PROMEDICA PHYSICIAN GROUP
HIPAA POLICY

1. Timing of Provision. The Notice of Privacy Practices must be made available, distributed, and the appropriate signage posted at each PPG office in accordance with this policy on or after April 14, 2003.
   
   
2. Availability to the Public. A copy of the Notice of Privacy Practices must be made available on request to any person who requests it in each separate building where patients receive treatment. A copy of this Notice can be requested from the contact person listed in Section VII of the Privacy Notice, and can be viewed on the PPG web site at www.ppgdocs.org.
   
   Individuals have the right to get a copy of this Notice by e-mail and to request a paper copy. Individuals that cannot read may request that an employee read the Notice to the individual upon appointment.
   
   
3. Distribution to Patients. All patients will be provided a copy of the Notice of Privacy Practices no later than the date of their first in-office treatment encounter on or after April 14, 2003. PPG will make a good faith effort to obtain written acknowledgment of receipt of the Notice by having the patient or legally authorized representative initial the Acknowledgment of Notice of Privacy Practices form. The Notice will remain valid until such time that the Notice has been revised.
   
   In accordance with the PPG Acknowledgment of Notice of Privacy Practices Policy, prior to the first in-office treatment at PPG, patients must be given a Notice of Privacy Practices and sign the Acknowledgment of Notice of Privacy Practices form. PPG will perform this function annually upon presentation for treatment.
   
   In an emergency treatment situation, the patient will be provided a Notice of Privacy Practices as soon as reasonably practicable after the delivery of the treatment and will be asked to acknowledge receipt of the Notice.
   
   If acknowledgment of the Notice cannot be obtained, the good faith efforts to obtain the acknowledgment and the reasons why the acknowledgment was not obtained must be documented on the PPG Acknowledgment of Notice of Privacy Practices form and retained in the medical record.
   
   When the Notice of Privacy Practices has been given to, or acknowledgment received from, the patient, the specific department or office handling it must document it in the Off-Bill comments in Medic. It should be made easily identifiable for all who will access the Off-Bill comments. All entries regarding HIPAA specific information will be in Off-Bill comments as, for example: HIPAA-NPP given, HIPAA-restrictions, etc. This may be achieved by using the Medic key codes.
   
   
4. Inmates. When the patient is an inmate in a correctional facility, provision of the Notice and the attempt to obtain acknowledgment of receipt of the Notice is not required.
   
   
5. Signage. PPG is required to post signage regarding the Notice of Privacy Practices in all buildings where patients receive treatment.
   
   
6. E-Mail Delivery of Notice. The Notice of Privacy Practices may be provided to a patient by e-mail, if the patient agrees to electronic notice. An electronic acknowledgment from the patient via e-mail will be considered written acknowledgment of receipt. Such e-mail message will be printed and retained in the medical record, as well as documented in the Off-Bill comments in Medic. If it is known that the e-mail transmission failed, a paper copy of the Notice must be provided to the patient.
   
   
7. Web Site Posting. A copy of the most recent Notice of Privacy Practices will be posted prominently on our web site for PPG.
   
   
8. Revisions to the Notice. PPG reserves the right to change this Notice and privacy policies at any time. Any changes will apply to all protected health information. If any changes are made to PPG privacy policies, the Privacy Notice will be changed, if applicable, and a new Notice will be posted on the web.
   
   
9. Record Retention. The PPG Privacy Officer shall retain all versions of the Notice of Privacy Practices, i.e., the original and all subsequent revised Notices. Copies of the Notices shall be retained for six years.