We have taken a long journey in this HIPAA Readiness series, so let’s not forget the basics —
Stop Me If You’ve Heard This One: Notice of Privacy Practices
Communication is the key to success. Or so read a poster on the wall in my high school English class. Communication is also the key to HIPAA compliance. You need to give every patient a Notice of Privacy the first time you provide any health service. The Notice of Privacy Practices must be designed to inform the patient as to how their Protected Health Information may and may not be used, and provide them with information related to their individual rights.
Communication is a two-way street. Another tried and true aphorism that’s relevant to HIPAA. Your patients need to tell you that they received a Notice of Privacy Practices. Luckily, you don’t have to document that they read and understand the notice, but you do need to get them to sign an acknowledgement that you gave it to them. You probably have a checklist for serving new patients; it may even be part of your pharmacy software. Make sure that the Notice of Privacy Practices acknowledgment is on it, and that you have some method of quality control to double check that all patient files include an acknowledgment. If you find a file that is missing the acknowledgment, don’t panic, but put an alert on their account to make sure you get one on the patient’s next visit.
Here’s another old saw: Repetitio mater studiorum est, or Repetition is the mother of all learning. You’ve handed your patients a Notice of Privacy Practices which they will very likely toss, file away, or lose. It is therefore prudent for you to offer the notice in other, more lasting forms. Post a copy at the pharmacy counter. Put a Privacy Notice link on every page of your website where patients go for services like prescription renewals. Such repetition adheres to another ancient adage: CYA, or Cover your…assets.
For more information about HIPAA and other pharmacy compliance solutions for your pharmacy, call PRS at 1-800-338-3688 and speak with one of our Specialists. Also, stop back here for additional posts on compliance issues and what you need to know as a pharmacy owner.