Protected Personal Health Information Policy
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Your Rights You have the right to:
- Get a copy of your paper or electronic medical record
- Correct your paper or electronic medical record
- Request confidential communication
- Ask us to limit the information we share
- Get a list of those with whom we’ve shared your information
- Get a copy of this privacy notice
- Choose someone to act for you
- File a complaint if you believe your privacy rights have been violated
Your Choices You have some choices in the way that we use and share information as we:
- Tell family and friends about your condition
- Provide disaster relief
- Include you in a facility directory
- Provide mental health care
- Market our services
- Raise funds
Our Uses and Disclosures We may use and share your information as we:
- Treat you
- Run our organization
- Bill for your services
- Help with public health and safety issues
- Do research
- Comply with the law
- Respond to organ and tissue donation requests
- Work with a medical examiner or funeral director
- Address workers’ compensation, law enforcement, and other government requests
- Respond to lawsuits and legal actions
Your Health Information Rights When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
Right to a Copy of This Notice: You have the right to obtain a paper copy of this Notice at any time, even if you have agreed to receive this Notice electronically.
Right to Request Restrictions: You have the right to request restrictions on the use or disclosure of your personal health information for treatment, payment or health care operations. Specifically the right to restrict certain disclosures of PHI to health plans when the payment in full for the health care item and service has been made. You also have the right to restrict the personal health information we disclose about you to a family member, friend or other person who is involved in your care or the payment for your care. We are not required to agree to your requested restriction. However, if we do agree to the restriction, then we must adhere to the restriction.
Choose someone to act for you: If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action
Right of Access to Personal Health Information: You have the right to request, either orally or in writing, your medical or billing records or other written information that may be used to make decisions about your care. The facility must provide access or the requested information within 24 business hours and/or a copy provided within 2 working days in the format requested at a reasonable cost.
Right to Request Amendment: You have the right to request the facility to amend any personal health information you think is incorrect or incomplete maintained by the facility for as long as the information is kept by or for the facility. You must make your request in writing and must state the reason for the requested amendment. We may deny your request for amendment of the information:
- Was not created by the facility, unless the originator of the information is no longer available to act on our request;
- Is not part of the personal health information maintained by or for the facility;
- Is not part of the information to which you have a right of access; or
- Is already accurate and complete, as determined by the facility.
If your request for amendment is denied, we will give you a written denial within 60 days including the reasons for the denial and the right to submit a written statement disagreeing with the denial.
Right to an Accounting of Disclosures: You have the right to request a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). To request an accounting, you must submit a request in writing, we will provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
Right to Request Confidential Communication: You have the right to request that we communicate with you concerning personal health matters in a certain manner or at a certain location. For example, you can request that we contact you only at a certain phone number. We will accommodate your reasonable requests.
Our Responsibilities This organization is required to:
- We are required by law to maintain the privacy and security of your protected health information.
- We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
- We must follow the duties and privacy practices described in this notice and give you a copy of it.
- We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
For More Information or you feel your rights are violated:
You may contact the organization’s Privacy Officer at: 610-794-5175.
You can file a complaint with the U.S. Department of Health and Human Services, Office of Civil Rights, by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling the office at 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
We will not retaliate against you for filing a complaint. There is to be no retaliation for filing a complaint.
Your PHI Choices: For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.
In these cases, you have both the right and choice to tell us to:
- Share information with your family, close friends, or others involved in your care
- Share information in a disaster relief situation
- Include your information in a facility directory
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
In these cases we never share your information unless you give us written permission:
- Marketing purposes
- Sale of your information
- Most sharing of psychotherapy notes
Changes to the Terms of this Notice: We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.
We may use and disclose your personal health information for purposes of treatment, payment and health care operations without needing to obtain your consent:
We have described these uses and disclosures below and provide examples of the types of uses and disclosures we may make in each of these categories. Other uses and disclosures not described in this NPP will be made only with authorization from the individual.
For Treatment: We will use and disclose your personal health information in providing you with treatment and services. We may disclose your personal health information to facility and non-facility personnel who may be involved in your care, such as physicians, nurses, nurse aides, and physical therapists. For example, a nurse caring for you will report any change in your condition to your physician. We also may disclose personal health information to individuals who will be involved in your care after you leave the facility.
For Payment: We may use and disclose your personal health information in order to bill and receive payment for the treatment and services received at the facility. For billing and payment purposes, we may disclose your personal health information to your representative, and insurance or managed care company, Medicare or your health plan to confirm your coverage or to request prior approval for a proposed treatment or service. You have the right to restrict certain disclosures of PHI to a health plan when payment is made out of pocket in full for the health care item or service.
For Health Care Operations: We may use and disclose your personal health information for facility operations. These uses and disclosures are necessary to manage the facility and to monitor our quality of care. For example, we may use personal health information to evaluate our facility’s services, including the performance of our staff.
Business Associates: There are some services provided in our organization through contacts with business associates. Examples include physician services, radiology, certain laboratory tests, nutrition services, ambulance services, and professional consulting services. When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we’ve asked them to do and bill you or your third-party payer for services rendered. To protect your health information, however, we require the business associate to appropriately safeguard your information.
Directory: Unless you notify us that you object, we will use your name, location in the facility, general condition, and religious affiliation for directory purposes. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name.
Notification: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.
Communication with family: Health professionals, using their best judgment, may disclose to a family member, other relative, close personal friend or any other person you identify, health information relevant to that person’s involvement in your care or payment related to your care.
Research: We may disclose information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.
Funeral directors: We may disclose health information to funeral directors consistent with applicable law to carry out their duties.
Organ procurement organizations: Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.
Marketing: We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. All other uses or disclosures of your protected health information for marketing purposes will only be made with your written authorization.
Fund-raising Activities: We may contact you for fundraising efforts, but you can tell us not to contact you again. Unless you notify us that you object, we may use certain personal health information in an effort to contact you for the purpose of raising money for the facility and its operations or a foundation related to the facility. You have the right to opt out of such communications related to fund-raising activities.
Food and Drug Administration (FDA): We may disclose to the FDA health information relative to adverse events with respect to food, supplements, produce and product defects, or post marketing surveillance information to enable product recall, repairs or replacement.
Workers compensation: We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law.
Public health: As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.
Health Oversight Activities: We may disclose your personal health information to a health oversight agency for oversight activities authorized by law. These may include, for example, audits, investigations, inspections and licensure actions or other legal proceedings. These activities are necessary for government oversight of the health care system, government payment or regulatory programs, and compliance with civil rights laws.
Respond to lawsuits and legal actions: We can share health information about you in response to a court or administrative order, or in response to a subpoena.
Law enforcement: We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena or a court order.
Federal law makes provision for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public.
Effective Date: September 27, 2017