chapter  8
Writing Effective Privacy Policies
Pages 16

CEs are allowed to use “layered” notices to implement the HIPAA Privacy Rule notice requirements. When a layered notice is used, all of the elements listed in Section 8.3.2 must still be present within the notice. For example, your organization can choose to create a short notice that briey summarizes individuals’ rights regarding their PHI, but then also provide the longer, more detailed, full version of the notice as an attachment or addendum to the brief summary. e brief summary is in eect similar to an executive summary, and the full details provide elaboration and expand on the summary points. By using a layered approach you may get more individuals to read the summary page, realize the importance of their rights regarding their PHI, and then continue to read on to discover the details of their full rights.