Designating a HIPAA Privacy Official and Contact Person: A Requirement for Your Practice (§ 164.530(a))

Under HIPAA, every covered entity is required to designate a Privacy Official responsible for developing and implementing privacy policies and procedures. Additionally, practices must name a contact person to receive complaints and answer questions about HIPAA. This requirement, found in § 164.530(a), is more than a formality, it ensures someone is clearly accountable for maintaining privacy standards. This guide explains how small practices can meet this obligation, what qualifications are necessary, and how to avoid compliance failures. A real-life case example and practical checklist are included.

HIPAA compliance isn’t just about forms and encryption. It’s about accountability.

Many small medical and dental practices believe that using HIPAA-compliant forms, encrypting emails, or posting a Notice of Privacy Practices is enough to stay compliant. But HIPAA is not a checklist, it’s a framework built around assigning real responsibility to real people.

One of the most overlooked requirements of the HIPAA Privacy Rule is found in Section 164.530(a). This provision mandates that every covered entity, regardless of size, must formally designate:

• A HIPAA Privacy Official, responsible for developing and implementing privacy policies and procedures

• A Contact Person, who is available to respond to patient inquiries and concerns about their privacy rights

These roles cannot be left vague or assumed. They must be documented, actively maintained, and clearly communicated to both staff and patients. Without them, your practice operates without accountability, and that opens the door to compliance failures, patient complaints, and federal enforcement.

Failing to assign and document these roles is not just a technical error, it signals to regulators that your practice may lack the internal structure to protect health information (PHI). The result can be serious: investigations by the Office for Civil Rights (OCR), mandatory corrective action plans, and financial penalties.

This article breaks down exactly what the law requires, how to comply efficiently even in a small office setting, and the most common missteps that lead to violations. Whether you’re new to HIPAA or conducting a compliance refresh, this guide will help you build a foundation of privacy accountability that protects both your patients and your practice.

What § 164.530(a) Requires

This regulation mandates that a covered entity:

• “Designate a privacy official who is responsible for the development and implementation of the policies and procedures of the entity.”

• “Designate a contact person or office who is responsible for receiving complaints under this subpart and who is able to provide further information about matters covered by the notice.”

These roles may be separate or combined, especially in small practices where staffing is limited.

This person should:

• Understand HIPAA requirements

• Have authority to enforce privacy practices

• Be trained in compliance and security basics

• Oversee privacy policy updates, training, and breach response

In a small practice, this is often the practice manager, lead nurse, or even the provider.

Who Should Be the Contact Person?

This person must:

• Be accessible to patients and staff

• Understand the basic rights under HIPAA

• Be able to route complaints or questions to the right place

• Be documented as the point of contact in your Notice of Privacy Practices (NPP)

This role can be the same as the Privacy Official or someone from the front desk or admin team.

In 2021, a pediatric clinic faced an OCR investigation following a parent's complaint that their child’s PHI had been disclosed without consent. In response, the Office for Civil Rights requested documentation of the clinic’s compliance infrastructure, specifically:

• The identity of the designated HIPAA Privacy Official

• Policies and training materials on HIPAA compliance

• Records showing how complaints were handled and by whom

The clinic was unable to produce documentation identifying a Privacy Official, and no staff member could confidently answer HIPAA-related questions. Although several assumed the office manager was responsible for privacy oversight, there was no formal designation in writing and no evidence of training.

Outcome:

OCR imposed a $10,000 fine, required the clinic to adopt a corrective action plan, and mandated the formal assignment of a Privacy Official with documented authority and responsibilities.

Lesson:

If no one is clearly assigned to oversee privacy compliance, your practice is out of alignment with HIPAA requirements. Designating a Privacy Official isn’t just a formality ,  it’s a legal obligation that establishes accountability and helps prevent avoidable violations.

Frequently Asked Questions

Can the Privacy Official and Contact Person be the same person?

Yes. Especially in small practices, it’s common for one person to hold both roles, as long as they are trained and clearly documented.

Do I have to file the name of the Privacy Official with HHS?

No. You don’t need to report this to HHS, but you must document the designation internally and make the contact information available in your NPP.

What if the Privacy Official leaves the practice?

You must immediately appoint a new official and update:

• Internal compliance records

• The Notice of Privacy Practices (if the contact changes)

What if we outsource compliance?

You may work with a HIPAA consultant or vendor, but the designated Privacy Official must be within your organization, not an external contractor.

• 45 CFR § 164.530(a): Privacy Official Requirement

• HHS HIPAA Privacy Rule Summary

• OCR HIPAA FAQs

• Sample Corrective Action Plans – OCR
  

Appointing a HIPAA Privacy Official and a designated Contact Person is not optional ,  it is a foundational requirement under the HIPAA Privacy Rule. These roles exist to ensure that your practice has clear accountability for protecting patient information and responding to concerns or complaints promptly and effectively.

To maintain compliance and build patient trust, your practice should:

• Clearly assign and document who serves as the Privacy Official and Contact Person.

• Provide regular training to ensure these individuals understand their responsibilities under HIPAA.

• Maintain accurate logs of all privacy complaints and document how each was handled.

• Keep the Notice of Privacy Practices (NPP) updated with the current name, title, and contact details of the responsible individuals.

Failing to assign these roles or to train them properly can lead to breakdowns in communication, delayed responses to breaches, and costly enforcement actions. By establishing strong leadership in privacy compliance, your practice not only meets legal obligations but also reinforces its commitment to safeguarding patient information.