Model HIPAA Notices of Privacy Practices Come Out Late, Distribution Deadline Today

Just a few short days prior to today’s deadline to distribute revised Notices of Privacy Practices under the Health Insurance Portability and Accountability Act (HIPAA), the U.S. Department of Health and Human Services (HHS) issued model notices for health care providers and health care plans.  

The HIPAA Omnibus Final Rule (Final Rule) requires covered entities, which includes health care plans, to distribute revised Notices of Privacy Practices that comply with the additional notice requirements established by the Final Rule. Although the HHS model notices are available in a variety of design formats (booklet, layered notice with summary content, full-page presentation, and text only), the underlying substance of the notices is consistent. Covered entities may, but are not required, to use the model notices. If model notices are used, they need to be customized to reflect the plan’s privacy practices and administration. The model notices are available here along with questions and instructions for entering plan information into each of the model notices.

Please see our April Bulletin for a more thorough explanation of the required revisions to the Notice of Privacy Practices and how they must be distributed.