HIPPA (Health Insurance Portability and Accountability
This notice describes how your medical information may be used and disclosed
and how you can get access to this information. Please read it carefully.
We understand that your medical information is private and confidential.
Further, we are required by law to maintain the privacy of "protected
health information". "Protected health information" includes
any individually identifiable information that we obtain from you or others
that relates to your past, present or future physical or mental health,
the health care you have received, or payment for your health care.
As required by law, this notice provides you with information about your
rights and our legal duties and privacy practices with respect to the privacy
of protected health information. This notice also discusses the uses and
disclosures we will make of your protected health information. We must comply
with the provisions of this notice as currently in effect, although we reserve
the right to change the terms of this notice from time to time and to make
the revised notice effective for all protected health information we maintain.
You can always request a written copy of our most current privacy notice
from our Privacy Officer by calling the office.
PERMITTED USES AND DISCLOSURES
We can use or disclose your protected health information for purposes of
treatment, payment and health care operations. For each of these categories
of uses and disclosures, we have provided a description and an example below.
However, not every particular use or disclosure in every category will be
Treatment means the provision, coordination
or management of your health care, including consultations between health
care providers regarding your care and referrals for health care from one
health care provider to another. For example, a doctor treating your for
a broken leg may need to know if you have diabetes because diabetes may
slow the healing process. In addition, the doctor may need to contact a
physical therapist to create the exercise regimen appropriate to your care.
Payment means the activities we undertake to
obtain reimbursement for the health care provided to you, including billing,
collections, claims management, determinations of eligibility and coverage
and utilization review activities. For example, prior to providing health
care services, we may need to provide information to your Third Party Payor
about your medical condition to determine whether the proposed course of
treatment will be covered. When we subsequently bill the Third Party Payor
for the services rendered to you, we can provide the Third Party Payor with
information regarding your care if necessary to obtain payment. Federal
or State law may require us to obtain a written release from you prior to
disclosing certain protected health information for payment purposes, and
we will ask you to sign a release when necessary under applicable law.
Health care operations means the support functions
of our practice related to treatment and payment, such as quality assurance
activities, case management, receiving and responding to patient comments
and complaints, physician reviews, compliance programs, audits, business
planning, development, management and administrative activities. For example,
we may use your protected health information to evaluate the performance
of our staff when caring for you. We may also combine health information
about many patients to decide what additional services we should offer,
what services are not needed, and whether certain new treatments are effective.
In addition, we may remove information that identifies you from your patient
information so that others can use the de-identified information to study
health care and health care delivery without learning that you are.
OTHER USES AND DISCLOSURES OF HEALTH INFORMATION
In addition to using and disclosing your information for treatment, payment
and health care operations, we may use your protected health information
in the following ways:
We may contact you to provide appointment
reminders for treatment or medical care.
We may contact you to tell you about
or recommend possible treatment alternatives or other health-related benefits
and services that may be of interest to you.
We may disclose to your family or friends
or any other individual identified by you protected health information directly
relevant to such person's involvement with your care or payment for your
care. We may use or disclose your protected health information to notify,
or assist in the notification of, a family member, a personal representative,
or another person responsible for your care of your location, general condition
or death. If you are present or otherwise available, we will give you an
opportunity to object to these disclosures, and we will not make these disclosures
if you object. If you are not present or otherwise available, we will determine
whether a disclosure to your family or friends is in your best interest,
taking into account the circumstances and based upon our professional judgment.
When permitted by law, we may coordinate our uses and disclosures
of protected health information with public or private entities authorized
by law or by charter to assist in disaster relief efforts.
We will allow your family and friends
to act on your behalf to pick-up filled prescriptions, medical supplies,
X-rays, and similar forms of protected health information, when we determine,
in our professional judgment that it is in your best interest to make such
We may contact you as part of our efforts
to market our practice's services as permitted by applicable law.
Subject to applicable law, we may make
incidental uses and disclosures of protected health information. Incidental
uses and disclosures are by-products of otherwise permitted uses or disclosures
which are limited in nature and cannot be reasonably prevented.
We may use or disclose your protected
health information for research purposes, subject to the requirements of
applicable law. For example, a research project may involve comparisons
of the health and recovery of all patients who received a particular medication.
