HIPAA Notice of Privacy Practices

Organized Health Care Arrangement

St. Elizabeth Healthcare participates in a clinically integrated care setting in which patients typically receive healthcare from more than one healthcare provider. This arrangement is called an Organized Health Care Arrangement (or OHCA) under the federal laws governing the privacy of patient health information. This means that when you receive services at St. Elizabeth Healthcare, you may receive certain professional services from physicians on our Medical Staff, residents, and/or medical students who are independent practitioners and not employees or agents of St. Elizabeth Healthcare. These independent practitioners have agreed to abide by the terms of this Notice when providing services at St. Elizabeth Healthcare. Therefore, this Notice applies to all of your health information that is created or received as a result of being a patient at St. Elizabeth Healthcare. However, this Notice does not apply to the independent practitioners in their private offices. As a result, you will also receive Notices of Privacy Practices from these independent practitioners when they provide services in their private offices.

Who will follow this notice?

The privacy practices in this notice will be followed by any healthcare professional that treats you at any of our locations, by all departments and units of our organization (including all off-campus units or departments), and by all employed associates, staff and volunteers of our organization.

Our pledge to you

We understand that medical information about you is personal. We are committed to protecting your medical information. We create a record of the care and services you receive to provide quality care and to comply with legal requirements. This notice applies to all of your care records that we maintain, whether created by facility staff or your personal doctor. Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your medical information created in the doctor’s office.

Purpose

We are required by law to keep medical information about you private, to give you this notice of our legal duties and privacy practices with respect to your medical information, and to follow the terms of the notice that is currently in effect.

Changes to this Notice

We may change our policies at any time. Changes will apply to information we already hold, as well as new information after the change occurs. If we make a material change in our policies that affects this notice, we will change our notice and post the new notice in our facilities and on our website at www.stelizabeth.com. You may receive a copy of the current notice at any time. The effective and revised dates are listed just below the title. You will be offered a copy of the current notice each time you register. You will also be asked to acknowledge in writing that you were offered the notice.

How we may use and disclose medical information about you

Under certain circumstances, we are entitled to use or disclose your medical information without obtaining your written authorization. Some examples of when we are permitted to do this are presented below:

• Treatment
  We will use or disclose medical information about you for treatment purposes to doctors, nurses, technicians, and other caregivers in accordance with the Medical Authorization and Release that you signed and provided to us. We will make health information about you available through an electronic medical record system to healthcare providers who treat you. For example, a physician treating you for a broken leg in our facility may need to know whether you are a diabetic because diabetes slows the healing process. A nurse or diabetic counselor may discuss your medical condition with your physician.
• Payment
  We will use and disclose your medical information as necessary for payment purposes, in accordance with the Medical Authorization and Release that you signed and provided to us. For instance, we may forward information regarding your medical treatment to your insurance company to arrange payment for the services provided to you or we may use your information to prepare a bill to send to you or to the person responsible for your payment. We may use and disclose your medical information to another entity or healthcare provider for payment of the entity that receives the information. For instance, we may forward information to the ambulance company that brought you to the hospital so they can prepare a bill for you or your insurance company for the ambulance service.
• Healthcare Operations
  We may use and disclose medical information about you to support our healthcare operations. For example, we may use or disclose your medical information in order for us to review our services and to evaluate our staff’s performance. We may also use or disclose your medical information to obtain a medical consultation regarding your care or treatment.

While you are a patient in our facility, unless you tell us otherwise, we will list in the patient directory your name, your location in the hospital, and your general condition (in terms such as “fair” or “good”). We will release this information to anyone who asks about you by name. Your religious affiliation may be disclosed only to clergy members, even if they do not ask for you by name. If you do not want us to release such information, please inform the person assisting you during registration and/or admission.

Unless you tell us otherwise, we may disclose your medical information to a family member, friend, and others whom you have identified as being involved with your care. If family members or friends are present while care is being provided, we will assume you are comfortable with your companions hearing the discussion, unless you state otherwise. In a disaster situation, we also may disclose relevant protected health information to disaster relief organizations to help locate your family members or friends or to inform them of your location, condition or death.

We may use or disclose medical information about you for fundraising efforts in support of our facility, unless you tell us otherwise. We also may contact you for appointment reminders or to tell you about or recommend possible treatment options and other health-related benefits or services that may be of interest to you.

Subject to certain requirements, we are permitted or required by law to make certain other uses and disclosures of your medical information without your authorization.

For instance, we will release your medical information if we suspect child abuse or neglect, if we believe you to be a victim of abuse, neglect, or domestic violence, and as required by law to report wounds, injuries and crimes. We may disclose your medical information for public health purposes such as reporting births and deaths, and reporting information to prevent and control disease. We may disclose your medical information to a health oversight agency such as the Department of Health and Human Services for health oversight activities including, but not limited to, conducting an audit or inspection of our facility. We may also disclose your medical information to coroners and funeral directors, as well as to organ donation agencies (to facilitate organ and tissue donation and transplantation).

