HIT list today was whether HITECH will require covered entities to revise their NoPPs. There are only 2 areas within HITECH that I can think of that might impact what’s disclosed in your NoPP: the “hide” rule and the changes to marketing.
Read more of his comments on HIPAA Blog.