Physical site NPP posting is the duty of a covered direct-treatment provider with a physical service-delivery site to keep the current notice available for individuals to request and take, and to post it in a clear, prominent location where people seeking service can reasonably be expected to read it. Posting supports access to the notice while individual delivery follows its own timing requirements.
Editorial approval scope: The team checked current source fidelity, scope boundaries, dates, arithmetic, reader usefulness, practical workflow, and general-information limitations.
Availability and display are two controls
45 CFR 164.520 requires take-away availability and a clear, prominent posting. Record each site, entrance and service path, display location, format, languages or access supports, available copies, notice version, inspection date, and owner.
Walk the path a person seeking service would take. Confirm the posting is visible before or at the service area, readable, unobstructed, and associated with the correct covered entity. A poster behind a locked door, hidden by furniture, or placed only in a staff space does not achieve prominent display.
Maintain paper copies that people can take on request. A QR code or digital screen can supplement access, while it should not leave a person without a usable copy. Check language and accessibility support under the entity's broader obligations and policies.
The current version must reach every site
A headquarters update can leave satellite offices with old posters or empty handout racks. Include clinics, temporary locations, and service sites that meet the rule's physical-site condition. Verify local screens and QR links open the current notice if used as supplements.
Use a site register with opening, closing, relocation, and temporary-service dates. Assign a local custodian and central version owner. Release new posters and copies through controlled distribution, collect obsolete stock, and confirm receipt. Include acquired and co-located sites in scope analysis.
Inspect the full site experience
Record notice version, photo, location, copy inventory, link target, inspection time, and remediation. Test all entrances and check whether the display remains visible during construction, events, or altered traffic flow. Review damaged, faded, or inaccessible materials.
Posting is separate from individual first-service delivery and acknowledgment. Site readiness supports notice access but cannot substitute for delivering the notice under the applicable timing rule.
Example across sites
A practice audits five centers. Four display the current notice and have copies available; one has the current poster but old take-away copies. Complete site readiness is 4 of 5 centers.
The fifth site removes old stock, receives the current version, and documents a new inspection. The poster component had passed, while complete readiness required both display and take-away availability. Report those subcontrols separately.
Site-posting checklist
- Inventory every physical service-delivery site and covered entity.
- Walk actual entrances and service paths to confirm prominence.
- Display the current readable notice and stock take-away copies.
- Test QR codes or screens only as supplemental routes.
- Assign central version control and local inspection ownership.
- Remove obsolete copies after material revisions.
- Retain photos, inventory, findings, remediation, and dates.
Owner controls
HHS guidance describes office availability and prominent posting. Use a site register, version date, photo evidence, copy inventory, accessibility review, change checklist, and periodic inspection. Keep individual first-service delivery as a separate metric.
Monitor sites current, copies stocked, inspections overdue, links broken, and findings unresolved. Trigger inspection after opening, relocation, renovation, acquisition, or notice revision. Mystery-shop periodically from the visitor's perspective rather than relying only on staff confirmation.
Define site scope with operations and legal owners. Include spaces where the provider maintains a physical service-delivery site, and document the basis for mobile, school, shared, or temporary locations that receive different handling. For shared spaces, identify which entity's notice appears, whether several notices are needed, and how a visitor can distinguish them. Do not let a lease label substitute for a functional service-path review.
Use inspection sampling that covers opening hours, alternate entrances, weekend operations, and low-stock periods. Confirm the display survived cleaning, construction, and seasonal signage. Count current take-away copies and restock thresholds. After a revision, reconcile the number of sites sent new materials to the number that confirmed display and old-stock removal. Preserve photos carefully so they show compliance evidence without capturing people or incidental PHI.
Give each finding a specific correction path. A hidden display may need relocation, an inaccessible frame may need another format, and an empty holder requires both restocking and review of the reorder threshold. If a site shows an obsolete notice, identify when the old version appeared and whether take-away copies or first-service packets were also affected. Record the responsible owner, target date, completion evidence, and follow-up test. Roll recurring defects into facilities, opening, acquisition, and revision checklists so the same problem is not rediscovered at every inspection.
Include the closure date and verifying inspector so remediation is supported by an independent follow-up rather than a self-attested task status.
Related terms
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