Effective Date: December 12, 2011
Updated Date: June 5, 2013 THIS NOTICE DESCRIBES HOW YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS CAREFULLY.
THE PRIVACY OF YOUR HEALTH INFORMATION IS IMPORTANT TO US.
OUR OBLIGATION TO OUR PATIENTS:
We are required by law to maintain the privacy of Personal Health Information. We are required to provide this Notice of Privacy Practices to you by the privacy regulations issued under the federal Health Insurance Portability and Accountability Act of 1996 (“HIPAA”.) You may request a copy of our Notice at any time. For more information about our privacy practices, or for additional copies of this Notice, please contact us using the information listed at the end of this Notice. Your health information is personal. We are committed to protecting your health information. We create a record of the care and services you receive at this office. 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 this office whether made by your personal physician or one of the office’s employees.
This Notice will tell you about the ways in which we may use and disclose your health information. This Notice will also describe your rights and certain obligations we have regarding the use and disclosure of your health information.
This office is required by law to:
1. Make sure that health information that identifies you is kept private;
2. Give you this Notice of our legal duties and privacy practices with respect to health information about you; and
3. Follow the terms of the Notice that is currently in effect.
How this Office May Use and Disclose Your Health information
The following describes the different ways that your health information may be used or disclosed by this office. For clarification we have included some examples. Not every possible use or disclosure is specifically mentioned. However, all of the ways we are permitted to use and disclose your health information will fit within one of these general categories—We use and disclose health information about you for treatment, payment, and healthcare operations.
We will use health information about you to provide you with medical/dental treatment and services. We may disclose health information about you to doctors, dentists (when appropriate), nurses, technicians and other office personnel who are involved in providing you medical/dental treatment.
We may use and disclose health information about your so that the treatment and services you receive at this office may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about treatment you received here so your health plan will pay us or reimburse you for the treatment. 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.
For Healthcare Operations:
We may use and disclose health information about you for office operations. These uses and disclosures are necessary to run our office and make sure that all of our patients receive quality care. For example, we may use health information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine health information about many of our patients to decide what additional services the office should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, technicians, and other office personnel for review and learning purposes. We may remove information that identifies you from this set of health information so others may use it to study health care and health care delivery without learning the identity of the specific patients.
We may use and disclose health information to contact you as a reminder that you have an appointment for treatment or medical/dental care at this office.
We may use and disclose health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefits and Services:
We may use and disclose health information to tell you about health-related benefits or services that may be of interest to you.
Under certain circumstances, we may use and disclose health 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.
As Required By Law:
We will disclose health information about you when required to do so by federal, state or local law. For Example, disclosure may be required by Workers’ Compensation statutes and various public health statutes in connection with required reporting of certain diseases, child abuse and neglect, domestic violence, adverse drug reactions. Etc.
To Avert a Serious Threat to Health or Safety:
We may use and disclose health 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 disclosures, however, would only be made to someone able to help prevent the threat.
Health Oversight Activities:
We may disclose health information to a governmental or other oversight agency for activities authorized by law. For example, disclosures of your health information may be made in connection with administrative or criminal investigations, inspections, licensure or disciplinary actions and other similar activities necessary for appropriate oversight of government benefit programs or functions.
Lawsuits and Disputes:
If you are involved in a lawsuit or a dispute, we may use your health information to defend the office or to respond to a court order.
We may release health information about you if required by law when asked to do so by a law enforcement official.
Coroners and Medical Examiners:
We may release health information to a coroner or medical examiner to identify a deceased person or determine the cause of death.
Your Rights Regarding Your Health information
You have the following rights regarding the health information this office maintains about you:
Right to Inspect and Copy:
You have the right to inspect and copy your health information with the exception of any psychotherapy notes or information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding. We require you to make requests for access in writing.
To inspect and copy your health information, you must submit your request in writing, (i.e. a medical records release) to the Medical Records Administrator to the address listed at the end of this Notice. If you request a copy of the information, 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 you are denied access to your health information, you may request that the denial be reviewed. For information regarding such a review contact Medical Records Administrator at the address listed at the end of this Notice.
Right to Amend:
If you feel that health 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 this office. To request an amendment, your request must be in writing and submitted to the address listed at the end of this Notice. 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:
1. Was not created by us;
2. Is not part of the health information kept by this office;
3. Is not part of the information which you would be permitted to inspect and copy; or
4. 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 this office has made of your health information.To request this accounting of disclosures, you must submit your request in writing to the address listed at the end of this Notice. Your request must state a time period which may not be longer than six years and may not include dates before February 26, 2003.
Right to Request Restrictions:
You have the right to request a restriction or limitation on the use or disclosure we make of your health information. We are not required to agree to your request for a restriction. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. To request restrictions, you must submit your request in writing to the address listed at the end of this Notice.
Right to Request Confidential Communications:
You have the right to request that we communicate with you only in a certain manner. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must submit your request in writing to the address listed at the end of this Notice. We will accommodate all reasonable requests.
Right to a Paper Copy of This Notice:
You have the right to a paper copy of this Notice. Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy of this Notice. To obtain a paper copy of this Notice, contact the address listed at the end of this Notice. You may also obtain a copy of this Notice at our website. www.covenantcommunitycare.org
For Business Associates:
Some services at Covenant Community Care are provided through contracts with outside vendors and consultants. We may disclose PHI to our business associates to perform the services we have requested. We require our business associates by contract to appropriately safeguard your information. Revisions to This Notice: We reserve the right to revise this Notice. Any revised Notice will be effective for health information we already have about you as well as any information we receive in the future. We will post a copy of any revised Notice in this office. Any revised Notice will contain on the first page, at the top of the page, the effective date/updated date. In addition each time you visit the office we will make available for you a copy of the current Notice in effect. Complaints: If you believe your privacy rights have been violated, please contact our Compliance Officer at 313-228-0220. You may also file a complaint with the Secretary of the Department of Health and Human Services. All complaints must be submitted in writing. THIS OFFICE WILL NOT PENALIZE YOU IN ANY WAY FOR FILING A COMPLAINT. Other Uses of Health information: Other uses and disclosures of your health information not covered by this Notice of Privacy Practices will be made only with your written authorization. If you provide us such an authorization in writing to use or disclose health information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose health information about you for the reasons covered by your written authorization.
Omnibus Final Rule Update:
Final modifications to the HIPAA Privacy, Security, and Enforcement Rules mandated by the Health Information technology for Economic and Clinical Health (HITECH) Act, are as follows:
- You have the right to be notified of a data breach.
- You have the right to ask for a copy of your electronic medical record in an electronic form.
- You have the right to opt out of fundraising communications from Covenant Community Care, and Covenant Community Care cannot sell your health information without your permission.
- Certain uses of your medical data, such as use of patient information in marketing, require prior disclosure and your authorization.
- Use and Disclosure of any psychotherapy notes require your authorization. Other uses and disclosures not described in this notice will be made only with your authorization.
- If you pay in cash in full (out of pocket) for your treatment, you can instruct Covenant Community Care not to share information about your treatment with your health plan.
Compliance Officer: Jan Pillai
- Telephone: (313) 228-0220
- Address: 559 W. Grand Blvd. Detroit, MI 48216
Medical Records Administrator: Virginia Parker
- Telephone: 313-228-0217
- Address: 559 W. Grand Blvd, Detroit MI 48216