Privacy (HIPAA) Policy

indivctr

Where do most of you put your privacy (HIPAA) policy? As part of personnel policies?

skyrocket

Based on conversations with our benefits attorney, the following was suggested for "distribution" to current employees:

No special or separate mailings are required to satisfy the notice distribution requirements. The Privacy Rule allows employers discretion in this area. An employer may distribute the notice through the mail or as part of another mailing to the individual. In addition, it can be provided by an e-mail that includes additional information. No separate e-mail is required. The notice may also be distributed on an employer’s internal website provided that employees are advised to review the information there and the employee has reasonable access to a computer to review the information.

As to distribution to newly hired employees, we would include this document in the Benefit Enrollment packet - along with COBRA and other required notices.

Does this help?

indivctr

Yes, it does partially, thank you. We have written it up as a policy and are not sure as to whether it is actually a personnel policy (pertains to staff) or should go into another section of policies, such as agency wide policies.
thank you