Notice of Privacy Practices
Effective August 1, 2016
This notice is required as the privacy regulations created as a result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
This notice describes how health information about you (as a patient of this practice) may be used and disclosed and how you can get access to your individually identifiable health information. The terms of this notice apply to all records containing your protected health information that are created or maintained by our practice. We reserve the right to revise or amend this Notice of Privacy Practices. Any revisions or amendments to this notice will be effective for all your records that have been created or maintained in the past, and for any records we create or maintain in the future. Our office will post a copy of our current Notice in our office in a visible location at all times, and you may request a copy at any time.
Our commitment to your privacy
Student Health Services (SHS) is dedicated to maintaining the privacy of your individually identifiable health information (also called protected health information (PHI). In conducting our business, we will create records regarding you and the treatment and services we provide you. We are required by law to maintain the confidentiality of health information that identifies you. We also are required by law to provide you with this notice of our legal duties and the privacy practices that we maintain in our practice concerning your PHI. By federal and state law, we must follow the terms of the Notice of Privacy Practices that we have in effect at the time.
We realize that these laws are complicated, but we must provide you with the following important information:
- How we may use and disclose your PMI,
- Uses and disclosures of your PHI that requires your separate authorization,
- Your privacy rights in your PHI,
- Our obligations concerning the use and disclosure of your PHI.
If you have any questions about this Notice, please contact:
Lisa Ritenour, MSN, FNP-BC
Director of Student Health Services
We may disclose and use your PHI in the following ways:
- Our practice may use your PHI to treat you. All information that we obtain through history exam and laboratory testing will be used to help us reach a diagnosis. We may then use that information to write a prescription for you, thus disclosing your PHI to a pharmacy or laboratory. Many of the people who work for our practice- including, but not limited to, our Nurse Practitioners, Physicians, Nurses- may use or disclose your PHI in order to treat you or to assist others in your treatment. Finally, we may also disclose your PHI to other health care providers for purposes related to your treatment.
- If you have the Student Health Insurance, we may also use and disclose your PHI in order to bill and collect payment for the services and items you may receive from us. For example, we may contact your health insurer to certify that you are eligible for benefits, and we may provide your insurer with details regarding your diagnosis and treatment to determine if your insurer will cover, or pay for your treatment. Also, we may use your PHI to bill you directly for services and items. We may disclose your PHI to other health care providers and entities to assist in their billing and collection efforts.
- Health care operations. Our practice may use and disclose your PHI to operate our business. As example of the ways in which we may use and disclose your information for our operations, we may use your PHI to evaluate the quality of care you receive from us, or to conduct cost-management and business planning activities for our practice. We may disclose your PHI to other health care providers and entities to assist in their health care operations.
- Appointment reminders. Our practice may use PHI to contact you and remind you of an appointment by phone or mail.
- Disclosures required by law. Our practice will use and disclose your PHI when we are required by federal, state and local law.
The following PHI disclosures and restrictions of disclosure require your written authorization:
- Disclosure of PHI for marketing purposes or disclosures that constitute the sale of PHI buy the practice.
- The disclosure of psychotherapy notes.
- Restricted disclosure to Health Plans. An individual has the right to restrict certain PHI to health plans when the individual pays out of pocket, in full, for their care.
Use and disclosure of your PHI in certain special circumstances
- Public Health risks. We may disclose your PHI to public health authorities that are authorized by law to collect information for the purpose of:
- Maintaining vital records, such as births and deaths,
- Reporting child abuse or neglect,
- Preventing or controlling disease, injury or disability,
- Notifying a person regarding potential exposure to communicable disease,
- Notifying a person regarding a potential risk for spreading or contracting a disease or condition,
- Reporting reactions to drugs or problems with products or devices,
- Notifying individuals if a product or device they may be using has been recalled,
- Notifying appropriate government agencies and authorities regarding the potential abuse or neglect of an adult patient (including domestic violence); however, we will only disclose this information if the patient agrees or we are required or authorized by law to disclose the information,
- Notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance.
- Health oversight activities. Our practice may disclose your PHI to a health oversight agency for activities authorized by law. Oversight activities can include investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative and criminal procedures or actions: or other activities necessary for the government to monitor their programs, compliance with civil rights laws and the health care system in general.
