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Notice of Privacy Practices

Drexel University Clinical Covered Entities
Privacy Program Policies and Procedures

Policy Title: Notice of Privacy Practices
Policy Number: IM-15
Effective Date: April 14, 2003; September 23, 2013
Last Revision: September 1, 2017
Responsible Officer: Vice President, Chief Compliance, Privacy and Internal Audit Officer

Table of Contents

Applicability

This policy applies to all Covered Entities within Drexel University.

Covered entities are defined in the HIPAA rules as (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically transmit any health information in connection with transactions for which HHS has adopted standards.

I. Policy

Drexel University (DU) requires that each patient be provided the opportunity to review the laminated "Notice of Privacy Practices" (NPP) in the office waiting area and to acknowledge they have reviewed the document by signing the appropriate block on the registration form. The DU website offers Spanish and Mandarin Chinese versions of the NPP, which may be printed by staff or by the patient if needed. Note that Philadelphia area Hahnemann/American Academic Health System (AAHS) inpatients are provided a Joint Notice of Privacy Practices (JNPP) to give notice to inpatients that Hahnemann/AAHS and DU employees may provide inpatient services.

The patient is provided a "paper" copy upon request.

II. Purpose

This Policy meets the requirement to inform patients of the DU Privacy Practices and to record the patient review with a signature on the registration form.

III. Procedure

  1. All patients, at their first visit, will be given the laminated "Notice of Privacy Practices" to review in the office waiting area.
  2. Patients, at their first visit, will be asked to sign the registration form block noting that the Privacy Notice has been received.
  3. The Office Manager will note "REFUSED", enter the date and initial in the space for the patient signature on the registration form if the patient refuses to sign.
  4. If the patient is unable to review and/or sign the form, a designated guardian or surrogate may sign.
  5. A parent may sign for a child under 18 years of age who cannot consent to their own health care under law.
  6. The office must provide a "paper" non-laminated copy of the "Notice of Privacy Practices" if the patient requests a copy.
  7. Treatment cannot be denied if the patient refuses to sign that they have received the notice.

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