Optometry Coding & Billing Alert

Q: Is it sufficient to provide patients with only a URL link to our notice of privacy practices (NPP)?


A: No, says attorney Robyn Meinhardt of Foley & Lardner in Denver. While the privacy regs do make allowances for the electronic posting and distributing of NPPs, covered entities nonetheless "have to have the paper copy available" at all times, she says. HIPAA requires all notices to contain a statement that informs individuals of their right to receive a paper copy of the entity's NPPupon request (see 45 CFR 164.520).

"I know some facilities are thinking of having a dedicated computer terminal or terminals in the waiting area where people can view the notice of privacy practices online," Meinhardt reports. However, such a practice "seems to be more like complying with the posting requirement and not the hard-copy requirement," she states. If individuals viewing the NPPonline in the facility could also print it out if they wanted, then that might function as "the equivalent of giving them a copy," Meinhardt says.

"I know people are trying to get creative about this because they're anticipating a huge printing cost, and most of them end up in the trash," she says. Just remember to have that paper copy of your NPPready for distribution on April 14, she says.