This Notice of Our Privacy Practices (this “Notice”) Explains:
1. How we may use and disclose your health information in the course of providing treatment and services to you.
2. What rights you have with respect to your health information. These include the right:
o To inspect and obtain a copy of your health information.
o To request that we amend health information in our records.
o To receive an accounting of certain disclosures we have made of your health information.
o To request that we restrict the use and disclosure of your health information.
o To request confidential communication about health information.
o To receive a paper copy of this Notice.
· How to file a complaint if you believe your privacy rights have been violated.
Our Commitment Regarding Health Information
We are committed to protecting the privacy of “protected health information” about you, as that term is defined in the privacy regulations issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). With certain limited exceptions, protected health information is generally defined as information that identifies an individual or that reasonably can be used to identify an individual, and that relates to the individual’s past, present, or future health or condition, healthcare provided to the individual, or the past, present, or future payment for healthcare provided to the individual. For simplicity, we will refer to protected health information simply as “health information” in this Notice.
Our privacy practices concerning your health information are as follows:
· We will safeguard the privacy of health information that we have created or received as required by law.
· We will explain how, when and why we use and/or disclose your health information.
· We will comply with the provisions of this Notice and only use and/or disclose your health information as described in this Notice.
· We will provide notice of a DHE breach of unsecured health information.
Who Will Follow This Notice?
This Notice applies to the facilities, providers and workforce members of the WACC, including:
· Any health care professional authorized to enter health information into your medical record.
· All departments and units of the facility.
· All employees, staff, volunteers and other facility personnel.
· All hospitals, ambulatory surgery centers, clinics, ancillary provider locations, and other healthcare facilities and administrative offices of the facility.
How We May Use and Disclose Your Health Information
The following categories describe different ways that we may use and disclose health information. For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose health information will fall within at least one of the categories.
For Treatment. We may use your health information to provide, coordinate or manage your healthcare treatment and related services. This may include communication with other healthcare providers regarding your treatment and coordinating and managing your healthcare with others.
For Payment. We may use and disclose your health information in order to bill and collect payment for treatment and services provided to you by the facility. We may also disclose your health information to other providers so they may bill and collect payment for treatment and services they provided to you. Before you receive scheduled services, we may share health information about these services with your health plan(s) to obtain prior approval or to determine whether your insurance will cover the treatment. We may also share your health information with billing and collection departments or agencies, insurance companies and health plans to collect payment for services, departments that review the appropriateness of the care provided and the costs associated with that care and consumer reporting agencies (e.g., credit bureaus).
For Health Care Operations. We may use and disclose your health information to conduct activities that are called healthcare operations that allow us to improve the quality of care we provide and reduce healthcare costs. Examples of uses and disclosures for healthcare operations include the following:
· Reviewing and improving the quality, efficiency and cost of care that we provide to you and other patients.
· Evaluating the skills, qualifications, and performance of healthcare providers taking care of you.
· Providing training programs for students, trainees, healthcare providers or non-healthcare professionals (for example, billing clerks) to help them practice or improve their skills.
· Cooperating with outside organizations that assess the quality of care we provide. These organizations might include government agencies or accrediting bodies.
· Cooperating with outside organizations that evaluate, certify or license healthcare providers, staff or facilities in a particular field or specialty
· Sharing health information with the Bowie Police Department to maintain safety at our facilities.
· Assisting various people who review our activities. Health information may be seen by clinicians reviewing services provided to you, and by accountants, lawyers and others who assist us in complying with applicable laws.
· Conducting business management and general administrative activities related to our organizations and the services we provide.
· Resolving grievances within our organizations.
· Complying with this Notice and with applicable laws.
Contacting You. We may use and disclose health information to contact you about appointments, clinical instructions, surveys, or general communications. We may contact you by mail, telephone, email, or text message when you provide your address, telephone number, email address, or mobile phone number.
Treatment Alternatives. We may use and disclose your health information to manage and coordinate your healthcare and inform you of treatment alternatives and other health-related benefits that may be of interest to you.
Electronic Health Information Exchange (HIE). We may participate in certain HIEs that permit health care providers or other health care entities, such as your health plan or health insurer, to share your health information for treatment, payment, and other purposes permitted by law, including those described in this Notice.
The Chesapeake Regional Information System for our Patients (CRISP) is a regional health information exchange serving Maryland and D.C. As permitted by law, providers who participate with CRISP may share your health information in the exchange in order to provide faster access, better coordination of care and assist providers and public health officials in making more informed decisions. Patients may “opt-out” and disable access to your health information available through CRISP by calling 1-877-952-7477 or completing and submitting an Opt-Out form to CRISP by mail, fax or through their website at www.crisphealth.org.
We have chosen to use in the Chesapeake Regional Information System for our Patients (CRISP) in order to ACCESS information about you to provide better coordination of care. If there are healthcare records pertaining to you in the CRISP HIE, our providers may access the data to improve their medical decision-making. For example, our providers may obtain information about you such as recent hospital visits and discharge records, lab work, and prescriptions prescribed and dispensed.
