HIPAA PRIVACY NOTICE
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.
INTRODUCTION
The Hartford GYN Center understands that your medical
information is private and confidential. Further, we are required by law to
maintain the privacy of “protected health information”. “Protected
health information” includes any individually identifiable information
that we obtain from you or others that relates to your past, present or future
physical or mental health, the health care you have received, or payment for
your health care.
As required by law, this notice provides you with information about your rights
and our legal duties and privacy practices with respect to the privacy of protected
health information. This notice also discusses the uses and disclosures we
will make of your protected health information. We must comply with the provisions
of this notice as currently in effect, although we reserve the right to change
the terms of this notice from time to time and to make the revised notice effective
for all protected health information we maintain. You can always request a
written copy of our most current privacy notice from the Hartford
Women's Center Privacy Officer.
PERMITTED USES AND DISCLOSURES
We can use or disclose your protected health information for purposes of treatment,
payment and health care operations. For each of these categories of uses
and disclosures, we have provided a description and an example below. However,
not every particular use or disclosure in every category will be listed.
Treatment means the provision, coordination or management
of your health care, including consultations between health care providers
regarding your care and referrals for health care from one health care provider
to another. For example, a doctor treating your for a broken leg may need to
know if you have diabetes because diabetes may slow the healing process. In
addition, the doctor may need to contact a physical therapist to create the
exercise regimen appropriate to your care.
Payment means the activities we undertake to obtain reimbursement
for the health care provided to you, including billing, collections, claims
management, determinations of eligibility and coverage and utilization review
activities. For example, prior to providing health care services, we may need
to provide information to your Third Party Payor about your medical condition
to determine whether the proposed course of treatment will be covered. When
we subsequently bill the Third Party Payor for the services rendered to you,
we can provide the Third Party Payor with information regarding your care if
necessary to obtain payment. Federal or State law may require us to obtain
a written release from you prior to disclosing certain protected health information
for payment purposes, and we will ask you to sign a release when necessary
under applicable law.
Health care operations means the support functions of our
practice related to treatment and payment, such as quality assurance activities,
case management, receiving and responding to patient comments and complaints,
physician reviews, compliance programs, audits, business planning, development,
management and administrative activities. For example, we may use your protected
health information to evaluate the performance of our staff when caring for
you. We may also combine health information about many patients to decide what
additional services we should offer, what services are not needed, and whether
certain new treatments are effective. In addition, we may remove information
that identifies you from your patient information so that others can use the
de-identified information to study health care and health care delivery without
learning who you are.
OTHER USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION
In addition to using and disclosing your information for treatment, payment
and health care operations, we may use your protected health information
in the following ways:
- We may contact you to provide appointment reminders for treatment or medical
care.
- We may contact you to tell you about or recommend possible treatment alternatives
or other health-related benefits and services that may be of interest to
you.
- We may disclose to your family or friends or any other individual identified
by you protected health information directly relevant to such person’s
involvement with your care or payment for your care. We may use or disclose
your protected health information to notify, or assist in the notification
of, a family member, a personal representative, or another person responsible
for your care of your location, general condition or death. If you are present
or otherwise available, we will give you an opportunity to object to these
disclosures, and we will not make these disclosures if you object. If you
are not present or otherwise available, we will determine whether a disclosure
to your family or friends is in your best interest, taking into account the
circumstances and based upon our professional judgment.
- When permitted by law, we may coordinate our uses and disclosures of protected
health information with public or private entities authorized by law or by
charter to assist in disaster relief efforts.
- We will allow your family and friends to act on your behalf to pick-up
filled prescriptions, medical supplies, X-rays, and similar forms of protected
health information, when we determine, in our professional judgment,that
it is in your best interest to make such disclosures.
- We may contact you as part of our efforts to market our practice’s
services as permitted by applicable law.
- Subject to applicable law, we may make incidental uses and disclosures
of protected health information. Incidental uses and disclosures are by-products
of otherwise permitted uses or disclosures which are limited in nature and
cannot be reasonably prevented.
- We may use or disclose your protected health information for research
purposes, subject to the requirements of applicable law. For example, a
research project may involve comparisons of the health and recovery of
all patients who received a particular medication. All research projects
are subject to a special approval process which balances research needs
with a patient’s need for privacy. When required, we will obtain
a written authorization from you prior to using your health information
for research.
