PPNNE HIPAA Policy
HEALTH INFORMATION PRIVACY PRACTICES
THIS NOTICE DESCRIBES:
1. HOW HEALTH INFORMATION ABOUT YOU MAY BE USED OR DISCLOSED BY Planned Parenthood of Northern New England/Vermont Women’s Choice (PPNNE/VWC), AND
2. HOW YOU CAN ACCESS THIS INFORMATION.
Effective: February 22, 2010
PLEASE REVIEW THIS NOTICE CAREFULLY
We understand that health information about you is very personal. PPNNE/VWC takes your privacy rights very seriously. All employees and volunteers must sign a confidentiality agreement when hired. A Federal Law called HIPAA, the Health Insurance Portability and Accountability Act, was created to support your privacy and rights surrounding your health information. PPNNE/VWC is required by HIPAA to maintain the privacy of your health information and to provide you with this Notice that explains our privacy practices and our legal duties concerning your health information. We must abide by the terms of this Notice.
WHAT IS HEALTH INFORMATION?
Health information is recorded every time you seek treatment from a health care provider or visit a health center. Typically, health information contains your symptoms, examination and test results, diagnoses, treatment, and plans for future care.
HOW WE MAY USE AND DISCLOSE (SHARE) HEALTH INFORMATION ABOUT YOU
The following three categories, Treatment, Payment, and Healthcare Operations, are the most common ways that PPNNE/VWC uses or shares your health information.
We may use and disclose health information about you to nurse practitioners, physician
assistants, doctors, nurses, health care associates, nursing and medical students, volunteers or other personnel who work within the PPNNE/VWC health center and administrative office network.
We may also disclose health information if you are hospitalized under our supervision, sent by us to a lab to perform tests, to a pharmacy to have prescriptions filled, to the hospital for x-rays, or for other treatment purposes, or if we need to refer you to a specialist for treatment.
If a healthcare provider, outside of PPNNE/VWC, requests your health information we may ask, in certain situations, for your oral or written consent before sharing the information.
We may use and disclose health information about you so that the services you received from us may be billed for and payment collected. For example, we may need to give your health insurance plan information about your office visit so they will pay us or reimburse you.
For Healthcare Operations:
We may use and disclose health information about you internally to make sure that you receive quality care. For example, we may use health information to review our services, to evaluate the performance of our staff, or to review your records if you file a complaint.
OTHER WAYS WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU:
1) Other times when PPNNE/VWC may disclose your health information:
§ Public Health Information (these are all required by state or federal law):
o To report birth, death and abortion (name not included) data;
o To report abuse or neglect of minors;
o To report reactions to medications or problems with products;
o To report certain diseases to the health department, such as confirmed cases of chlamydia, gonorrhea, syphilis, hepatitis, AIDS, cancer.
§ Health Oversight Activities: We may disclose health information to a health oversight agency for them to make sure we are following the law. (Audits, inspections, investigations, or licensure.)
§ In an Emergency Situation: If an emergency happens to you we might need to release your health information, without your consent, to an ambulance so they can treat you. We may also disclose your health information if we feel it could prevent someone else from being hurt by you.
§ For a Worker’s Compensation claim
§ As Required By Law: We may disclose health information about you in situations not already mentioned when required to do so by federal, state, or local law.
§ For Research Purposes: We may want to review your medical records for research purposes. For example, we might want to compare two different medications to see which one worked better. We will either get your authorization to use your health information or ask an Institutional Review or Privacy Board to waive this requirement. Even with a waiver of authorization, researchers will not further share information that could identify you, such as your name.
§ Military and Veterans: If you are a member of the armed forces or are separated/discharged from military services, we may release health information about you as required by military command authorities or the Department of Veterans Affairs as may be applicable. We may also release health information about foreign military personnel to the appropriate foreign military authorities.
§ 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 healthcare; (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.
2) PPNNE/VWC will not release your health information without your written authorization:
§ The results of HIV testing;
§ For requests from life insurance companies, employers, family, friends, and other 3rd parties;
§ Before you enter into a research study;
§ If your records are requested for a common legal proceeding (lawyer or local police).
3) There may be times, listed below, when someone outside of PPNNE/VWC requests your records. Such release of information will only be made after reasonable efforts to contact you for your authorization. If we cannot contact you, we will obtain legal advice, but we may be required to release your records.
