What are the general rules of HIPPA? I.E. you can't display PHI (protected health information)
other than for providing what?
Cannot display PHI other than for providing health care treatment, obtaining payment, and for
day-to-day health care operations
What does HIPPA apply to?
-Health care providers (ie. pharmacies)
-Health plans
-Health care cleaning houses
What are the requirements of HIPPA?
HIPPA Requirements:
-Notifying patients of rights/uses (Notice of Privacy Practices) (NOPP) *Need to inform patients
on their rights to PHI
-ensuring pharmacy personnel compliance
-appointing privacy officer
-securing patient records (all personal must be trained in regards to privacy of HPI and maintain
confidential patient records
What content is to be included in the Notice of Privacy Practices (NOPP)?
NOPP content:
-how pharmacy intends to use and disclose information
-obligation to notify patient of a breach of unsecured PHI
-Legal duties of the pharmacy to protect confidentiality of PHI
-statement of uses and disclosures that require authorization in written document form
-statement of patient rights and how to exercise those rights (ex: how to access amendment and
accounting)
-statement that patients may complain to the pharmacy or DHHS and how to file a complain
-name of the individual to contact with privacy concerns, including telephone number
What are NOPP obligations that have to be met by the pharmacy?
NOPP obligations for the pharmacy:
*provide to patients
*good faith effort to obtain signature (6 yr retention)
*must be displayed in a clear and prominent location in the pharmacy
*must make a copy of the NOPP on request to anyone who requests a copy, whether customer or
not
*If pharmacy has a website, must make a notice and acknowledgement available on that website
If a patient refuses to sign a Notice of Privacy Practices, can you refuse treatment? what should
you do in this instance?
No, cannot refuse treatment if someone refuses to sign acknowledgement
*If patient refuses to sign, DOCUMENT the refusal***
RPh job to make good faith effort to obtain signature, if someone doesn't want to sign, make
careful note
Pharmacy can use/disclose PHI without authorization as long as it is for ____________,
__________________, or __________________
Pharmacy can use/disclose PHI without authorization as long as it is for TREATMENT,
PAYMENT, or HEALTH CARE OPERATIONS
Note: for any purposes other than these listed, would need patient authorization
What are some examples of treatment where the pharmacy can use/disclose PHI?
Treatment: Dispensing medications, counseling, maintaining profiles, consulting with patient's
other health care providers
What are some examples of Payments where pharmacy can use/disclose PHI?
Payment= submitting claims for reimbursement, determining patient eligibility and extent of
coverage, sending bills to patients
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