Create a confusion-free NPP to avoid compliance crackdowns Even if your optometry practice has a comprehensive, legally airtight notice of privacy practices (NPP), you're still vulnerable if you don't help your patients comprehend it fully. Let our three expert tips help you make your NPP more patient-friendly without putting you in the HHS Office of Civil Rights' spotlight. 1. Use Examples to Be Clear Pinpoint and revise the sections where your notice might cause some confusion for your patients, says Daniel Shepherd, privacy officer for Singing River Hospital System in Ocean Springs, Miss. 2. Keep It Short and Sweet If you can't whittle your privacy notice down to a couple of pages, try breaking it into two parts: a summary and a detailed explanation, says partner Debbie Larios, an attorney with Miller & Martin in Nashville, Tenn. 3. Avoid Deluging With Details You have to focus on your patients' needs, not the rule's requirements, Downing says. Ask yourself: "What do my patients need to know?" she says. Write your notice so that an eighth-grader could read and understand it, and adjust the text size for your patients' age, she says.
Tip: Get your staff in on the action, says Katherine Downing, director of patient privacy for HCA Healthcare in Nashville, Tenn. Ask each staffer to read your notice and point out the areas that are confusing or outdated, she says.
Your summary should clearly state your patients' "basic privacy rights and what disclosures you will make," Larios says. Include a disclaimer at the beginning of your summary that directs patients to your full notice, she says.
Good idea: Don't wait for your patients to request a copy of your full NPP. Instead, "post it in your waiting room, and have the patient sign a condensed version," says Linda Boudreau, office manager for Optometric Associates in Lewiston, Maine. Keep the summary with the patient's chart, Boudreau says.