Notice of Privacy Practices (NPP) under HIPAA

The Notice of Privacy Practices (NPP) is a cornerstone of HIPAA compliance, ensuring that individuals understand how their health information is used and protected. This document serves as a transparent guide, outlining patients’ rights and the responsibilities of healthcare providers and health plans when it comes to personal health information.

HIPAA requires covered entities to share the NPP with patients in a way that is easy to understand and accessible to everyone. This means using plain language, highlighting important content, and following strict posting requirements to keep patients informed at every point of care.

The NPP isn’t just a formality—it’s a legal obligation and a valuable educational tool for patients. It covers a range of critical topics, from the specific rights patients have regarding their information, to how organizations handle updates, effective dates, acknowledgment of notice, and even electronic delivery options for greater convenience.

In this article, we’ll break down the essential elements of a HIPAA NPP and provide practical advice for ensuring your notice meets all regulatory standards and is truly accessible to your community. Understanding these practices empowers both healthcare organizations and patients, making privacy a shared priority from the very first interaction.

What is in a HIPAA NPP

What is in a HIPAA NPP

The content of a Notice of Privacy Practices (NPP) is carefully structured to provide individuals with a clear, comprehensive understanding of how their protected health information (PHI) is handled. Every NPP must be written in plain language, avoiding legal jargon that could confuse patients. This requirement ensures that the information is accessible to everyone, regardless of their background or reading level.

Core elements typically included in the NPP content are:

• Uses and Disclosures: The NPP describes how a covered entity may use and disclose PHI for treatment, payment, and healthcare operations, as well as other allowed uses and disclosures without individual authorization.
• Individual Rights: Patients are informed of their rights concerning their health information, such as the right to access, inspect, and obtain a copy of their records, request amendments, and receive an accounting of disclosures.
• Legal Duties: The notice clearly states the covered entity’s legal obligation to protect PHI and to notify individuals in case of a breach of unsecured information.
• Contact Information: Details are provided for whom individuals can contact for more information or to file a complaint about privacy practices.
• Effective Date: The NPP must include the date when the notice becomes effective, helping individuals know when the policies described came into force.

Posting Requirements and Accessibility: Covered entities must prominently display the NPP in their physical locations—typically in waiting rooms or reception areas—and post it on any website they maintain that offers information about customer services or benefits. This ensures accessibility for everyone who interacts with the organization.

Acknowledgment of Receipt: For direct treatment providers, there’s a requirement to make a good faith effort to obtain a written acknowledgment from individuals, confirming they received the NPP. If acknowledgment cannot be obtained, the provider must document the attempt and the reason for not obtaining it. This step is vital for compliance and transparency.

Electronic Notice Options: In today’s digital world, the NPP can also be delivered electronically, provided the individual consents. The electronic notice must be as accessible and clear as the paper version, ensuring no one is left uninformed due to the format.

We know that privacy can feel overwhelming, but the NPP is designed to empower you with knowledge and control over your health information. By ensuring the NPP is clear, accessible, and regularly updated, healthcare organizations not only meet legal requirements but also build trust with the individuals they serve.

NPP document standards

NPP document standards are critical to making sure every patient’s rights and information are communicated clearly, comprehensively, and accessibly. To comply with HIPAA, covered entities must pay close attention to both the content and the presentation of their Notice of Privacy Practices (NPP). Let’s break down the essential standards every NPP must meet:

• Plain Language: The NPP must be written in clear, straightforward language that can be understood by the average person. Avoiding legal jargon is key—patients shouldn’t need a law degree to know their rights. This improves engagement and fosters trust.
• Comprehensive NPP Content: The document must explicitly outline all necessary details, including:
  • A description of how protected health information (PHI) may be used and disclosed.
  • Individual rights regarding their PHI and how to exercise those rights.
  • The covered entity’s duties to protect patient information.
  • Procedures for filing complaints and contact details for privacy concerns.
• Posting Requirements: The NPP should be posted prominently in all physical locations where patients receive care, such as waiting rooms or reception areas. Additionally, it must be available on any entity’s website that provides information about services or benefits.
• Acknowledgment of Receipt: For healthcare providers, there’s an obligation to make a good faith effort to obtain written acknowledgment from patients confirming they received the NPP. If acknowledgment isn’t possible, the attempt and reason must be documented.
• Effective Date: Every NPP must display a clear effective date, signaling the start of the policies described. When changes are made, an updated effective date is required, ensuring patients always know which version applies.
• Accessibility: The NPP must be accessible to all individuals, including those with disabilities and those with limited English proficiency. This may mean providing versions in other languages, large print, Braille, or accessible digital formats.
• Electronic Notice: If a covered entity interacts with patients electronically, it can provide the NPP in digital form—such as via email or a secure website—provided the patient consents. The electronic version must be just as complete and clear as a printed version.

