Range Regional Health Services Notice Of Privacy Practices
Effective Date: May 30, 2006
FAIRVIEW RANGE REGIONAL HEALTH SERVICES NOTICE OF PRIVACY PRACTICES
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. WE HAVE A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION
We are legally required to protect the privacy of your health information. We call this information Protected Health Information, or PHI for short, and it includes information that identifies you and relates to your past, present or future physical or mental health or condition; the provision of health care to you; or the past, present, or future payment for health care furnished to you. We understand that PHI about you is personal. We are committed to protecting the privacy of your PHI by complying with all applicable privacy and confidentiality requirements. Accordingly, we have developed polices, added controls to our computer and other systems and educated our employees about protecting your PHI. We are required by law to maintain the privacy of PHI and to provide you with this notice of our legal duties and privacy practices with respect to PHI. We create a record of the care and services you receive at Fairview Range Regional Health Services (FRRHS). We need this record to provide you with quality care and to comply with certain legal requirements. This notice will tell you about the ways in which we may use and disclose PHI about you. It also describes your rights and certain obligations we have regarding the use and disclosure of PHI. If you have any questions about this notice, please ask the registration personnel.
FRRHS provides a variety of health care services to the community. In doing so, the various parts of the system obtain PHI about and from their patients. This notice sets forth how we use and disclose that PHI and the rights that you as a patient have with respect to accessing that information and ensuring that it is kept private. For privacy purposes, all of the following entities are considered one covered entity and all will follow the terms of this Notice: University Medical Center-Mesabi, Mesaba Clinics, HealthLine, LLC, Range Mental Health Center Inc. and Greenview. In order to help the entire system provide quality health care, we share PHI between these FRRHS entities when necessary. For example, for one health problem, a patient may be seen initially at one of our Mesaba Clinic sites, be admitted to the University Medical Center-Mesabi Hospital, and then receive home care services from HealthLine HomeCare. We share information among these parts of the system to help ensure better and more convenient care for the patient. All of our employees, volunteers and agents will comply with the terms of this notice.
When your physicians, including, but not limited to anesthesiologists, pathologists, radiologists, behavioral health workers and other physician specialties or other non-FRRHS employed health care providers such as advanced practice nurses, technicians and physician assistants are treating you at a FRRHS facility, they will follow the terms of this notice. We share health information with these providers to help them provide treatment and for payment and health care operations. Your physician or other health care provider may have different policies or notices regarding their use and disclosure of your PHI created in their office or clinic.
PROTECTING THE SECURITY OF YOUR HEALTH INFORMATION
FRRHS works hard to protect the privacy and security of your health information while you are treated and after your treatment has ended. FRRHS uses electronic record systems and believes that they are an important part of improving the quality and safety of the care we give. Physicians, authorized practitioners and authorized members of our workforce use these systems so that they have the information needed to treat you. FRRHS has policies, processes and technical protections in place to keep your information from being seen by anyone that should not see it.
While our internal information systems are secure from access by unauthorized people, e-mail communication between you and FRRHS is not secure because it is sent without being encrypted (coded) through public communication lines (the Internet). There is a possibility that e-mail sent using the Internet could be received by an unauthorized person. Physicians and staff will not communicate with you using e-mail unless you want us to do so.
HOW WE MAY USE AND DISCLOSE PHI ABOUT YOU
We use and disclose PHI for many different reasons. Below, we describe the different categories of our uses and disclosures and give you some examples of each category. A. Uses and Disclosures Relating to Treatment, Payment, or Health Care Operations. We may use and disclose your PHI for the following purposes:
1. For Treatment. We may use PHI about you to provide you with medical treatment or services. We may disclose PHI about you to physicians, nurses, technicians, medical students, or other personnel who are involved in taking care of you. For example, if you’re being treated for a knee injury, we may disclose your PHI to the physical rehabilitation department in order to coordinate your care. Different departments of this facility also may share PHI about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We also may disclose PHI about you to a specialist who is consulted about your treatment or care. It is our practice to give information about your care and treatment to your regular physician so that they have information for your future care. Also, in order to provide better continuity of care for our patients, FRRHS is implementing an electronic medical record with certain physician groups that practice at FRRHS but are not a FRRHS-owned clinic. We have policies and procedures in place to protect the confidentiality of your health information as it is shared with these physician groups.