- We will use or disclose protected health information about you when required
to do so by applicable law.
- (Note: In accordance with applicable law, we may disclose your
protected health information to your employer if we are retained to conduct
an evaluation relating to medical surveillance of your workplace or to
evaluate whether you have a work-related illness or injury. You will be
notified of these disclosures by your employer or the Center as required
by applicable law.
SPECIAL SITUATIONS
Subject to the requirements of applicable law, we will make the following uses
and disclosures of your protected health information:
- Organ and Tissue Donation. If you are an organ donor,
we may release health information to organizations that handle organ procurement
or organ, eye, or tissue transplantation or to an organ donation bank, as
necessary to facilitate organ or tissue donation and transplantation.
- Military and Veterans. If you are a member of the Armed
Forces, we may release health information about you as required by military
command authorities. We may also release health information about foreign
military personnel to the appropriate foreign military authority.
- Worker’s Compensation. We may release health information
about you for programs that provide benefits for work-related injuries or
illnesses.
- Public Health Activities. We may disclose health information
about you for public health activities, including disclosures:
- To prevent or control disease, injury or disability;
- To report births and deaths;
- To report child abuse and neglect;
- To persons subject to the jurisdiction of the Food and Drug Administration
(FDA) for activities related to the quality, safety, or effectiveness
of FDA-regulated products or services and to report reactions to medications
or problems with products;
- 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 that an
adult patient has been the victim of abuse, neglect or domestic violence.
We will only make this disclosure if the patient agrees or when required
or authorized by law
Health Oversight Activities. We may disclose health information
to Federal or State agencies that oversee our activities. These activities
are necessary for the government to monitor the health care system, government
benefit programs, and compliance with civil rights laws and regulatory program
standards.
- Lawsuits and Disputes. If you are involved in a lawsuit
or a dispute, we may disclose health information about you in response to
a court or administrative order. We may also disclose health information
about you in response to a subpoena, discovery request, or other lawful process
by someone else involved in the dispute, but only if the Center is given
assurances that efforts have been made by the person making the request to
tell you about the request or to obtain an order protecting the information
requested.
- Law Enforcement. We may release health 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 of a crime under certain limited circumstances;
- About a death we believe may be the result of criminal conduct;
- About criminal conduct on our premises; and
- In emergency circumstances, to report a crime, the location of the
crime or the victims, or the identity, description or location of the
person who committed the crime.
- Coroners, Medical Examiners and Funeral Directors. We
may release health information to a coroner or medical examiner. Such disclosures
may be necessary, for example, to identify a deceased person or determine
the cause of death. We may also release health information about patients
to funeral directors as necessary to carry out their duties.
- National Security and Intelligence Activities. We may
release health information about you to authorized Federal officials for
intelligence, counterintelligence, or other national security activities
authorized by law.
- Protective Services for the President and Others. We may
disclose health information about you to authorized Federal officials so
they may provide protection to the President or other authorized persons
or foreign heads of state or may 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 health
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.
- Serious Threats. As permitted by applicable law and standards
of ethical conduct, we may use and disclose protected health information
if we, in good faith, believe that the use or disclosure is necessary to
prevent or lessen a serious and imminent threat to the health or safety of
a person or the public or is necessary for law enforcement authorities to
identify or apprehend an individual.
NOTE: HIV-related information, genetic information, alcohol
and/or substance abuse records, mental health records and other specially protected
health information may enjoy certain special confidentiality protections under
applicable State and Federal law. Any disclosures of these types of records
will be subject to these protections.
OTHER USES OF YOUR HEALTH INFORMATION
Other uses and disclosures of protected health information not covered by this
notice or the laws that apply to us will be made only with your permission
in a written authorization. You have the right to revoke that authorization
at any time, provided that the revocation is in writing, except to the extent
that we already have taken action in reliance to your authorization.
YOUR RIGHTS
1. You have the right to request restrictions on our uses and disclosures of
protected health information for treatment, payment and health care operations.
However, we are not required to agree to your request. To request a restriction,
you must make your request in writing to the Clinic’s Privacy Officer.
