Purpose

Under the Health Insurance Portability and Accountability Act Privacy Regulations, a covered entity has the responsibility to fully comply with the standard 144.520 regarding Notice of Privacy Practices for protected health information (PHI).  As a standard, an individual has the right to adequate notice of the uses and disclosures of their PHI that may be made by Goodwill of the Great Plains.  The purpose of this notice is to inform the individual of his/her rights and Goodwill’s legal duties with respect to PHI.

The notice acknowledgement process is intended to provide a formal opportunity for the program participant to engage in discussion with Goodwill staff about privacy.  The process is intended to draw the participant’s attention to the importance of the notice.

Policy

The notice must contain a statement of the individual’s rights with respect to PHI and a brief description of how the individual may exercise these rights.  The Notice of Privacy Practice describes situations in which the participant’s information may be released without the participant’s consent, and describe the participant’s rights concerning his/her health information.  These rights include the following:

  • The right to request restrictions on certain uses and disclosures of PHI, including a statement that the covered entity is not required to agree to a requested restriction.
  • The right to receive confidential communication of PHI.
  • The right to inspect and copy PHI.
  • The right to amend PHI.
  • The right to receive an accounting of PHI.
  • The right of an individual, including an individual who has agreed to receive the notice electronically, to obtain a paper copy of the notice from Goodwill upon request.

Procedures

  • The Notice of Privacy Practices must be made available to all program participants and explained by Goodwill staff at the time of the participant’s enrollment in the program.  Any questions on the participant’s behalf concerning the notice must be promptly addressed by Goodwill staff.
  • If an individual refuses to sign or otherwise fails to provide an acknowledgement, Goodwill of the Great Plains is required to document its good faith efforts to obtain the acknowledgement and the reason why the acknowledgement was not obtained.
  • The Good Faith Efforts to Obtain Acknowledgement of Notice of Privacy Form will be used by the appropriate Goodwill staff when a program participant refuses to sign the Notice of Privacy Practices.  The purpose of the Good Faith Efforts to Obtain Acknowledgement of Notice of Privacy Form is to document Goodwill’s due diligence.
  • Notice of Privacy Practices Procedures
  • The Good Faith Effort to Obtain Acknowledgement of Notice of Privacy Form includes the following elements:
    • Name of the participant.
    • Social Security number.
    • Statement of due diligence by Goodwill staff.
    • Account of first attempt to obtain acknowledgement.  It contains a detailed explanation of reason for refusal to sign, date of contact, time of contact and type of contact.
    • Account of Second Attempt to obtain acknowledgement.  It contains a detailed explanation of refusal to sign, date of contact, time of contact and type of contact.
  • The “Good Faith Efforts to Obtain Acknowledgement of Notice of Privacy From” must be included in the participant’s file and attached to the Notice of Privacy Practices.  In addition, a copy of this form must be sent to the Chief Privacy Officer for record keeping.  Failure by Goodwill to obtain an individual’s acknowledgement, assuming that Goodwill documented is good faith effort, is not a violation of the Privacy Rule.
  • Goodwill of the Great Plains Rehabilitation Facilities must promptly revise and distribute its notice whenever there is a material change to the uses and disclosures, the individual’s rights, Goodwill’s legal duties or other privacy practices stated in the notice.  Except when required by law, a material change to any term of the notice may not be implemented prior to the effective date of the notice in which such material change is reflected.

If you have questions about this notice please contact our chief privacy officer:

Program Manager
3100 West 4th Street
Sioux City, Iowa 51103-3032
(712) 258-4511