§ If we receive a court order or subpoena to produce your health information;
§ To help identify or locate a suspect, fugitive, material witness, or missing person;
§ To the State or District Attorney’s Office if you are a victim of a crime;
§ If a medical examiner requests your health information.
4) Lastly, PPNNE/VWC may contact you;
§ as a reminder that you have an appointment, or you are due for an exam or contraceptive injection
§ to ask you to fill out a survey or to join a “focus” group, in order to expand or improve our services.
Before we do, we will refer to the contact information and instructions that you fill out on the Patient Information Form.
YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU
You have the following rights to your health information:
Right to Inspect and to a Copy of your health care and billing records.
Right to Request an Amendment to your records if you feel that health information we have about you is incorrect or incomplete. Any amendment will become a permanent part of your medical record.
Right to Request a list of how we shared your health information except for treatment, payment and health care operations, as previously described on the first page of this notice.
Right to Request Restrictions on uses or sharing of your health care information in specific incidences. For example, you could ask that some of your healthcare information not be sent to an outside health care provider.
These requests must be made in writing on a form provided by us. We may, at times, deny your request.
Right to Request Confidential Communications: You have the right to ask that we contact you in a certain manner or at a certain location. For example, you can ask that we only contact you at work or by mail to a post office box. We will try to honor all reasonable requests.
Right to a Paper Copy of This Notice: You have the right to obtain a paper copy of this Notice at any time upon request. You may also obtain a copy of this Notice at our website http://www.ppnne.org/.
Right to Receive Notice of a Breach: We are required to notify you by first class mail of any breaches of Unsecured Protected Health Information (PHI) as soon as possible, but in any event, no later than 60 days following the discovery of the breach. “Unsecured PHI” is information about you that is not secured through the use of a technology or methodology identified by the Secretary of the U.S. Department of Health and Human Services to render the PHI unusable, unreadable, and undecipherable to unauthorized users. The notice to you is required to include the following information:
• a brief description of the breach, including the date of the breach and the date of its discovery, if known. A breach is a failure to maintain proper privacy of your health information;
• a description of the type of Unsecured Protected Health Information involved in the breach;
• steps you should take to protect yourself from potential harm resulting from the breach;
• a brief description of actions we are taking to investigate the breach, mitigate losses, and protect against further breaches;
• contact information, including a toll-free telephone number, Web site or postal address to permit you to ask questions or obtain additional information.
In the event the breach involves 10 or more patients whose contact information is insufficient or out of date we will post a notice of the breach on the home page of our Web site or in a major print or broadcast media. If the breach involves more than 500 patients in a state or jurisdiction, we will send notices to prominent media outlets. If the breach involves more than 500 patients, we are required to notify the Secretary of the U.S. Department of Health and Human Services. We also are required to submit an annual report to the Secretary of a breach that involved less than 500 patients during the year and will maintain a written log of breaches involving less than 500 patients.
MINORS AND PERSONS WITH GUARDIANS
Minors have all the rights outlined in this Notice with respect to health information relating to reproductive healthcare. If you are a minor or a person with a guardian obtaining healthcare that is not related to reproductive health (such as a school or sports physical), your parent or legal guardian may have the right to access your medical record and make certain decisions regarding the uses and disclosures of your health information.
CHANGES TO THIS NOTICE
We reserve the right to revise or change this Notice. A dated copy of the revised Notice will be posted.
OTHER USES OF HEALTH INFORMATION
Other uses and sharing of health information not covered by this Notice or the laws that apply to us will be made only with your written permission. If you have given us permission you may change your mind, in writing, at any time, and we will no longer use or share that health information in the manner you have requested. Information already used or shared cannot be taken back. We are required to keep the records of the care that we have given to you.
If you believe your privacy rights have been violated, you may file a complaint with us. Please contact:
PPNNE Privacy Official
183 Talcott Road, Suite 101, Williston, Vermont 05495
The Secretary of the Department of Health and Human Services.
200 Independence Avenue, S.W.
Washington, D.C. 20201
Toll Free: 1-877-696-6775
All complaints must be submitted in writing. You will not be penalized for filing a complaint.