2. You have the right to reasonably request to receive confidential communications
of protected health information by alternative means or at alternative locations.
To make such a request, you must submit your request in writing to the Clinic’s
Privacy Officer.
3. You have the right to inspect and copy protected health information contained
in your medical and billing records and in any other Clinic records used by
us to make decisions about you, except:
a. For psychotherapy notes, which are notes that have been recorded by a
mental health professional documenting or analyzing the contents of conversations
during a private counseling session or a group, joint or family counseling
session and that have been separated from the rest of the medical record;
b. For information compiled in reasonable anticipation of, or for use in,
a civil, criminal, or administrative action or proceeding;
c. For protected health information involving laboratory tests when your
access is restricted by law;
d. If you are a prison inmate, obtaining a copy of your information may
be restricted if it would jeopardize your health, safety, security, custody,
rehabilitation or that of other inmates, or the safety of any officer, employee,
or other person at the correctional institution or person responsible for
transporting you;
e. If we obtained or created protected health information as part of a research
study, your access to the health information may be restricted for as long
as the research is in progress, provided that you agreed to the temporary
denial of access when consenting to participate in the research;
f. For protected health information obtained from someone other than us
under a promise of confidentiality when the access requested would be reasonably
likely to reveal the source of the information;
In order to inspect and copy your health information, you must submit your
request in writing to the Clinic’s Privacy Officer. If you request a
copy of your health information, we may charge a fee for the costs of copying
and mailing your records, as well as other costs associated with your request.
We may also deny a request for access to protected health information
if:
- A licensed health care professional has determined, in the exercise of
professional judgment, that the access request is reasonably likely to endanger
your life or physical safety or that of another person;
- The protected health information makes reference to another person (unless
such other person is a health care provider) and a licensed health care professional
has determined, in the exercise of professional judgment, that the access
requested is reasonably likely to cause substantial harm to such other person;
or
- The request for access is made by the individual’s personal representative
and a licensed health care professional has determined, in the exercise of
professional judgment, that the provision of access to such personal representative
is reasonably likely to cause substantial harm to you or another person.
If we deny a request for access for any of the three reasons described above,
then you have the right to have our denial reviewed in accordance with the
requirements of applicable law.
4. You have the right to request an amendment to your protected health information,
but we may deny your request for amendment, if we determine that the protected
health information or record that is the subject of the request:
a. Was not created by us, unless you provide a reasonable to believe that
the originator of protected health information is no longer available to
act on the requested amendment;
b. Is not part of your medical or billing records or other records used
to make decisions about you;
c. Is not available for inspection as set forth above; or
d. Is accurate and complete.
In any event, any agreed amendment will be included as an addition to, and
not a replacement of, already existing records. In order to request an amendment
to your health information, you must submit your request in writing to the
Clinic’s Privacy Officer, along with a description of the reason for
your request.
5. You have the right to receive an accounting of disclosures of protected
health information made by us to individuals or entities other than to you
for the six years prior to your request, except for disclosures:
a. To carry out treatment, payment and health care operations as provided
above;
b. Incident to a use or disclosure otherwise permitted or required by applicable
law;
c. Pursuant to a written authorization obtained from you;
d. To persons involved in your care or for other notification purposes as
provided by law;
e. For national security or intelligence purposes as provided by law;
f. To correctional institutions or law enforcement officials as provided
by law;
g. As part of a limited data set as provided by law; or
h. That occurred prior to April 14, 2003.
To request an accounting of disclosure of your health information, you must
submit your request in writing to the Clinic’s Privacy Officer. Your
request must state a specific time period for the accounting (e.g. the three
months). The first accounting you request within a twelve (12) month period
will be free. For additional accountings, we may charge you for the costs of
providing the list. We will notify you of the costs involved, and you may choose
to withdraw or modify your request at that time before any costs are incurred.
COMPLAINTS
If you believe that your privacy rights have been violated, you should immediately
contact the Clinic’s Privacy Officer. We will not take action against
you for filing a complaint. You also may file a complaint with the Secretary
of Health and Human Services.
CONTACT PERSON
If you have any questions or would like further information about this notice,
please contact the Hartford GYN Center Privacy Officer.
This notice is effective as of April 13, 2003