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.
II. WE HAVE A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION (PHI).
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 can be used to identify you that we’ve created or received about your past, present, or future health condition, the provision of health care to you, or the payment for this health care. We must provide you with this notice about our privacy practices that explains how, when, and why we use and disclose your PHI. With some exceptions, we may not use or disclose any more of your PHI than is necessary to accomplish the purpose of the use or disclosure. We are legally required to follow the privacy practices that are described in this notice.
However, we reserve the right to change the terms of this notice and our privacy policies at any time. Any changes will apply to the PHI we already have. Before we make an important change to our policies, we will promptly change this notice and post a new notice in the main reception area. You can also request a copy of this notice from the contact person listed in Section IV below at any time and can view a copy of this notice on our Web site atwww.wilfcampus.org
III. HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION.
We use and disclose health information for many different reasons. For some of these uses or disclosures, we need your prior consent or specific authorization. Below, we describe the different categories of uses and disclosures.
A. Uses and Disclosures Relating to Certain Treatment Payment, or Health Care Operations that do not require your prior consent
We may use and disclose your PHI without your consent for the following reasons:
- For certain treatment. We will use your PHI to provide you with health care, and we will disclose your PHI to personnel within our facility who provide you with health care services or are involved in your care. For example, if you’re being treated for high blood pressure, we would disclose that information to our nurses and physicians. We will also disclose your PHI to personnel of another health care facility to which you may be transferred.
- To obtain certain payments for treatment and services. We may use and disclose your PHI to personnel within our facility in order to bill and collect payment for the treatment and services we provide to you. For example, we may provide portions of your PHI to our billing department in order to get paid for the health care services we provide to you. If applicable, we may also disclose your PHI to a health insurance company if you have an agreement with the insurance company which would authorize us to disclose it.
- For certain health care operations. We may use and disclose your PHI within our facility in order to operate it. For example, we may use your PHI in order to evaluate the quality of health care services that you received or to evaluate the performance of the health care professionals who provided health care services to you.
- Appointment remainders and health-related benefits or services. We may use PHI to provide appointment reminders or give you information about treatment alternatives, or other health care services or benefits we offer.
- Fund Raising. We may contact you to participate in our fund raising activity.
B. Other Uses and Disclosures Do Not Require Your Consent.
In certain instances, may use and disclose your PHI without your consent or authorization for the following reasons:
- When a disclosure is required by law, judicial or administrative proceedings, law enforcement, or because of abuse or neglect. As examples, we may make disclosures of PHI in the following instances: (a) when a law requires that we report information to a government agency about persons who have been abused or neglected; (b) when a law requires that we report information about certain types of wounds to police; and (c) when we are required to provide information in response to a court order.
- For public health activities. For example, we report information about deaths, and various diseases, to government officials in charge of collecting that information, and we provide coroners, medical examiners, and funeral directors necessary information relating to an individual’s 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. In certain circumstances, we may provide PHI in order to conduct medical research.
- To avoid harm. In order to avoid a serious threat to the health or safety of a person or the public, we may provide PHI to law enforcement personnel or persons able to prevent or lessen such harm.
- For specialized government functions. For example, in certain instances, we may be required to disclosure PHI to authorized federal officials for national security purposes.
- For worker’s compensation purposes. We may provide PHI in order to comply with workers’ compensation laws.
- We may disclose your PHI to others without your consent in certain situations. For example, your consent isn’t required if you need emergency treatment, or we try to get consent but you are unable to communicate with us (for example, if you are unconscious or in severe pain) and we think you would consent if you were able to do so.
C. Use and Disclosure Where You to Have the Opportunity to Object:
- Disclosures to family, friends, or others. We may provide your PHI to a family member, friend, or any other person you indicate that is either involved in your care or the payment for your health care, unless you object in whole or in part. If your opportunity to agree or object cannot practicably be provided because of an emergency situation, we may disclose your PHI to such a person (but only to the extent that the PHI is directly relevant to that person’s involvement with your health care) if we determine that the disclosure is in your best interests.
- Facility Directory. We may list your name, general condition, religion, and room number in our facility directory. This information is maintained for two groups of people: members of the clergy and their designees or other people who ask for you by name.
- Disclosures regarding hospitalizations. In the event that you need to be hospitalized, we may disclose to your family, friends, or other persons involved in your case, that you have been transferred to a hospital. If you object to such disclosures, please tell our Privacy Officer (see VI below)
D. Other Uses and Disclosures. Any uses or disclosures of your PHI not described above will be made only with your written authorization. You may revoke such authorization at any time, except to the extent that we have already taken action in reliance upon it.
E. Uses and Disclosures of PHI Requiring Special Authorization. We are also required to also advise you about certain uses and disclosures of PHI that require special authorization, even though they may not be applicable to you. They are as follows.
- Genetic Information. Except in certain cases (such as for a court proceeding, anonymous research, or pursuant to a court order), we must obtain your authorization prior to obtaining or retaining your genetic information (for example, your DNA sample). We may use or disclose your genetic information only when your authorization expressly refers to your genetic information or when disclosure is permitted by law.
