We value our relationships with our community members more than anything. We want you to trust that we will handle your information in the most responsible way possible.
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Notice of Privacy Practices
I. 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.
The terms of this Notice of Privacy Practices apply to ProMedica Health System, Inc. (“ProMedica”). ProMedica is a covered entity that includes general acute care hospitals, ambulatory surgery centers, clinics, physician offices, home health care, and other health care facilities. ProMedica, its employees, volunteers, students, independent contractors, Medical Staff, and other professionals will share personal health information of patients with other ProMedica entities as necessary to carry out treatment, payment, and health care operations as permitted by law.
II. WE HAVE A LEGAL DUTY TO PROTECT YOUR HEALTH INFORMATION
We are required by law to protect the privacy of your health information. We are also required to provide you with this notice about our privacy practices. We are required to comply with all of the terms described in the current version of our Notice of Privacy Practices.
You can request a copy of this notice from the contact person listed in Section VI below at any time and can view a copy of this notice on our web site at www.promedica.org.
III. HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION
A.USE AND DISCLOSURE THAT DOES NOT REQUIRE YOUR AUTHORIZATION
ProMedica collects health information from you and stores it in a paper chart and on a computer. The collected information may be used for the following purposes.
- For treatment. We may give information about you to physicians, nurses, medical students, and other health care personnel who are involved in your care.
- To obtain payment for treatment. We may give portions of your information to our billing department and to your health plan to get paid for the services we provided to you. We may give your information to our business associates, such as billing companies, claims processing companies, law firms, collection agencies, and others that process our health care claims. We may also give your information to another health care provider that has treated you for their payment purposes.
- For regular health care operations. We may disclose information about you to operate this business. For example, we may use information about you to look at the quality of health care services that you received or to look at the performance of the professionals who provided health care services to you. We may provide information about you to our accountants, attorneys, consultants, and others in order to make sure we are complying with the laws that affect us. We may also give your information to other health care providers and health plans for their business operations if they have or had a patient relationship with you.
- When required by federal, state or local law, judicial or administrative proceedings, or law enforcement. For example, we give out your information when a law requires that we report information to government agencies and law enforcement personnel about victims of abuse, neglect, or domestic violence; when dealing with gunshot and other wounds; either by subpoena or when ordered by the court.
- For public health activities. For example, we report information about births, deaths, and various diseases, to government officials in charge of collecting that information, and we give coroners, medical examiners, and funeral directors necessary information relating to a death.
- For health oversight activities. For example, we will provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.
- For purposes of organ donation. We may notify organ procurement organizations to assist them in organ, eye, or tissue donation and transplants.
- For research purposes. We may give information about you in order to conduct research that has been approved by the ProMedica Institutional Review Board.
- To avoid harm. In order to avoid a serious threat to the health or safety of a person or the public, we may give your information to law enforcement personnel or persons able to prevent or lessen such harm.
- For specific government functions. We may give out information on military personnel and veterans in certain situations. We may also give your information for national security purposes, such as protecting the President of the United States or conducting intelligence operations.
- For workers’ compensation purposes. We may release your information to your employer when we have provided health care to you at the request of your employer to determine workplace-related illness or injury.
- Appointments and services. We may contact you to remind you of an appointment or give you a test result. You have the right to request that messages not be left on voice mail or sent to a particular address. We may also contact you to give you information about treatment alternatives, or other health care services and benefits we offer.
- Fundraising activities. We may contact you to raise funds for our organization. The money raised through these activities is used to expand and support the health care services and educational programs we provide to the community. If you do not wish to be contacted as part of our fundraising efforts, please call the confidential ProMedica Hotline number listed in Section VI below and your information will be forwarded to the appropriate department.
B. YOU HAVE THE OPPORTUNITY TO OBJECT TO THESE DISCLOSURES
- Patient directories. We may include your name, location in this facility, general condition, and religious affiliation, in our patient directory for use by clergy and visitors who ask for you by name. If you do not want us to provide this information to clergy and others, you must tell us that you object and fill out the appropriate form.
- Disclosures to family, friends, or others. We may provide your information to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object and fill out the appropriate form.
C. DISCLOSURES THAT REQUIRE YOUR AUTHORIZATION
Disclosures related to psychiatric treatment programs, human immunodeficiency virus (HIV) test results or diagnosis of AIDS or an AIDS-related condition, or information about alcohol or drug treatment you received in a drug or alcohol treatment program, or certain information to the State Long-Term Care Ombudsman, will not be made without your authorization except as required or allowed by law. Before we use, disclose or sell your personal health information for any reason other than those reasons described in Section III.A and III.B, we will need to get your written authorization. If you authorize us to use or disclose your information, you can revoke your authorization by filling out the appropriate form.
D. PATIENT SAFETY ROOM SURVEILLANCE
In some patient rooms video surveillance may be used for the purposes of patient safety and treatment. These images are not recorded and signage will be posted where video surveillance is in use.
IV. YOUR HEALTH INFORMATION RIGHTS
A. The Right to Request Limits on How We Use and Disclose Your Health Information. You have the right to ask that we limit how we use and give out your information. We will carefully consider your request, but we are not required to accept it, except for certain disclosures when you have paid for service out-of-pocket in full.
If we accept your request, we will put it in writing and abide by it except in emergency situations. To request limits, complete the appropriate form at the facility where you are receiving care.
B.The Right to Choose How We Send Your Information to You. You have the right to ask that we send information to you to an alternate address. For example, you may ask us to send information to your work address rather than your home address. You can also ask that it be sent by alternate means. For example, you can ask that we send information by fax instead of regular mail. We will agree to your request if we can easily provide it in the format you request.