While our providers may obtain information about you through the health information exchange, our providers will NOT share information about your treatment without your explicit written consent.
Please note that prescribers are required to access Public health reporting and Controlled Dangerous Substances information, as part of the Maryland Prescription Drug Monitoring Program (PDMP). If you opt out of CRISP, providers will still have access to information about your healthcare related to the prescribing and dispensing of Controlled Dangerous Substances.
Business Associates. There are some services provided in our organization through our business associates. For example, we may use a copy service to make copies of your medical record. When we hire companies to perform these services, we may disclose your health information to these companies so that they can perform the job we have asked them to perform. To protect your health information, however, we require the business associate to appropriately safeguard your health information.
As Required by Law. We will disclose your health information when required to do so by federal, state, or local law or other judicial or administrative proceedings. For example, we may disclose your health information in response to an order of a court or administrative tribunal.
To Avert a Serious Threat to Health or Safety. We may use and disclose your health information when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent or reduce the threat.
Public Health Risks. We may disclose your health information to appropriate government authorities for public health activities.
Health Oversight Activities. We may disclose your health information to a federal or state health oversight agency for oversight activities authorized by law.
Law Enforcement. We may release health information to a law enforcement official for certain law enforcement purposes.
Lawsuits and Disputes. In the course of any judicial or administrative proceeding, we may disclose your health information in response to a court or administrative order, subpoena, discovery request, or other lawful processes.
Coroners, Medical Examiners, and Funeral Directors. We may release health information to a coroner or medical examiner. This may be necessary to identify a deceased person or determine the cause of death. We may also release health information to funeral directors as necessary for them to carry out their duties.
Organ and Tissue Donation. 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.
Research. Under certain circumstances, we may use and disclose health information about you for research purposes.
Specialized Government Functions. We may disclose health information about you if it relates to military and veterans’ activities, national security and intelligence activities, protective services for the President, and medical suitability determinations of the Department of State.
Workers’ Compensation. We may release your health information for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illnesses.
Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release your health information to the correctional institution or law enforcement official. This release is required: (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; and (3) for the safety and security of the correctional institution.
Your Rights Regarding Your Protected Health Information
You have the following rights regarding the health information we maintain about you:
Right to Inspect and Copy. You have the right to inspect and obtain a copy of your health information. To inspect and copy your health information, please contact our main office for instructions on how to submit your written request. If you request a copy of the health information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We will respond to you within 30 days of receiving your written request. Under certain situations, we may deny your request in writing, describing the reason for denial and your rights to request a review of our denial.
Right to Amend. You have the right to request that we make amendments to clinical, billing and other records used to make decisions about you. Your request must be in writing and must explain your reason(s) for the amendment. We may deny your request if:
· The health information was not created by WACC unless you provide a reasonable basis for us to believe that the originator of the health information is no longer available to make the amendment.
· The health information is not part of the health information used to make decisions about you.
· We believe the health information is correct and complete.
· You would not have the right to inspect and copy the record as described above.
We will tell you in writing the reasons for the denial and describe your rights to give us a written statement disagreeing with the denial. If we accept your request to amend the health information, we will make reasonable efforts to inform others of the amendment, including persons you name that have received your health information.
Right to an Accounting of Disclosures. You have the right to receive a written list of certain disclosures we made of your health information. You may ask for disclosures made, up to six (6) years before your request.
Right to Request Restrictions. You have the right to request that we restrict the use and disclosure of your health information. We are not required to agree to your requested restrictions, except we will honor your request to not disclose to your health plan if the disclosure is for payment or healthcare operations purposes (and is not otherwise required by law) and the health information pertains solely to items or services for which you have paid out of pocket in full. If we agree to your request, there are certain situations when we may not be able to comply with your request. These situations include emergency treatment, disclosures to the Secretary of the Department of Health and Human Services, and uses and disclosures that do not require your authorization.
Right to Request Confidential Communication (Alternative Ways). You have the right to request confidential communications, i.e., how and where we contact you, about your health information. For example, you may request that we contact you at your work address or phone number. Your request must be in writing.
Right to a Paper Copy of This Notice. You have the right to a paper copy of this Notice upon request.
Contact For Questions and Complaints
If you have any questions regarding this Notice, our privacy policies or if you believe your privacy rights have been violated or you wish to file a complaint about our privacy practices, you may contact:
Privacy Officer
Washington Area Clinical Center
2905 Mitchellville Road
Suite 204
Bowie, MD 20716
You may also send a written complaint to the United States Secretary of the Department of Health and Human Services. You will not be retaliated against for filing a complaint.
Changes to This Notice
We reserve the right to change the terms of this Notice and to make new notice provisions effective for all health information that we maintain by:
· Posting the revised Notice at our facilities.
· Making copies of the revised Notice available upon request at our facility.
· Posting the revised Notice on our website, www.wacceneter.com.