Policies - Privacy Practices

We may use and disclose your protected health information for our treatment purposes as well as the treatment purposes of other health care providers. Treatment includes the provision, coordination, or management of health care services to you by one or more health care providers. Some examples or treatment uses and disclosures include:

• During an office visit, practice physicians and other staff involved in your care may review your medical record and share and discuss your medical information with each other.
• We may share and discuss your medical information with an outside physician to whom we have referred you for care or to whom we are consulting regarding you.
• We may share and discuss your medical information with an outside laboratory, radiology facility, home health agency, durable medical equipment agency, other health care facility or provider to whom we have referred you for health care services or products.
• We may share and discuss your medical information with a hospital or other health care facility where we are admitting or treating you.
• We may use a patient sign-in sheet in the waiting area which is accessible to all patients.
• We may page patients in the waiting room when it is time for them to go to an examination room.
• We may contact you to provide appointment reminders.
• We may leave messages on your answering machine.
  

We may use and disclose your protected health information for our payment purposes as well as the payment purposes of other health care providers and health plans. Payment uses and disclosures include activities conducted to obtain payment for the care provided to you or so that you can obtain reimbursement for that care, for example, from your health insurer. Some examples of payment uses and disclosures include:

• Sharing information with your health insurer to determine whether you are eligible for coverage or whether proposed treatment is a covered service.
• Submission of a claim form to your health insurer.
• Providing supplemental information to your health insurer so that your health insurer can obtain reimbursement from another health plan under a coordination of benefits clause in your subscriber agreement.
• Sharing your demographic information (for example your address) with other health care providers who seek this information to obtain payment for health care services provided to you.
• Mailing you bills in envelopes with our practice name and return address.
• Provision of a bill to a family member or other person designated as responsible for payment for services rendered to you.
• Providing medical records and other documentation to your health insurer to support the medical necessity of a health service.
• Allowing your health insurer access to your medical record for a medical necessity or quality review audit.
• Providing consumer reporting agencies with credit information.
• Providing information to a collection agency or attorney for purposes of securing payment of a delinquent account.
• Disclosing information in a legal action for purposes of securing payment of a delinquent account.
  

We may use and disclose your protected health information for our health care operation purposes as well as certain health care operation purposes of other health care providers and health plans. Some examples of health care operation purposes include:

• Quality assessment and improvement activities.
• Population based activities relating to improving health or reducing health care costs.
• Reviewing the competency, qualifications, or performance of health care professionals.
• Conducting training programs for medical and other students.
• Accreditation, certification, licensing, and credentialing activities.
• Health care fraud and abuse detection and compliance programs.
• Conducting other medical review, legal services, and auditing functions.
• Business planning and development activities.
• Other business management and general administrative practices, such as compliance with the federal privacy rule and resolution of patient grievances.



B. Uses and disclosures for other purposes

We may use and disclose your protected health information for other purposes. This section generally describes those purposes by category. Each category includes one or more examples. Not every use or disclosure in a category will be listed. Some examples fall into more than one category not just the category under which they are listed.

3. Individuals involved in care or payment for care

We may disclose your protected health information to someone involved in your care or payment for your care, such as a spouse, a family member, or close friends. For example, if you have surgery, we may discuss your physical limitations with a family member assisting in your post-operative care. We may discuss your care or payment with involved persons as authorized by you verbally or nonverbally.

4. Notification purposes

We may use and disclose your protected health information to notify, or to assist in the notification of a family member, a personal representative, or another person responsible for your care, regarding your location, general condition, or death. For example, if you are hospitalized, we may notify a family member of the hospital and your general condition. In addition, we may disclose your protected health information to a disaster relief entity, such as the Red Cross, so that it can notify a family member, a personal representative, or another person involved in your care regarding your location, general condition, or death.