- Lawsuits and similar proceedings. Our practice may disclose your PHI in response to a court or administrative order, if you are involved in a lawsuit or similar proceeding. We also may disclose your PHI in response to a discovery request , subpoena or other lawful process by another party involved in the dispute, but only if we have made an effort to inform you of the request or to obtain an order protecting the information the party has requested.
- Law enforcement. We may release PHI if asked to do so by law enforcement officials regarding a crime victim in certain situations if we are unable to obtain the person’s agreement for the following reasons:
- Concerning a death we believe has resulted from criminal conduct,
- Regarding criminal conduct at our office,
- In response to a warrant, summons, court order, subpoena or similar legal process,
- To identify/locate a suspect, material witness, fugitive or missing person,
- In an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity or location of the perpetrator.
- Serious threats to health or safety. Our practice may disclose your PHI when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.
- Our practice may disclose your PHI if you are a member of the U.S. or foreign military forces (including veterans) and if required by the appropriate authorities.
- National security. Our practice may disclose your PHI to federal officials for intelligence and national security activities authorized by law. We also may disclose your PHI to federal officials in order to protect the President, other officials or foreign heads of state, or to conduct investigations.
- Our practice may disclose your PHI to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official. Disclosure for these purposes would be necessary: (a) for the institution to provide health care services to you, (b) for the safety and security of the institution, and/or (c) to protect your health and safety or the health and safety of other individuals.
- Worker’s Compensation. Our practice may disclose your PHI for worker’s compensation and similar programs.
Your rights regarding your PHI
You have the following rights regarding your PHI that we maintain about you:
- Confidential communications. You have a right to request that our practice communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than work. In order to request a type of confidential communication, you must make give us a written request and we will accommodate that request without question.
- Request restrictions. You have the right to request a restriction to our use or disclosure of your PHI for treatment, payment or health care operations. You also have the right to request that we restrict our disclosure of your PHI to only certain individuals involved in your care or the payment for your care , such as family members or friends. We are not required to agree to your request. However, if we agree, we are bound by our agreement except when otherwise required by law. In emergencies or when the information is necessary to treat you. In order to request a restriction, you must make your request in writing. Your request must describe in clear and concise fashion:
- The information you wish restricted,
- Whether you are requesting to limit our practice’s use, disclosure, or both,
- To whom you want the limits to apply.
- Inspection and copies. You have the right to inspect and obtain a copy of the PHI that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes. You must make this request in writing in order to inspect or obtain a copy of your PHI. Our practice may deny your request in certain limited circumstances, but you may request a review of our denial. Another licensed health care professional chosen by us will conduct reviews.
- You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our practice. To request an amendment your request must be made in writing. You must provide us with a reason that supports your request for amendment. Our practice will deny your request if you fail to submit your request in writing. Also, we may deny your request if you ask us to amend information that is our opinion: (a) accurate and complete; (b) not part of the PHI kept by this practice; (c) not part of the PHI which you would be permitted to inspect and copy; (d) not created by our practice, unless the individual or entity that created the information is not available to amend that information.
- Accounting of disclosures. All of our patients have the right to request an “accounting of disclosures” which is a list of certain non-routine disclosures our practice has made of your PHI for purposes not made to treatment, payment, or operations. To obtain this yoy must submit your request in writing.
- Right to a paper copy of this notice. You are entitled to receive a paper copy of our privacy practices. We will also have this available on our website.
- Right to file a complaint. If you believe your privacy rights have been violated, you may file a complaint with our practice or with the Secretary of the Department of Health and Human Services. To file a complaint with our practice, contact Lisa Ritenour, MSN, FNP-BC, (330)972-7808. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
- Right to provide an authorization for other uses and disclosures. Our practice will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law. Any authorization you provide to us may be revoked at any time in writing. After you revoke your authorization we will no longer use or disclose your PHI for the reasons described in the authorization. Please note that we are required to retain records of your care.
- Right to notification of a breach of your PHI. In the event a breach of an individual’s unsecured PHI occurs, our practice will make every effort to notify the individual in accordance with the HIPAA Security Rule.
If you have any questions regarding this notice or our health information privacy policies, please contact Lisa Ritenour, MSN, FNP-BC, (330)972-7808.