Health Information Compliance Alert
MAKE CHANGES BEFORE YOU ASK PATIENTS TO RE-SIGN YOUR PRIVACY NOTICE
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Question: A visiting physician who recently joined our staff claims that patients must sign our notice of privacy practices annually. Is this mandated by the privacy rule?
California subscriber
Answer: "No," says David Szabo, a partner with Nutter McClennen & Fish in Boston. You don't need another signature unless you've made a material change to the notice, he clarifies.
Good idea: To eliminate the chances that your patients will need to re-sign your privacy notice, use generic language. For example, instead of "We will fax information to other treatment providers," say "We will exchange information with other providers for treatment purposes." That way, if you decide to send the information in the mail or electronically, you don't have to notify your patients first, Szabo says.
The Bottom Line: You do not have to ask patients to sign your notice of privacy practices unless either your policies and procedures change or the privacy rule is amended, Szabo assures.
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