5. Required by law

We may use and disclose protected health information when required by federal state, or local law. For example, we may disclose protected health information to comply with mandatory reporting requirements involving births and deaths, child abuse, disease prevention and control, vaccine- related injuries, medical device- related deaths and serious injuries, gunshot and other injuries by a deadly weapon or criminal act, driving impairments, and blood alcohol testing.

6. Other public health activities

We may use and disclose protected health information for public health activities including:



• Public health reporting, for example, communicable disease reports.
• Child abuse and neglect reports.
• FDA-related reports and disclosures, for example, adverse event reports.
• Public health warnings to third parties at risk of a communicable disease or condition.
• OSHA requirements for workplace surveillance and injury reports.

5. Victims of abuse, neglect, or domestic violence

We may use and disclose protected health information for purposes of reporting abuse, neglect, or domestic violence in addition to child abuse, for example, reports of elder abuse to the Department of Aging or abuse of a nursing home patient to the Department of Public Welfare.

6. Health oversight activities

We may use and disclose protected health information for purposes of health oversight

activities authorized by law. These activities could include audits, inspections, investigations, licensure actions, and legal proceedings. For example, we may comply with a Drug Enforcement inspection of patient records.

7. Judicial and administrative proceedings

We may use and disclose protected health information disclosures in judicial and administrative proceedings in response to a court order or subpoena, discovery request or other lawful process. For example, we may comply with a court order to testify in a case at which your medical condition is at issue.

8. Law enforcement purposes

We may use and disclose protected health information for certain law enforcement purposes including to:

• Comply with legal process, for example, a search warrant.
• Comply with a legal requirement, for example, mandatory reporting of gunshot wounds.
• Respond to a request for information for identification/location purposes.
• Respond to a request for information about a crime victim.
• Report a death suspected to have resulted from criminal activity.
• Provide information regarding a crime on the premises.
• Report a crime in an emergency.

9. Coroner and medical examiners

We may use and disclose protected health information for purposes of providing information to a coroner or medical examiner for the purpose of identifying a decease patient, determining a cause of death, or facilitating their performance of other duties required by law.

10. Funeral Directors

We may use and disclose protected health information for purposes of providing information to funeral directors as necessary to carry out their duties.

11. Organ and tissue donation

For purposes of facilitating organ, eye and tissue donation and transplantation, we may use protected health information and disclose protected health information to entities engaged in the procurement, banking, or transplantation of cadaveric organs, eyes, or tissues.

12. Threat to public safety

We may use and disclose protected health information for purposes involving a threat to public safety, including protection of a third party from harm and identification and apprehension of a criminal. For example, in certain circumstances, we are required by law to disclose information to protect someone from imminent serious harm.

13. Specialized government functions

We may use and disclose protected health information for purposes involving specialized government functions including:

• Military and veterans’ activities.
• National security and intelligence.
• Protective services for the President and others.
• Medicare suitability determinations for the Department of State.
• Correctional institutions and other law enforcement custodial situations.

14. Workers’ Compensation and similar programs

We may use and disclose protected health information as authorized by and to the extent necessary to comply with laws relating to workers’ compensation or similar programs, established by law, that provide benefits for work-related injuries or illness without regard to fault. For example, this work includes submitting a claim for payment to your employer’s workers‘ compensation carrier if we treat you for a work injury.

15. Business associates

Certain functions of the practice are performed by a business associate such as an accountant firm, collection agency, or a law firm. We may disclose protected health information to our business associates and allow them to create and receive protected health information on our behalf. For example, we may share with our collection agency information regarding your care and payment for your care so that the company can bill you or another responsible party.

16. Creation of de-identified information

We may use protected health information about you in the process of de-identifying the information. For example, we may use your protected health information in the process of removing those aspects which could identify you so that the information can be disclosed to a researcher without your authorization.

17. Incidental disclosures

We may disclose protected health information as a by-product of an otherwise permitted use or disclosure. For example, other patients may overhear your name being paged in the waiting room.