Health Information Compliance Alert

READER QUESTION:

Use Common Sense With NPPs

Question: "Required notices sent by financial institutions -- such as the Gramm-Leach-Bliley notices concerning information-collection and data-sharing -- were often printed in very small fonts. Does HIPAA have a minimum font size for NPPs?"


Missouri Subscriber


Answer: According to Robyn Meinhardt in the Denver office of Foley & Lardner, HIPAA doesn't regulate the font size for your notice of privacy practices. However, she cautions covered entities to consult local and state laws to see if there is a minimal font requirement for such notices. States like California have recently passed legislation that would require documents such as NPPs to be printed in a 12-point font, she reports.

"I've seen people that -- in order to make their NPP shorter -- have put it in a microscopic type, like 8-point font," she remarks. You might not get cited with a HIPAA violation for doing this, she states, but you do run the risk that patients will nonetheless complain to the OCR, which may in turn order you make your NPP more legible.

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