Avoiding Liability Bulletin – December 2005
… Among the many requirements of HIPAA, perhaps the most important one pertains to the Notice of Privacy Practices, which “covered providers” who have a direct treatment relationship with the patient must give to their patients “no later than the date of the first service delivery.” Essentially, the Notice should be given to the patient prior to the commencement of treatment. If the first service delivery is electronic (e.g., Internet therapy/telemedicine), the covered provider must furnish electronic notice automatically and contemporaneously in response to the individual’s first request for service. In addition, if a covered provider maintains a website, the Notice must be available electronically through the website.
