CONSOLIDATED CARE, INC. (CCI) NOTICE OF PRIVACY PRACTICES
Effective September Effective September 23, 2013
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.
If you have any questions about this notice, please contact our Privacy Officer.
WHO WILL FOLLOW THE REQUIREMENTS OF THIS NOTICE
This notice describes CCI’s practices and those of:
- Any health care professional authorized to enter information into your CCI chart.
- All departments and units of CCI.
- Any member of a volunteer group we allow to help you while under the care of CCI.
- All employees, staff and other CCI personnel.
- All of the following entities, sites and locations comply with the terms of this notice. In addition, these entities, sites and locations may share medical information with each other for treatment, payment or CCI operations described in the notice.
1. Behavioral Health Generations (BHG).
2. Mental Health, Drug and Alcohol Services Board of Logan and Champaign Counties (MHDASB).
3. Clark, Schaefer, Hackett & Company (CSH Co.).
OUR PLEDGE REGARDING MEDICAL INFORMATION
We understand that medical information about you and your health is personal. We are committed to protecting medical information about you. We create a record of the care and services you receive at CCI. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by CCI, whether made by CCI personnel or staff under contract to CCI (for example, psychiatrist).
This notice will tell you about ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.
We are required by law to:
- To maintain the privacy of PHI, to provide you with this notice of our legal duties and privacy practices with respect to PHI.
- We reserve the right to change the privacy policies and practices described in this notice and to make changes effective for all of the PHI we maintain.
- We reserve the right to revise our policies and procedures. If we do so, we will make available a copy of the revised notice to you on our website, if we maintain one. A copy will always be available to you at our office and you can request that a paper copy be sent to you by mail.
- You have a right to be notified about any unsecured breach of your PHI to persons not authorized to receive your PHI if the PHI was not encrypted or otherwise made unreadable to such unauthorized recipients.
- Follow the terms of the notice that is currently in effect.
USES AND DISCLOSURES FOR TREATMENT, PAYMENT AND HEALTH CARE OPERATIONS
- For Treatment: We may use medical information about you to provide you with behavioral health/recovery and medical treatment/services. We may disclose medical information about you to doctors, nurses, counselors, social workers, healthcare professionals in training, or other CCI personnel who are involved in taking care of you through CCI. Different departments of CCI may also share medical information about you in order to coordinate the different things you need, such as prescriptions, counseling and residential support. We also may disclose medical information about you to people outside CCI who may be involved in your care, such as family members, or others we use to provide services that are part of your care.
- For Payment: We may use and disclose medical information about you so that the treatment and services you receive at CCI may be billed to and payment may be collected from you, an insurance company or a third party.
- For Healthcare Operations: These are activities that relate to the performance and operations at CCI. Examples of health care operations are quality assessment and improvement activities, business-related matters such as audits and administrative services and care coordination. These uses and disclosures are necessary to run CCI and make sure that all of our clients receive quality care.
We may remove information that identifies you from the set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.
- Appointment Reminders: We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or services at CCI.
- Treatment Alternatives: We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
- Health- Health-Related Benefits and Services: We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.
- Fundraising Activities: We may use medical information about you to contact you in an effort to raise money for CCI and its operations. We may disclose medical information to a foundation related to CCI so that the foundation may contact you in raising money for CCI. We would only release contact information, such as your name, address and phone number and the dates you received treatment or services at CCI. If you do not want to be contacted for fundraising efforts, you must notify in writing, our Privacy Office, 1521 N. Detroit St., PO Box 817, West Liberty, OH 43357-0817 that you want to opt out.
- Individuals Involved in Your Care or Payment for Your Care: We may release medical information about you to a friend or family member who is involved in your medical care. We may also give information to someone who helps pay for your care.
- Research: Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with the client’s need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, but we may, however, disclose medical information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the medical information they review does not leave CCI. We will almost always ask for your specific permission if the research will have access to your name, address or other information that reveals who you are, or will be involved in your care at CCI.
- Required By Law: We will disclose medical information about you when required to do so by federal, state or local law.
- To Avert a Serious Threat to Health or Safety: We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
- Military and Veterans: If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
- Worker’s Compensation: We may release medical information about you for worker’s compensation or similar programs. These programs provide benefits for work-related injuries or illness.
- Public Health Risks: We may disclose medical information about you for public health activities. These activities generally include the following:
- Prevent or control disease, injury or disability;
- Report births and deaths;
- Report child abuse or neglect;
- Report reactions or medications or problems with products;
- Notify people of recalls of products they may be using;
- Notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
- Notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
- Health Oversight Activities: We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
- Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery requests or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the requestor to obtain an order protecting the information requested.
- Law Enforcement: We may release medical information if asked to do so by a law enforcement official:
- In response to a court order, subpoena, warrant, summons or similar process;
- To identify or locate a suspect, fugitive, material witness, or missing person;
- About the victim or a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
- About a death we believe may be the result of criminal conduct;
- About criminal conduct at CCI; and
- In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.
- Coroners, Medical Examiners and Funeral Directors: We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medication information about clients of the agency to funeral directors as necessary to carry out their duties.
- National Security and Intelligence Activities: We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
- Protective Services for the President and Others: We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or 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 medical 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 institution.
YOUR WRITTEN AUTHORIZATION IS REQUIRED FOR OTHER USES AND DISCLOSURES
- Psychotherapy Notes; Uses and disclosures of psychotherapy notes will be made only with your written authorization.
- Marketing: We will not sell or disclose your PHI to any other company for their use in marketing their products to you.
YOUR RIGHTS YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU
You have the following rights regarding medical information we maintain about you: All requests to exercise these rights must be submitted in writing to our Privacy Officer.
- Right to Inspect and Copy: You have the right to inspect and copy medical information that may be used to make decisions about your care. Usually, this includes medical and billing records including psychotherapy notes. To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing. If you request a copy of the information, we may charge a fee for the cost of copying, mailing or other supplies associated with your request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you request that the denial be reviewed. Another licensed health care professional chosen by CCI will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.
- Right to Amend: If you feel that medical information we have about you is incorrect or incomplete you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by, or for, CCI. In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
- Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
- Is not part of the medical information kept by or for CCI;
- Is not part of the information which you would be permitted to inspect and copy; or
- Is accurate and complete.
- Right to an Accounting of Disclosures: You have the right to request an “accounting of disclosures”. This is a list of the disclosures we made of medical information about you. Your request must state a time period that may not be longer than six years. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12-month period will be free. We may charge a reasonable cost-based fee for all subsequent requests during that 12-month period. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.
- Right to Request Restrictions: You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. We must comply with your request not to disclose health information to a health plan for treatment when you have paid in full out-of-pocket for your service. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your case, like a family member or friend. For example, you could ask that we not use or disclose information about a treatment you had. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. In your request you must tell us (1) what information you want to limit, (2) whether you want to limit our use, disclosure or both and (3) to whom you want the limits to apply for example, disclosures to your spouse.
- Right to Request Confidential Communications: You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
- Right to a Paper Copy of This Notice: You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. You may obtain a copy of this notice at our website, www.ccibhp.com, request a paper copy of this notice from the receptionist at any office location.
CHANGES TO THIS NOTICE
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in CCI offices. The notice will contain on the first page in the top center, the effective date. In addition, each time you register or are re-admitted to ‘CCI for treatment or health care services, you will be offered a copy of the current notice in effect.
If you believe your privacy rights have been violated, you may file a complaint with CCI or with the Secretary of the Department of Health and Human Services. All complaints must be submitted in writing.
You will not be penalized or discriminated against for filing a complaint.
OTHER USES OF MEDICAL INFORMATION
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written permission; we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.