Notice of Information Practices

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Notice of Information Practices

• Privacy Officers Forum
• June 14, 2002
• Karen Nestor RN, MBA
• Privacy Officer
• UMass Memorial Health Care

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Decision Points

• Adopt a Model
• Level of Detail
• Style
• Cost
• Single vs. Joint
• Signature

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Our Process

• Privacy Security Work Group
• Member Entity Work Groups
• Executive Steering Committee
• NEHW Privacy Security Group
• General Counsel
• Marketing
• Privacy Officers

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1. Plain Language

• Short Sentences
• Short Sections
• Active Voice
• Use you
• Common, everyday words
• Alternate means language, video

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2. Header

• This notice describes how medical information
  about you may be used and disclosed and how you
  can get access to this information. Please
  review it carefully.

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3. Uses Disclosures

• Examples of TPO
• Those permitted/required without authorization
• Preemption applies
• Sufficient detail

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4. Other Uses

• Appointment reminders
• Treatment alternatives
• Health related benefits and services
• Fundraising
• Those involved in care, Clergy, Inpatient List,
  Business Associates

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5. Authorization

• All other uses only with authorization
• Right to revoke

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6. Entity Duties

• Required by law to
• Maintain privacy
• Provide the notice
• Abide by terms
• Reserve right to change practices
• Describe how revised notice provided

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7. Patient Rights

• Restrictions
• Entity does not have to agree
• Confidential communications
• Inspect Copy
• Amend
• Accounting
• Paper copy

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8. Complaints

• How to lodge a complaint
• No retaliation
• May complain to HHS

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9. Contact

• Point of contact for additional information

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10. Joint Notice

• Single notice for OHCA
• All abide by terms
• Reasonably identify entities/sites
• Statement that PHI is shared for TPO