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HIPAA Notice of Privacy Practices Policy

PURPOSE

To comply with the requirements of 45 C.F.R. §164.520 of the HIPAA Privacy Standards with respect to providing Connections for Kids’ (“CFK”) clients copies of CFK’s Notice of Privacy Practices.

POLICY

It is the policy of CFK to post, offer and provide to each client a copy of CFK’s Notice of Privacy Practices that describes (i) the uses and disclosures of the client’s protected health information (“PHI”) that may be made by CFK, (ii) the client’s rights with respect to his or her PHI, and (iii) CFK’s legal duties with respect to the client’s PHI, in accordance with the requirements of the HIPAA Privacy Standards.     

PROCEDURES OUTLINE

A. Provision of Notice on Request: CFK and its workforce members will make CFK’s Notice of Privacy Practices (Addendum A) available to any person who requests a copy.

B. Provision of Notice at Time of Registration or First Service Delivery: Members of CFK’s workforce responsible for registering CFK clients at CFK practice locations will:

    1. Offer to each client (or the client’s authorized representative) at the time of admission or registration, or as soon as practical after such time but no later than the date health care services are first provided to the client (including services delivered electronically), a copy of CFK’s Notice of Privacy Practices (Addendum A); and
    1. Except in an emergency treatment situation, make a good faith effort to obtain each client’s (or the client’s authorized representative’s) written acknowledgement of receipt or refusal of CFK’s Notice of Privacy Practices, and document such good faith efforts to obtain such acknowledgement and the reason why the acknowledgement was not obtained, on the Acknowledgement of Receipt/Refusal of CFK’s Notice of Privacy Practices Form attached to this Policy as Addendum B.

    C. Provision of Notice in Emergency Circumstances: In an emergency treatment situation, CFK will provide a copy of CFK’s Notice Privacy Practices as soon as reasonably practicable after the emergency treatment situation.

    D. Provision of Electronic Notice:

      1. Website: CFK will prominently post its Notice of Privacy Practices on its website location that provides information about CFK’s customer services or benefits, and will makes the Notice available electronically through its website.
      2. Provision of Notice by Email: CFK may provide its Notice of Privacy Practices to a client (or the client’s authorized representative) by email if the client (or authorized representative) agrees to electronic notice and such agreement has not been withdrawn.  If CFK knows that the email transmission has failed, CFK will provide a paper copy of the Notice to the client (or authorized representative).
      3. Timeliness of Electronic Notice: If the first service delivery to a client is delivered electronically, CFK will provide an electronic Notice of Privacy Practices to the client (or the client’s authorized representative) automatically and contemporaneously in response to the client’s first request for services.
      4. Right to Request Paper Copy: A client who has received CFK’s Notice of Privacy Practices electronically retains the right to obtain a paper copy of CFK’s Notice upon request, and CFK will provide the client with a paper copy of the Notice on request.

        E. Updates and Revisions to Notice: CFK and its Privacy Officer will promptly revise and distribute CFK’s Notice of Privacy Practices whenever there is a material change to the uses and disclosures, clients’ rights, CFK’s legal duties, or other privacy practices stated in CFK’s Notice of Privacy Practices.  Unless required by law, CFK will not implement a material change to any term of its Notice of Privacy Practices prior to the effective date of the notice in which such material change is reflected.  CFK’s Privacy Officer and Executive Director will ensure that whenever CFK’s Notice of Privacy Practices is revised, copies of the revised Notice are posted, and made available upon request, at each CFK practice site on or after the effective date of the revised Notice.

        F. Availability of Notice at CFK Practice Locations: CFK’s Privacy Officer and CFK’s Executive Director will ensure that copies of CFK’s Notice of Privacy Practices are available at each CFK practice location for clients (or their authorized representatives) to request to take with them.

        G. Posting of Notice at CFK Practice Locations: CFK’s Privacy Officer and CFK’s Executive Director will ensure that a copy of CFK’s Notice of Privacy Practices, or a summary thereof, is posted in clear and prominent locations at each CFK practice location where it is reasonable to expect clients seeking services to be able to read the Notice.  If a summary Notice is posted in lieu of the full Notice at a CFK practice location, copies of the full Notice must be immediately available (such as on a table or in a brochure rack directly under or near the posted summary Notice) for clients to pick up without having to ask a receptionist for a copy of the full Notice.

        H. Documentation Retention: CFK will retain the following documentation for a period of six years from the date of its creation, or the date when it was last in effect, whichever is later: 

          1. CFK will retain, either in paper or electronic form, copies of each version of the Notice of Privacy Practices it provides to clients.
          2. CFK will retain, either in paper or electronic form, copies of any written acknowledgements of receipt of CFK’s Notice of Privacy Practices or documentation of its good faith efforts to obtain such written acknowledgements from clients.