C.The Right to See and Get Copies of Your Health Information. Most of the time, you have the right to look at or get copies of your health information that we have. Your request must be on the appropriate form and signed by you or your legally authorized representative. If we keep your health information in an Electronic Health Record, it will be given to you (or your designee) electronically upon your request. In certain situations, we may deny your request. If we do, we will tell you, in writing, our reasons why and explain how you can have the denial reviewed.
D.The Right to Get a List of Who We Have Given Your Information To. You have the right to get a list of certain instances in which we have given out your health information after April 14, 2003. To get this list, you must complete the appropriate form and submit it to the facility where you received your care.
E.The Right to Correct or Update Your Health Information. If you believe that there is a mistake in your information or that a piece of important information is missing, you have the right to request that we correct the existing information or add the missing information. Your request and your reason for the request must be submitted on the appropriate form.
Each request will be carefully considered. If we approve your request, we will make the change to your information, tell you that we have done it, and tell others that need to know about the change.
F.The Right to Get This Notice. You have the right to request a paper copy of this notice. You also have a right to get a copy of this notice by e mail.
G.The Right to Privacy Notification. You have the right to be notified after a breach of your protected health information.
V. CHANGES TO THE POLICY
VI. COMPLAINTS AND CONTACT INFORMATION
If you think that we may have violated your privacy rights, or you disagree with a decision we made about your health information, you may file a written complaint to the Office of Civil Rights, Region V – Regional Manager, U.S. Department of Health and Human Services, 233 N. Michigan Avenue, Suite 240, Chicago, IL 60601. We will take no action against you if you file a complaint about our privacy practices.
If you have any questions about this notice or any complaints about our privacy practices, please call the confidential ProMedica Hotline at (419) 824-1815 or (800) 807-2693. Your information will be directed to the appropriate Privacy Officer or Patient Representative.
VII. EFFECTIVE DATE OF THIS NOTICE
Effective Date: April 14, 2003
Revised Date: February 17, 2010
Revised Date: May 16, 2011
Revised Date: December 1, 2011
Revised Date: August 13, 2013
Policy Title: Dissemination of the Notice of Privacy Practices
Policy No: SP 6.14
Effective Date: April 14, 2003
Revised Date: January 1, 2007, January 1, 2012
Purpose: The federal HIPAA regulations on patient privacy and confidentiality require ProMedica entities to provide notice to patients and the public about how personal health information (“PHI”) may be used and disclosed by the organization.
1. Timing of Provision. The Notice of Privacy Practices must be made available, distributed, and the appropriate signage posted at each ProMedica entity in accordance with this policy on or before April 14, 2003.
2. Availability to the Public. A copy of the Notice of Privacy Practices (“Notice”) must be made available on request to any person who requests it in each separate building where patients receive treatment. A copy of this Notice can be requested by calling the confidential ProMedica Hotline number as listed in Section VI of the Notice, and can be viewed on the ProMedica web site at www.Promedica.org.
Individuals have the right to receive a copy of this Notice by e-mail and to request a paper copy. Individuals that cannot read may request that an employee read the Notice to the individual upon appointment.
3. Distribution to Patients. All patients will be offered a copy of the Notice no later than the date of the first service delivery or first treatment encounter on or after April 14, 2003, including service delivered electronically, to such patient. Each ProMedica entity will make a good faith effort to obtain written acknowledgement or receipt of the Notice by having the patient or legally authorized representative sign the Acknowledgement of Notice of Privacy Practices or a similar acknowledgment form. The Notice will remain valid until such time that the notice has been revised.
In an emergency situation, the Notice should be provided and acknowledgment obtained as soon as reasonably practicable after the emergency situation.
When the first treatment encounter for a direct treatment relationship with the patient is over the telephone, the Notice will be forwarded to the individual that day unless the first face-to-face encounter with the patient will occur shortly thereafter. The notice may be forwarded via mail, fax, or e-mail and documentation of that fact shall be maintained for a period of six years. The written acknowledgment will be obtained at the first face-to-face encounter with the patient or earlier in accordance with individual ProMedica entity policy.
Scheduling an appointment is not considered a treatment encounter. As such, the Notice will be provided to the patient at the time the individual arrives at the ProMedica entity for his or her appointment.
If acknowledgment of the Notice cannot be obtained, the good faith efforts to obtain the acknowledgement and the reasons why the acknowledgment was not obtained must be documented on the Acknowledgement of Notice of Privacy Practices form or similar acknowledgment form and retained in the medical record.
4. Inmates. When the patient is an inmate in a correctional facility, provision of the Notice and the attempt to obtain acknowledgment of receipt of the Notice is not required.
5. Signage. Each ProMedica entity is required to post the Notice in all buildings where patients receive treatment. Notice signage for all ProMedica entities is developed and obtained through ProMedica Public Relations.
6. Email Delivery of Notice. The Notice may be provided to a patient by e-mail, if the patient agrees to electronic notice. An electronic acknowledgment from the patient via e-mail will be considered written acknowledgment of receipt. Such e-mail message will be printed and retained in the medical record. If it is known that the e-mail transmission failed, a paper copy of the Notice must be provided to the patient.
7. Website Posting. A copy of the most recent Notice will be posted prominently on the ProMedica website, for each individual ProMedica entity.
8. Revisions to the Notice. ProMedica reserves the right to change its Notice and privacy policies at any time. Any changes will apply to all protected health information. If any changes are made to ProMedica privacy policies, the Notice will be changed, if applicable, and a new Notice will be posted on the web.
9. Record Retention. The individual Privacy Officer at each entity shall retain all versions of the Notice, i.e., the original and all subsequent revised Notices. Copies of the Notices shall be retained for six years.