All research projects are subject to a special approval process, which balances
research needs with a patient's need for privacy. When required, we will
obtain a written authorization from you prior to using your health information
We will use or disclose protected health
information about you when required to do so by applicable law.
(Note: In accordance with applicable
law, we may disclose your protected health information to your employer
if we are retained to conduct an evaluation relating to medical surveillance
of your workplace or to evaluate whether you have a work-related illness
or injury. Your employer or the Center as required by applicable law will
notify you of these disclosures.)
Subject to the requirements of applicable law, we will make the following
uses and disclosures of your protected health information:
Organ and Tissue Donation. If you are
an organ donor, we may release health information to organizations that
handle organ procurement or organ, eye, or tissue transplantation or to
an organ donation bank, as necessary to facilitate organ or tissue donation
Military and Veterans. If you are a member of the Armed Forces,
we may release health information about you as required by military command
authorities. We may also release health information about foreign military
personnel to the appropriate foreign military authority.
Worker's Compensation. We may release
health information about you for programs that provide benefits for work-related
injuries or illnesses.
Public Health Activities. We may disclose health information about you
for public health activities, including disclosures:
o To prevent or control disease, injury or disability;
o To report births and deaths;
o To report child abuse and neglect;
o To persons subject to the jurisdiction of the Food and Drug Administration
(FDA) for activities related to the quality, safety, or effectiveness of
FDA-regulated products or services and to report reactions to medications
or problems with products;
o To notify a person who may have been exposed to a disease or may be at
risk for contracting or spreading a disease or condition;
o To notify the appropriate government authority if we believe that an
adult patient has been the victim of abuse, neglect or domestic violence.
We will only make this disclosure if the patient agrees or when required
or authorized by law. Health Oversight Activities. We may disclose health
information to Federal or State agencies that oversee our activities. These
activities are necessary for the government to monitor the health care
system, government benefit programs, and compliance with civil rights laws
and regulatory program standards.
Lawsuits and Disputes. If you are involved
in a lawsuit or a dispute, we may disclose health information about you
in response to a court or administrative order. We may also disclose health
information about you in response to a subpoena, discovery request, or
other lawful process by someone else involved in the dispute, but only
if the Center is given assurances that the person making the request to
tell you about the request has made efforts or to obtain an order protecting
the information requested.
Law Enforcement. We may release health
information if asked to do so by a law enforcement official:
o In response to a court order, subpoena, warrant, summons or similar process;
o To identify or locate a suspect, fugitive, material witness, or missing
o About the victim of a crime under certain limited circumstances;
o About a death we believe may be the result of criminal conduct;
o About criminal conduct on our premises; and
o In emergency circumstances, to report a crime, the location of the crime
or the victims, or the identity, description or location of the person
who committed the crime.
Coroners, Medical Examiners and Funeral
Directors. We may release health information to a coroner or medical examiner.
Such disclosures may be necessary, for example, to identify a deceased
person or determine the cause of death. We may also release health information
about patients to funeral directors as necessary to carry out their duties.
National Security and Intelligence Activities.
We may release health information about you to authorized Federal officials
for intelligence, counterintelligence, or other national security activities
authorized by law.
Protective Services for the President
and Others. We may disclose health information about you to authorized
Federal officials so they may provide protection to the President or other
authorized persons or foreign heads of state or may conduct special investigations.
Inmates. If you are an inmate of a correctional
institution, or under the custody of a law enforcement official, we may
release health information about you to the correctional institution or
law enforcement official.
This release would be necessary (1) for the institution to provide you
with health care; (2) to protect your health and safety or the health and
safety of others; or (3) for the safety and security of the correctional
Serious Threats. As permitted by applicable
law and standards of ethical conduct, we may use and disclose protected
health information if we, in good faith, believe that the use or disclosure
is necessary to prevent or lessen a serious and imminent threat to the
health or safety of a person or the public or is necessary for law enforcement
authorities to identify or apprehend an individual.
NOTE: HIV-related information, genetic information, alcohol and/or substance
abuse records, mental health records and other specially protected health
information may enjoy certain special confidentiality protections under
applicable State and Federal law. Any disclosures of these types of records
will be subject to these protections.
