Q&A: Providing an NPP

Q. A local school has asked us to come in and provide flu shots to the students and staff. Do we need to ask each person who gets the shot to sign our Notice of Privacy Practices (NPP), or can the school do so on their behalf and provide the information to them?

A. If you’re providing flu vaccines to students and staff, you should have the students’ parents and the staff members sign a consent form to receive the vaccine. Briefly discuss the NPP in the consent form and make copies available at the vaccination sites. If the NPP is available on your website, provide the link in the consent form. Include a brief acknowledgment in the consent form that states the NPP has been made available.

Editor’s note: This questions was answered by Mary D. Brandt, MBA, RHIA, CHE, CHPS. Brandt is a healthcare consultant specializing in healthcare regulatory compliance and operations improvement. She is also an advisory board member for Briefings on HIPAA. This information does not constitute legal advice. Consult legal counsel for answers to specific privacy and security questions. Opinions expressed are those of the author and do not represent HCPro or ACDIS. Email your HIPAA questions to Editor Nicole Votta at nvotta@hcpro.com.