- AIDS or HIV Related Information. If PHI contains AIDS or HIV related information, that information is confidential and shall not be disclosed without your written authorization, except as follows. Such information may be released without your authorization to medical personnel directly involved in your medical treatment. If you are deemed to lack decision-making capacity, we may release such information (only if necessary and unless you request otherwise) to the person responsible for making health care decisions on your behalf (spouse, primary caretaking partner, an appropriate family member, etc.). Under certain circumstances, such information may also be released without your authorization for scientific research, certain audit and management functions, and as may otherwise be allowed or required by law or court order.
- Alcohol or Drug Abuse Programs. If PHI contains information related to treatment provided in an alcohol or drug abuse program, that information is confidential and shall not be disclosed without your written authorization, except as follows. Under certain circumstances, such information may be released without your authorization: (1) for internal communications; (2) if there is not patient-identifying information; (3) for medical emergencies; (4) in order to report and/or investigate certain crimes; and (5) as may otherwise be allowed or required by law or court order.
IV. WHAT RIGHTS YOU HAVE REGARDING YOUR PHI.
You have the following rights with respect to your PHI:
- The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask that we limit certain uses and disclosures of your PHI. We will consider your request but we are not always legally required to agree to it. If we agree to your request, we will put any limits in writing and abide by them except in emergency situations.
- The Right to Choose How We Send PHI to You. You have the right to ask that we send PHI to you to an alternate address (for example, sending information to your work address rather than your home address) or by alternate means (for example, e-mail instead of regular mail). We must accommodate all such reasonable requests.
- The Right to See and Get Copies of Your PHI. In most cases, you have the right to look at or get copies of your PHI that we have. Request for access to PHI should be made to your Social Worker, Medical Records Department, or other Administrative Personnel. If we don’t have your PHI but we know who does, we will tell you where to direct your request. We will respond to your request to view your PHI within 24 hours after receiving your request and make photo copies available to you, or make the originals available for your review, within 2 working days. In certain situations, we may deny your request (although in that case your PHI shall be made available to your legally authorized representative, your physician, or your advanced practice nurse). If we do, we will tell you, in writing, our reasons for the denial and explain your right to have the denial reviewed. If you request copies of your PHI, we will charge you a reasonable fee. If you agree in advance, we may choose to provide you with a summary of explanation of the PHI (instead of the PHI itself) as long as you agree to the cost in advance.
- The Right to Get a List of the Disclosures We Have Made. You have the right to get a list of certain (but not all) instances in which we have disclosed your PHI. For example, the list will not include uses or disclosures made for treatment, payment, or health care operations, with a valid authorization, directly to you, to your family, or in our facility directory. The list also won’t include uses and disclosures made before April 14, 2003. We will respond within 60 days of receiving your request. The list we will give you will include disclosures made in the last six years unless you request a shorter time. The list will include the date of the disclosure, to whom PHI was disclosed (including their address, if known), a brief description of the information disclosed, and the reason for the disclosure. We will provide the list to you at no charge, but if you make more than one request within a single 12-month period, we will charge you a reasonable amount for each additional request within that same period (although in that case we will inform you in advance of the fee and provide you with an opportunity to withdraw or modify your request). Request for a list of disclosures should be made to the medical records department.
- The Right to Correct or Update Your PHI. You have the right to have us amend your PHI. We will respond within 60 days of receiving your request in writing., and you must provide a reason to support a requested amendment. If the PHI is (i) accurate and complete, (ii) not created by us, (iii) not normally available to you, or (iv) not part of our records we may deny your request. Our written denial will: state the reasons for the denial; explain your right to file a written statement of disagreement with the denial; a statement that, if you don’t file a statement of disagreement, you have the right to request that your request and our denial be attached to all future disclosures of your PHI; and provide a description of how you may complain to either us pursuant to our complaint procedure, or to the Secretary of Health and Human Services (see V below). If we approve your request, we will make the change to your PHI, tell you that we have done it, and tell others that need to know about the change to your PHI. Notwithstanding any of the foregoing, you will always have the right to attach a brief comment or statement to your medical record after it is completed.
- The Right to Get a Paper Copy of this Notice. If you agree, we may choose to provide you with this Notice by e-mail. However, even if you so agree, you still have the right, upon request, to obtain a paper copy of this Notice.
V. HOW TO COMPLAIN ABOUT OUR PRIVACY PRACTICES.
If you think that we may have violated your privacy rights, or you disagree with a decision we made about access to your PHI, you may file a complaint with the person listed in Section VI below. You also may send a written complaint to the Secretary of the Department of Health and Human Services at 200 Independence Ave., S.W.; Room 615F; Washington, DC 20201. We will take no retaliatory action against you if you file a complaint about our privacy practices.
VI. PERSON TO CONTACT FOR INFORMATION ABOUT THIS NOTICE OR TO COMPLAIN ABOUT OUR PRIVACY PRACTICES.
If you have any questions about this notice or any complaints about our privacy practices, or would like to know how to file a complaint with the Secretary of the Department of Health and Human Services, please contact: Wilf Campus Privacy Officer, at 350 Demott Lane, Somerset, NJ 732-568-1155 or at their email firstname.lastname@example.org.
VII. EFFECTIVE DATE OF THIS NOTICE.
This notice went into effect on April 14, 2003.