HIPAA Notice of Privacy Practices for Occupational Therapists

Occupational therapists in private practice who bill insurance or submit electronic claims are HIPAA covered entities. You need a compliant Notice of Privacy Practices — updated to the HHS February 2026 model — provided to each client at first contact and posted on your website.

When does an OT need their own NPP?

Occupational therapists can work in multiple settings simultaneously — hospitals, schools, outpatient clinics, and private practice. The NPP obligation attaches to each covered entity, not each individual clinician. If you:

• Operate an independent OT practice (even part-time)
• Submit your own electronic claims or use a billing service
• Accept Medicare, Medicaid, or private insurance in your own name

— then your independent practice has its own NPP obligation separate from any employing organization.

What your OT NPP must include

• Permitted uses and disclosures for treatment, payment, and healthcare operations
• Patient rights: access, amendment, restriction requests, accounting of disclosures, confidential communications
• Complaint process with HHS OCR contact information
• Privacy Officer contact information (for a solo OT, this is typically you)
• Effective date and supersede date if replacing a prior version

Distribution requirements

• Provide to each new client at first service and request written acknowledgment
• Post the full NPP text on your public website
• Display at your office or clinical location
• Redistribute to existing clients and update website when material changes occur

Frequently Asked Questions