By meeting these document standards, we don’t just check a compliance box—we empower patients to understand and control their health information. These requirements ensure every person, regardless of their background or abilities, can engage confidently with their healthcare providers and plans. If you’re responsible for preparing or updating an NPP, always review these standards to guarantee clarity, transparency, and accessibility for all.

What rights does a HIPAA NPP outline

The Notice of Privacy Practices (NPP) clearly spells out the rights that individuals hold over their protected health information (PHI) under HIPAA. Understanding these rights is crucial for patients and clients, as it empowers them to make informed decisions about their health information and ensures transparency in how organizations handle sensitive data.

Here’s what the NPP content typically outlines regarding patient rights:

• Right to Access PHI: Individuals can request and receive copies of their health information maintained by a covered entity. This includes the right to inspect physical and electronic records, with some exceptions for certain types of notes or information. The NPP must explain the process for making such a request and any associated fees.
• Right to Request Amendments: If someone believes their health information is incorrect or incomplete, the NPP explains how they can ask for a correction. The covered entity must respond and, if denying the request, provide a clear reason in plain language.
• Right to an Accounting of Disclosures: The NPP details how individuals can request a list of certain disclosures of their PHI made by the covered entity over a specified period, not including disclosures for treatment, payment, or healthcare operations.
• Right to Request Restrictions: The notice informs individuals about their ability to ask for limits on how their PHI is used or disclosed for treatment, payment, or operations. While the covered entity isn’t always required to agree, some restrictions (such as for services paid for out-of-pocket) must be honored.
• Right to Request Confidential Communications: Individuals have the right to request that communications about their health information are sent by alternative means or to alternative locations. For example, a patient might ask for appointment reminders to be sent to a work email instead of a home address, increasing privacy and accessibility.
• Right to File a Complaint: The NPP must clearly describe how to file a complaint with the covered entity or with the Department of Health and Human Services if an individual believes their privacy rights have been violated. Contact details and a simple, accessible process are expected in the notice.
• Right to Receive a Paper or Electronic Copy of the NPP: Even if the NPP was provided electronically, individuals have the right to request and receive a paper copy at any time, supporting both accessibility and clarity.

The NPP uses plain language to ensure these rights are easy to understand for everyone, regardless of background or ability. Posting requirements mean the NPP must be available on the organization’s website, easily accessible in physical locations, and provided electronically when appropriate. The acknowledgment process serves as a record that individuals are informed of their rights, while the effective date ensures everyone knows when the current practices began.

By making this information accessible, clear, and actionable, the NPP helps us all protect our personal health information and exercise our rights with confidence.

Distribution and posting rules

Understanding exactly how and when to distribute and post the Notice of Privacy Practices (NPP) is essential for HIPAA compliance. The distribution and posting rules ensure that everyone interacting with a covered entity has timely, convenient access to clear information about their privacy rights. Let’s break down what’s required and how you can meet these standards.

Distribution of the NPP must be timely and proactive. Covered entities are required to provide the NPP to individuals as early as possible in their relationship. For health plans, this typically means at the time of enrollment. For healthcare providers with direct treatment relationships, it’s no later than the first service delivery—think of the first appointment, whether in-person, by phone, or even electronically.

