Procedures - Notice of Privacy Practices and Policy Change Management

	LOS ANGELES COUNTY DEPARTMENT OF MENTAL HEALTH
	Policy 503.01 Notice of Privacy Practices and Policy Change Management
	PROCEDURES

Procedures for Revising or Amending Privacy Practices Addressed in the Notice of Privacy Practices (NPP)

To ensure compliance with applicable federal and state privacy laws, including the Health Insurance Portability and Accountability Act (HIPAA), DMH shall follow the procedures outlined below when revising or amending privacy practices addressed in the NPP:
1. DMH Privacy Officer shall:
  • Collaborate with the Chief Executive Office (CEO) HIPAA Compliance Officer and Privacy Officers from the Department of Health Services (DHS) and the Department of Public Health (DPH) to ensure consistency in language and alignment across Los Angeles County Health Agencies, where applicable.
  • Conduct a regulatory review to ensure proposed revisions comply with 45 C.F.R. § 164.520(b)(3) and § 164.520(c), and applicable provisions governing the content and distribution of the NPP.
2. DMH Privacy Officer shall:
  • Ensure the revised NPP clearly describes updated uses and disclosures of Protected Health Information (PHI), individual rights and the Department's legal responsibilities.
  • Submit proposed revisions/amendments for review and approval by the CEO prior to implementation.
3. Amendments to privacy practices addressed in the NPP must not be implemented prior to the effective date of the revised notice.
  
  4. The effective date shall be clearly indicated on the revised NPP and shall be distributed and posted in accordance with HIPAA and State requirements.