The HHS’ Office of Civil Rights has developed a couple of different model notices of privacy practices that can be used by health plans. There are 4 different formats of these sample notices:
The model notices are posted here. The files labeled “NPP Health Plan Files” could be used by health plans that are determined to be covered entities. There are also ‘Health Plan Instructions’ and Q&As about using these model forms.
Remember that the Notice of Privacy Practices (NPP) is to be provided by the covered entity. A covered entity is a health plan, health care provider or healthcare clearinghouse.
An employer should only issue a NPP after working closely with its plan vendors to ensure consistency.
As a reminder, the NPP was to be updated and re-distributed by September 23, 2013.
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