• For health plans: New enrollees must receive the NPP at enrollment. If there are material changes to the NPP content, updated notices must go to current members within 60 days. Additionally, health plans need to remind members of the NPP’s availability, and how to obtain it, at least once every three years.
• For direct treatment providers: The NPP must be provided to patients at their first visit (or as soon as possible after an emergency). Providers must make a good faith effort to obtain written acknowledgment of receipt, whether on paper or digitally. If acknowledgment isn’t possible, the provider should document the attempt and the reason it wasn’t obtained.

Posting requirements play a huge role in accessibility and transparency. Covered entities must prominently post the current NPP at any physical location where care is delivered or services are offered. This usually means placing the notice in a waiting area, on a lobby wall, or at the reception desk—somewhere everyone can see it without having to ask.

• The full NPP should be available for individuals to take with them—providing printed copies on request is a must.
• If the organization maintains a website that describes its services or benefits, the NPP must be posted there prominently. Individuals should not have to search extensively; a clear link on the homepage is best practice.

Electronic notice brings added convenience and reach. If an individual agrees, the NPP can be delivered electronically—by email or through a secure patient portal. For telehealth or other digital-first services, sending the NPP automatically for the first service request is required, with reasonable efforts to get a return receipt or acknowledgment.

Effective date and updates are critical for compliance. Every NPP must clearly state its effective date so individuals know when the information applies. If there are changes to privacy practices, the revised NPP must be distributed—and posted—without delay. This ensures everyone knows their most up-to-date rights and how their information is handled.

Using plain language and ensuring accessibility are non-negotiable. The NPP should be easy to understand, avoiding legal jargon or complex terms. It’s also important to provide alternative formats if needed, such as large print or translations, so everyone—regardless of ability or language—can access their privacy rights.

By following these NPP distribution and posting rules, we build transparency and trust with those we serve. Staying proactive, documenting our efforts, and making the notice easy to find and understand are not just legal requirements—they’re the foundation of respectful, patient-centered care.

Acknowledgment of receipt

Acknowledgment of receipt is a crucial step in the Notice of Privacy Practices (NPP) process under HIPAA, as it demonstrates that individuals have been informed about how their health information may be used and disclosed. Covered entities—such as healthcare providers with direct treatment relationships—are required to make a good faith effort to obtain a written acknowledgment from patients that they have received the NPP. This acknowledgment is typically obtained at the time of first service delivery, and can be provided in paper or electronic format, depending on the patient’s preference.

Here's why acknowledgment matters:

• Proof of compliance: Collecting an acknowledgment serves as tangible evidence that the covered entity has fulfilled its obligation to inform patients about their privacy rights and the provider’s practices, as mandated by HIPAA.
• Fosters patient trust: When patients are asked to acknowledge receipt, it encourages them to review the NPP content, ask questions, and become more aware of their rights.
• Streamlines documentation: Maintaining records of signed acknowledgments (either digital or physical) helps organizations stay audit-ready and demonstrates their ongoing HIPAA compliance.

If a patient is unable or unwilling to sign the acknowledgment, the provider isn’t off the hook. The covered entity must document its efforts to obtain the acknowledgment and note the reason it was not received. Examples might include a patient declining to sign, language barriers, or emergency situations where obtaining a signature isn’t immediately possible.

Accessibility and flexibility are built into the HIPAA rules to accommodate various situations:

• If services are provided electronically (such as via telehealth or email), an electronic notice is sent automatically, and the provider should seek an electronic acknowledgment—like a return email or digital signature.
• For in-person visits, signatures may be captured on paper forms or via electronic tablets at check-in.
• In emergency care scenarios, the NPP and acknowledgment process can be completed as soon as reasonably practicable after the emergency has subsided.

It’s important to remember that acknowledgment of receipt does not mean a patient agrees with the NPP's terms—it simply confirms that they have been provided with the information. Patients should always have the opportunity to review the NPP in plain language and in a format that is accessible, whether in print or through electronic notice. This process is designed not just to check a box, but to ensure transparency and empower individuals to exercise their privacy rights.

Updates and effective dates

Updates and effective dates play a crucial role in maintaining the integrity and relevance of your Notice of Privacy Practices (NPP). HIPAA mandates that every NPP must clearly show its effective date—this is the exact date the notice’s privacy practices take effect. By doing so, individuals always know which version of the notice is governing their protected health information (PHI) at any given time.