2. For Payment. We may use and disclose your PHI in order to bill and collect payment for the treatment and services provided to you. For example, we may provide portions of your PHI to our billing department and your health plan to get paid for the health care services we provided to you. This may include PHI created prior to the enrollment in an insurance plan. We may also provide your PHI to our business associates, such as billing companies, claims processing companies, and others that process our health care claims. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
3. Health Care Operations. We may use and disclose PHI about you for health care operations. These uses and disclosures are necessary to operate our facility and make sure that all of our patients receive quality care. For example, we may use PHI to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine PHI about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose PHI to physicians, nurses, technicians, medical students, and other personnel for review and learning purposes. Sometimes it is necessary for us to hire outside consultants to help us carry out certain health care operations. If we do so we only provide them with PHI when it is necessary and only after they have signed a written agreement agreeing to follow the terms of our Notice of Privacy Practice and applicable law.
B. Additional Uses and Disclosures That Do Not Require Your Authorization.
1. When a disclosure is required by federal, state, or local law, judicial or administrative proceedings, or law enforcement. We will disclose PHI about you when required to do so by federal, state, or local law, or in response to a court order, grand jury subpoena, warrant, summons or similar process. We may also release PHI if asked to do so by a law enforcement official: * To identify a deceased person, or locate a missing child under age 18; and * About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement.
We may also disclose PHI to law enforcement officials: * About a death we believe may be the result of criminal conduct. * About criminal conduct at one of our facilities; * 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; and * In other situations as required by law.
2. For public health activities. For example, we may disclose PHI about you to public health authorities for certain public health activities. These include: * to prevent or control disease, injury or disability; * to report births and deaths; * to report child abuse or neglect; * to report reactions to medications or problems with products; * to notify people of recalls of products they may be using; * 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; * to 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.
3. For health oversight activities. For example, we will provide PHI to assist the government when it conducts an investigation or inspection of a health care provider or organization. Examples of oversight activities include audits, investigations, inspections and licensing. These activities are necessary for the government to monitor the health care system, government programs and compliance with civil rights laws.
4. Appointment Reminders and Health-Related Benefits and Services. We may use and disclose PHI to contact you as a reminder that you have an appointment for treatment or give you information about treatment alternatives or other health care services or benefits we offer.
5. Coroners, Medical Examiners and Funeral Directors. We may release PHI 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 PHI about patients of the hospital to funeral directors as necessary to carry out their duties.
6. To Avert a Serious Threat to Health or Safety. We may use and disclose PHI 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.
7. Organ and Tissue Donation. We may provide PHI to organ procurement organizations to assist them in organ, eye, or tissue donation and transplants.
8. Military and Veterans. If you are a member of the armed forces, we may release PHI about you as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.
9. Workers' Compensation. We may release PHI about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.
10. National Security and Intelligence Activities. We may release PHI about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law. We may disclose PHI 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.
11. Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclosure PHI about you in response to a court or administrative order. We may also disclose PHI about you in response to a grand jury subpoena, discovery request, or other lawful process by someone else involved in the dispute, but generally only if your consent is obtained.
12. Fundraising Activities. We may use certain limited PHI 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 contact Administration at (218) 362-6655.