OTHER USES OF YOUR HEALTH INFORMATION
Other uses and disclosures of protected health information not covered
by this notice or the laws that apply to us will be made only with your
permission in a written authorization. You have the right to revoke that
authorization at any time, provided that the revocation is in writing,
except to the extent that we already have taken action in reliance to your
1. You have the right to request restrictions on our uses and disclosures
of protected health information for treatment, payment and health care
operations. However, we are not required to agree to your request. To request
a restriction, you must make your request in writing to our Privacy Officer.
2. You have the right to reasonably request to receive confidential communications
of protected health information by alternative means or at alternative
locations. To make such a request, you must submit your request in writing
to our Privacy Officer.
3. You have the right to inspect and copy protected health information
contained in your medical and billing records and in any other records
used by us to make decisions about you, except:
a. For psychotherapy notes, which are notes that have been recorded by
a mental health professional documenting or analyzing the contents of conversations
during a private counseling session or a group, joint or family counseling
session and that have been separated from the rest of the medical record;
b. For information compiled in reasonable anticipation of, or for use in,
a civil, criminal, or administrative action or proceeding;
c. For protected health information involving laboratory tests when your
access is restricted by law;
d. If you are a prison inmate, obtaining a copy of your information may
be restricted if it would jeopardize your health, safety, security, custody,
rehabilitation or that of other inmates, or the safety of any officer,
employee, or other person at the correctional institution or person responsible
for transporting you;
e. If we obtained or created protected health information as part of a
research study, your access to the health information may be restricted
for as long as the research is in progress, provided that you agreed to
the temporary denial of access when consenting to participate in the research;
f. For protected health information obtained from someone other than us
under a promise of confidentiality when the access requested would be reasonably
likely to reveal the source of the information; In order to inspect and
copy your health information, you must submit your request in writing to
our Privacy Officer. If you request a copy of your health information,
we may charge a fee for the costs of copying and mailing your records,
as well as other costs associated with your request.
We may also deny a request for access to protected health information if:
o A licensed health care professional has determined, in the exercise of
professional judgment, that the access request is reasonably likely to
endanger your life or physical safety or that of another person;
o The protected health information makes reference to another person (unless
such other person is a health care provider) and a licensed health care
professional has determined, in the exercise of professional judgment,
that the access requested is reasonably likely to cause substantial harm
to such other person; or
o The request for access is made by the individual's personal representative
and a licensed health care professional has determined, in the exercise
of professional judgment, that the provision of access to such personal
representative is reasonably likely to cause substantial harm to you or
another person. If we deny a request for access for any of the three reasons
described above, then you have the right to have our denial reviewed in
accordance with the requirements of applicable law.
4. You have the right to request an amendment to your protected health
information, but we may deny your request for amendment, if we determine
that the protected health information or record that is the subject of
a. Was not created by us, unless you provide a reasonable to believe that
the originator of protected health information is no longer available to
act on the requested amendment;
b. Is not part of your medical or billing records or other records used
to make decisions about you;
c. Is not available for inspection as set forth above; or
d. Is accurate and complete. In any event, any agreed amendment will be
included as an addition to, and not a replacement of, already existing
records. In order to request an amendment to your health information, you
must submit your request in writing to our Privacy Officer, along with
a description of the reason for your request.
5. You have the right to receive an accounting of disclosures of protected
health information made by us to individuals or entities other than to
you for the six years prior to your request, except for disclosures:
a. To carry out treatment, payment and health care operations as provided
b. Incident to a use or disclosure otherwise permitted or required by applicable
c. Pursuant to a written authorization obtained from you;
d. To persons involved in your care or for other notification purposes
as provided by law;
e. For national security or intelligence purposes as provided by law;
f. To correctional institutions or law enforcement officials as provided
g. As part of a limited data set as provided by law; or
h. That occurred prior to April 14, 2003. To request an accounting of disclosure
of your health information, you must submit your request in writing to
our Privacy Officer. Your request must state a specific time period for
the accounting (e.g. the three months). The first accounting you request
within a twelve (12) month period will be free. For additional accountings,
we may charge you for the costs of providing the list. We will notify you
of the costs involved, and you may choose to withdraw or modify your request
at that time before any costs are incurred.
If you believe that your privacy rights have been violated, you should
immediately contact our Privacy Officer. We will not take action against
you for filing a complaint. You also may file a complaint with the Secretary
of Health and Human Services.
If you have any questions or would like further information about this
notice, please contact our Privacy Officer by calling 215-424-0222 This
notice is effective as of April 13, 2003