Whenever there are material changes to the privacy practices described in the NPP, covered entities are required to promptly update the content. These changes may result from new laws, technology updates, or revised organizational policies impacting how PHI is used or disclosed. It’s not enough to simply make the updates internally—the revised NPP must be distributed to affected individuals and posted wherever the notice is required, ensuring ongoing transparency.

• The updated NPP must include the new effective date. This ensures patients and members are always aware of which rules apply to their information.
• For health plans, a revised notice must be provided to all currently enrolled individuals within 60 days of a material change. Additionally, plans must remind individuals of the availability of the NPP at least once every three years.
• Health care providers must make the latest version available at their physical locations and on their websites. This includes posting it in a clear and prominent area and offering copies upon request.
• Electronic notice requirements remain in effect as well. If individuals have agreed to receive the NPP electronically, ensure the updated notice is sent via the agreed-upon channel and is accessible in a format that meets accessibility standards.

Staying proactive about NPP updates is not just about compliance—it’s about building trust with your patients and members. By providing timely and understandable updates, using plain language, and ensuring easy access to the NPP, we empower individuals to make informed decisions about their health information and foster a culture of openness and respect.

Electronic delivery

Electronic delivery of the Notice of Privacy Practices (NPP) is not only permitted under HIPAA, but it’s also a modern approach that aligns with how many of us prefer to receive important information today. As healthcare increasingly moves online, offering the NPP electronically can enhance both accessibility and convenience for patients, while ensuring that all legal requirements are met.

HIPAA regulations allow covered entities to provide the NPP electronically, as long as certain conditions are satisfied:

• Patient consent is required. Before sending the NPP electronically, the individual must agree to receive it in this manner. This consent can be obtained in writing or electronically.
• The electronic NPP must be as easy to access as a paper copy. Patients should be able to download, save, or print the notice without barriers. This means using formats like PDFs or accessible web pages that don’t require proprietary software or complex steps.
• Accessibility is a priority. The electronic notice must be provided in a format that meets accessibility standards, so individuals with disabilities can access and understand the content. This includes using plain language, readable fonts, and compatibility with screen readers.
• The NPP must remain available. Covered entities must ensure the most current version of the NPP is posted in a clear and prominent manner on their website, if they maintain one. The posting requirements apply whether the site is for a health plan, medical practice, or hospital.

For providers offering digital health services or communicating primarily online, electronic notice can be integrated seamlessly into patient onboarding or appointment scheduling workflows. For instance, after a patient books an appointment online, the NPP can be delivered via a secure email or patient portal, with a request for the individual’s acknowledgment (such as an e-signature or electronic checkbox).

If a patient prefers a paper copy after receiving the NPP electronically, the covered entity must still provide one upon request, at no charge. This ensures that everyone has equal access to the information, regardless of their preferred communication method or digital literacy level.

As a best practice, always document the method of delivery and the patient’s acknowledgment, whether it’s electronic or paper-based. This step is crucial for demonstrating compliance with HIPAA and for maintaining trust with patients regarding their privacy rights and your organization’s legal duties.

In summary, the Notice of Privacy Practices (NPP) stands as a vital tool for building trust between patients and healthcare organizations. By clearly outlining how protected health information is handled, the NPP empowers individuals to make informed decisions about their privacy and encourages open communication with their providers.

To meet HIPAA's requirements, covered entities must ensure their NPP content is written in plain language, includes all necessary details—like the effective date—and is easily accessible to everyone. Posting requirements mean the notice should be available in physical locations, on websites, and offered in electronic formats if patients prefer.

Making a good faith effort to obtain patient acknowledgment of receipt underscores the importance of transparency and patient engagement. Remember, keeping the NPP current and promptly updating it when privacy practices change is not just a legal obligation—it's a sign of respect for patients’ rights.

Ultimately, a well-crafted, accessible, and regularly updated Notice of Privacy Practices helps foster confidence and compliance in every healthcare interaction. By prioritizing clarity, accessibility, and patient acknowledgment, we can ensure everyone understands their privacy rights and how their health information is protected.

FAQs

Is an NPP still required for telehealth?

