SCOPE OF PRACTICE:
SMART Health and Wellness Center

PURPOSE:
The Privacy Rules provide that a patient, or his/her personal representative, has a right to receive a notice of the covered entity’s privacy practices (“Notice of Privacy Practices or NPP”). The purpose of this policy is to describe the clinic’s distribution, posting, and revising of that NPP.

POLICY:
It is the policy of SMARTFAITHworks Health and Wellness Clinic to:

1. Provide a copy of the NPP to all patients, or their representatives, no later than the date of their first date of service, or as soon as possible after an emergency situation;
2. Post a copy of the NPP in a clear and prominent location, or in multiple locations, in the clinic where it is reasonable to expect patients seeking care and services to be able to see and read the NPP;
3. Post the NPP to the clinic website;
4. Have copies of the NPP available for any patient who requests a copy;
5. Revise the NPP whenever a material change is required regarding PHI uses or disclosures, patients’ rights, the clinic’s privacy duties/obligations, or other privacy practices; and
   1. to distribute the revised NPP to all new patients at their first visit following the revision;
   2. to place the revised NPP on the clinic website; and
   3. to post at the clinic and to make available for any patient who requests a copy.

PROCEDURE:

1. An individual has a right to adequate notice of the uses and disclosures of PHI that may be made by the clinic, and of the individual’s rights and clinic’s responsibilities with respect to PHI. The clinic is required to provide a notice of privacy practices document to all patients, as well as other individuals requesting a copy. The front office staff will be responsible for distributing a copy of the notice to all patients.
2. The clinic will:
   1. Provide the notice no later than the date of the first service delivery, including service delivered electronically to such individual.
   2. Make a good faith effort to obtain an initial written acknowledgement of the receipt of notice from the patient on the Notice of Privacy Practices Acknowledgement Form.
   3. Have the notice available at the clinic for individuals to take with them.
   4. Post the notice in a clear and prominent location where it is reasonable to expect individuals seeking care from the clinic to be able to read the notice.
   5. Whenever the notice is revised, make the notice available upon request on or after the effective date of the revision.
3. Exceptions
   1. If the clinic is treating patient during an emergency, the clinic does not have to provide a notice at the time of first service delivery. The clinic may delay the requirement for provision of notice and good faith effort of written acknowledgment.
   2. A prisoner receiving medical attention from the clinic does not have a right to receive a copy of the notice of privacy practices. However, the clinic must still protect prisoners’ PHI.
4. Documentation of Notice
   1. The clinic must document compliance with the notice requirements by retaining copies of the notices issued by the clinic.
   2. Front office personnel will be responsible for distributing the notice to all patients and documenting the receipt of the Notice of Privacy Practices Acknowledgement form. (See Patient Index System).
   3. The original Notice of Privacy Practices Acknowledgement form will be filed in the patient’s medical record.
   4. If a written acknowledgment was not obtained from the patient, the clinic must document the reason for the failure to obtain the
5. Revision to the Notice – The clinic must promptly revise and make available its notice whenever there is a material change to the uses or disclosures, the individual’s rights, clinic’s legal duties, or other privacy practices stated in the notice. Except when required by law, a material change to any term of the notice may not be implemented prior to the effective date of the notice in which such material change is reflected.