13. Research. In certain circumstances, we may provide PHI in order to conduct medical research. By performing research, researchers learn new or better ways to diagnose and treat illnesses. The treatment you are currently receiving is likely possible because of past research efforts. In most cases, use of your health information for research purposes will be reviewed and approved by an Institutional Review Board (IRB). An IRB is a federally mandated board that makes sure that human research subjects are protected. RRHS generally uses the IRB at FRRHS. FRRHS's internal researchers will not use your health information for research unless you authorize the use in writing or the IRB decides that the authorization requirement is not necessary. Before the IRB will decide that the authorization is not necessary, the researchers must prove that the project is important enough and show they have a plan to protect the information from any improper use or disclosure. FRRHS will not disclose your health information to external researchers unless you authorize the disclosure in writing.
14. Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release PHI 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.
15. Facility Directory. We may include certain limited PHI about you in the directory while you are a patient at one of our entities. This information may include your name, location, your general condition and your religious affiliation. The directory information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest, minister, or other spiritual advisor, even if they don't ask for you by name. This is so your family, friends and clergy can visit you and generally know how you are doing. You have the ability to request that we not include or provide this information.
16. Individuals Involved in Your Care or Payment for Your Care. We may release PHI about you to a friend or family member who is involved in your medical care. We may also give PHI to someone who helps pay for your care. We may also tell your family or friends your condition and that you are at our hospital or Greenview residence. You may limit the PHI we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. In addition, we may disclose PHI about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.
C. OTHER USES OF PHI. Other uses and disclosures of PHI not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to use or disclose PHI about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose PHI 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.
YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU
You have the following rights regarding PHI we maintain about you:
1. Right to Inspect and Copy. You have the right to inspect and copy your PHI. You must submit your request in writing to Health Information Services at the following address: 750 East 34th Street, Hibbing, MN 55746. If you request a copy of the PHI, we may charge a fee for the costs 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 we do, we will tell you, in writing, our reasons for the denial and explain your right to have the denial reviewed.
2. Right to Amend. If you feel that PHI 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 PHI is kept by or for us. To request an amendment, submit a written request to Health Information Services at the following address: 750 East 34th Street, Hibbing, MN 55746. 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 PHI that: * Was not created by us, unless the person or entity that created the PHI is no longer available to make the amendment; * Is not part of the PHI kept by or for us; * Is not part of the PHI which you would be permitted to inspect and copy; or * Is accurate and complete. We will notify you in writing if we deny your request. If the request is denied, you have the right to submit a written statement disagreeing with the denial, which will be appended or linked to the PHI in question.
3. Right to an Accounting of Disclosures. You have the right to request a list of the disclosures of your PHI, if any, we have made to third parties other than for treatment, payment, health care operations and certain other limited purposes. These disclosures are usually those required by law for reasons like disease management, protection of vulnerable adults and children, and birth and death reporting. To request this list or accounting of disclosures, you must submit your request in writing to Health Information Services at the following address: 750 East 34th Street, Hibbing, MN 55746. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. 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. 4. Right to Request Restrictions. You have the right to request a restriction or limitation on the PHI we use or disclose about you for treatment, payment or health care operations. Federal law states that we are not required to agree to your request. Should you restrict us from providing information to your insurer, you need to explain how you will pay for your treatment. If we do agree, we will comply with your request unless the PHI is needed to provide you emergency treatment. To request restrictions, you must make your request in writing to Health Information Services at the following address: 750 East 34th Street, Hibbing, MN 55746. 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.
5. 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. To request confidential communications, you must make your request in writing to Health Information Department at the following address: 750 East 34th Street, Hibbing, MN 55746. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
6. 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.
CHANGES TO THIS NOTICE We are required to abide by the terms of our Notice of Privacy Practice currently in effect. We reserve the right to change this Notice of Privacy Practice. We reserve the right to make the revised or changed notice effective for PHI 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 this facility. The notice will contain on the first page, in the top right-hand corner, the effective date.
Person to Contact For Information About This Notice or to Complain About Our Privacy Practices If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the Department of Health and Human Services. To file a complaint with us, contact Administration at (218) 362-6656. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
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