Yes, a Notice of Privacy Practices (NPP) is still required for telehealth services. The HIPAA Privacy Rule applies to all covered entities, regardless of whether care is delivered in person or via telehealth. This means that the same NPP content, posting requirements, and acknowledgment procedures must be followed when providing virtual care as with traditional, in-person services.

When delivering telehealth, providers must ensure patients receive the NPP, understand its effective date, and that it’s presented in plain language for accessibility. If the initial interaction with the patient occurs electronically—such as through a telehealth platform or email—the provider can deliver the NPP electronically, provided it is readily accessible and the patient has consented to receive information in this way.

Providers must also make a good faith effort to obtain the patient’s acknowledgment of receipt, even in a telehealth setting. This acknowledgment can be electronic, such as a digital signature or a return email, to confirm the patient has received and reviewed the NPP. Ensuring accessibility—by making the NPP available on your website and in formats accessible to people with disabilities—is also essential for compliance.

In short, telehealth doesn’t change the fundamental requirements for NPP delivery and acknowledgment. It simply means we need to adapt our processes, using digital tools to make sure patients are informed about their privacy rights and how their health information will be used, no matter where or how they receive care.

Do patients need to sign an acknowledgment?

Patients are generally asked to sign an acknowledgment when they receive a Notice of Privacy Practices (NPP). This acknowledgment simply confirms that the patient has received the NPP, which explains how their protected health information (PHI) may be used and disclosed, as well as their rights under HIPAA.

For direct treatment providers, making a good faith effort to obtain this acknowledgment is a requirement, whether it’s a handwritten or electronic signature. If a patient chooses not to sign or if it’s not feasible to obtain a signature, the provider must document their efforts and note the reason why the acknowledgment wasn’t obtained.

It’s important to remember that signing the acknowledgment does not mean the patient agrees with the NPP content—it simply verifies receipt. The focus is on transparency and ensuring patients have access to clear, plain language notices about their privacy rights. For accessibility, providers may offer the NPP electronically with the patient’s consent, and are encouraged to make the process as straightforward as possible.

In summary, while patient acknowledgment is requested and documented, care or services are not denied if a patient declines to sign. The priority is compliance with posting requirements and making privacy information easily available and understandable to everyone.

How often should we update the NPP?

The Notice of Privacy Practices (NPP) should be updated whenever there are material changes to your privacy practices, policies, or procedures regarding protected health information (PHI). This means that if you revise how you use or disclose PHI, update individuals' rights, or change your legal duties, you must promptly update your NPP content to reflect those changes.

In addition to updates triggered by changes in privacy practices, there are ongoing posting requirements to keep in mind. Health plans must notify individuals of the availability of the updated NPP and how to obtain it at least once every three years, even if no changes have occurred. For healthcare providers, it's crucial to always have the latest version posted prominently in your facility and on your website, ensuring accessibility for everyone, including those who require electronic notice or plain language formats.

Remember to always include a new effective date on your revised NPP. Make sure to distribute the updated notice to new patients or plan members and to obtain acknowledgment of receipt whenever possible. Staying proactive with these updates and maintaining accessibility helps build trust and keeps you compliant with HIPAA requirements.

Must the NPP be multilingual?

The Notice of Privacy Practices (NPP) is required by HIPAA to be written in plain language to ensure that individuals understand their privacy rights and how their protected health information (PHI) may be used or disclosed. However, HIPAA does not specifically mandate that the NPP be provided in multiple languages. The core requirement is clarity and accessibility for the audience served.

That said, accessibility is a key consideration for covered entities. If you regularly serve individuals with limited English proficiency, best practices—and in some cases, state or local laws—may require you to offer the NPP in the primary languages spoken by your patient or member population. This approach not only demonstrates a commitment to inclusivity and good patient care, but it also helps ensure that everyone fully understands their rights and your privacy practices.

Posting requirements also encourage making the NPP accessible via prominent display at your facility and on your website. If you offer electronic notice, providing translated versions or language assistance can further increase accessibility. While not strictly required by federal law, offering a multilingual NPP is strongly recommended whenever it will help your community better understand their rights and your responsibilities.