We may disclose medical information about you for workers’ compensation purposes if you are injured on the job. We may also disclose medical information when permitted or required by law, such as in response to a request from law enforcement officials in specific circumstances, and in response to valid judicial, administrative, or court orders. We may also disclose information about you in certain emergencies or to avert or lessen a serious threat to the health and safety of a person or the public. We may release your medical information if you are a member of the military as required by armed forces services, or if necessary for national security or intelligence activities. We may also disclose medical information for purposes of medical research studies when such use has been approved by an Institutional Review Board.

For Health Information Exchange

We may participate in one or more health information exchanges (HIEs) and may electronically share your health information for treatment, payment and healthcare operations purposes with other participants in the HIEs. HIEs allow your healthcare providers to efficiently access and use your pertinent medical information necessary for treatment and other lawful purposes. For example, we may participate in quality improvement projects with the Greater Cincinnati Health Council, HealthBridge, Inc. and/or the Health Improvement Collaborative of Greater Cincinnati in an effort to improve care and treatment related to certain diseases such as adult diabetes and pediatric asthma. If you do not opt-out of this exchange of information, we may provide your health information to the HIEs in which we participate in accordance with applicable law.

Other uses of medical information

Most uses and disclosures of psychotherapy notes (where appropriate), uses and disclosures of protected health information for marketing purposes, and disclosures that constitute a sale of protected health information require your written authorization. In any other situation not covered by this notice, we must receive your written authorization before using or disclosing your medical information. If you choose to authorize use or disclosure, you have the right to later revoke that authorization by notifying us in writing of your decision.

Your rights regarding your medical information

In most cases, you have the right to receive a copy and/or inspect the medical information we retain about you, upon written request. After the first request for copies, we may charge a fee for the cost of copying, mailing or other related supplies. If we deny your request, you may submit a written request for a review of that decision. In some circumstances, another licensed healthcare professional chosen by St. Elizabeth Healthcare may review your request and denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review. However, in some circumstances, our denial of a request by you to inspect and/or receive copies of your information is not subject to review.

You have the right to request that we amend your medical information, by submitting a request in writing that provides your reason for requesting the amendment. We have the right to deny your request if the information was not created by us, if it is not part of the medical information maintained by us, if it is not part of the information which you would be permitted to inspect and copy, or if in our opinion that record is accurate. If we deny your request, we will provide you with a written statement of the basis for the denial and a description of how you may file a written statement of disagreement. If you do not file a written statement of disagreement, you may request that your request for amendment and our written denial be provided with any future disclosures of your medical information.

You have the right to a list of those instances where we have disclosed your medical information when you submit a written request. This list will not include: disclosures made for treatment, payment or healthcare operations; disclosures made directly to you; disclosures you authorized pursuant to a signed authorization; disclosures for facility directory purposes or to persons involved in your care; and disclosures made to correctional institutions and for other law enforcement purposes. The request must state the time period desired for the accounting, which must be less than a 6-year period and start after April 14, 2003. You may receive the list in paper or electronic form. The first disclosure list request in a 12-month period is free. Additional requests may be provided for a fee. We will inform you of the fees before you incur any costs.

You also have the right to be notified if there is a breach of your unsecured protected health information.

If this notice was sent to you electronically, you have the right to a paper copy of this notice.

You have the right to request that medical information about you be communicated to you in a confidential manner, such as sending mail to a P.O. Box instead of your home address, by notifying us in writing of the specific way or location for us to use to communicate with you. We will not ask you the reason for your request. We will accommodate all reasonable requests, but we may not be able to agree to your request.

You may request, in writing, that we not use or disclose medical information about you for treatment, payment or healthcare operations or to persons involved in your care except when specifically authorized by you, when required by law, or in an emergency. You are entitled to a restriction to not disclose information to your health plan for healthcare services that we provided for which you paid us directly in full when the purpose of the disclosure is for the health plan’s payment or healthcare operations. We are not required to agree to other types of requests. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment.

All written requests or appeals should be submitted to our HIPAA Privacy Officer at St. Elizabeth Healthcare, attention HIPAA Privacy Officer, 1 Medical Village Dr., Edgewood, KY 41017.

Complaints

If you are concerned that your privacy rights may have been violated, or if you disagree with a decision we made about access to your records, you may lodge a written complaint with our Privacy Officer (listed below). Finally, you may send a written complaint to the U.S. Department of Health and Human Services Office for Civil Rights. Our Privacy Officer can provide you with the address. Under no circumstance will you be penalized or retaliated against for filing a complaint.