BROE REHABILITATION SERVICES, INC.

(referred to in this document as “the practice”

 

NOTICE OF PRIVACY PRACTICES

 

Effective:  April 14, 2003

 

 

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.

 

This Notice of Privacy Practices is being provided to you as a requirement of the Health Insurance Portability and Accountability Act (HIPAA).  This Notice describes how we may use and disclose your protected health information to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law.  It also describes your rights to access and control your protected health information in some cases.  Your “protected health information” means any of your written and oral health information, including demographic data that can be used to identify you.  This is health information that is created or received by your health care provider, and that relates to your past, present, or future physical or mental health or condition.

 

I.                   How We May Use and Disclose Protected Health Information About You

 

The Practice will share protected health information as necessary to carry out treatment, obtain payment for treatment, or conduct health care operations.  Your protected health information may be used or disclosed only for these purposes unless the Practice has obtained your authorization or the use and disclosure is otherwise permitted by the HIPAA Privacy Regulations or State law.  Disclosures of your protected health information for the purposes described in this Notice may be made in writing, orally, or by facsimile.

 

A.                 For Treatment.  We will use and disclose your protected health information to provide, coordinate, or manage your health care and related services.  This includes the coordination or management of your health care with a third party for treatment purposes.  For example, we may disclose your protected health information to doctors, nurses, hospitals and other health facilities who become involved in your care.  We may consult with other health care providers concerning you and, as part of the consultation, share your protected health information with them.  Similarly, we may refer you to another health care provider and, as part of the referral, share your protected health information with that provider.  For example, we may conclude you need to receive services from a physician with a particular specialty.  When we refer you to that physician, we also will contact that physician’s office and provide protected health information about you to them so they have information they need to provide services for you.

 

B.                  For Payment.  Your protected health information will be used, as needed, to obtain payment for the services that we provide.  This may include billing you, your insurance company, or a third party payor.  For example, we may need to give your insurance company information about the health care services we provide to you so your insurance company will pay us for those services or reimburse you for amounts you have paid.  We also may need to provide your insurance company or a government program, such as Medicare or Medicaid, with information about your medical condition and the health care you need to receive to determine if you are covered by that insurance or program.  We may also disclose protected health information to another provider involved in your care for the other provider’s payment activities.

 

C.                 For Health Care Operations.  We may use or disclose your protected health information, as necessary, for our own health care operations in order to facilitate the function of the practice and to provide quality care to all consumers.  For example, we may use your protected health information to review the services we provide and the performance of our employees in caring for you.  We may disclose protected health information about you to train our staff, volunteers and students working in Broe Rehabilitation Services, Inc.  We also may use the information to study ways to more efficiently manage our organization.  In certain situations, we may also disclose patient information to another provider or health plan for their heath care operations.

 

D.                 How We Will Contact You.  Unless you tell us otherwise in writing, we may contact you by either telephone or by mail at either your home or your workplace.  At either location, we may leave messages for you on the answering machine or voice mail.  If you want to request that we communicate to you in a certain way or at a certain location, see the section of this Notice entitled “Right to Receive Confidential Communications”.

 

E.                  Appointment Reminders.  We may use and disclose protected health information about you to contact you to remind you of an appointment or team meeting you have with us.

 

F.                  Treatment Alternatives.  We may use and disclose protected health information about you to contact you about treatment alternatives that may be of interest to you.

 

G.                 Health Related Benefits and Services.  We may use and disclose protected health information about you to contact you about health-related benefits and services that may be of interest to you.

 

H.                 Marketing Communications.   We may use and disclose protected health information about you to communicate with you about a product or service to encourage you to purchase the product or service.  This may be:

·         To describe a health-related product or service that is provided by us;

·         For your treatment;

·         For case management or care coordination for you;

·         To direct or recommend alternative treatments, therapies, health care providers, or settings of care.

 

We may communicate to you about products and services in a face-to-face communication by us to you.  We also may communicate about products or services in the form of a promotional gift of nominal value.

 

All other use and disclosure of protected health information about you by us to make a communication about a product or service to encourage the purchase or use of a product or service will be done only with your written authorization.

 

I.                   Fundraising.  We may use and disclose protected health information about you to contact you to raise funds for Broe Rehabilitation Services, Inc.  We may disclose protected health information to a business associate of Broe Rehabilitation Services, Inc. or a foundation related to Broe Rehabilitation Services, Inc. so that business associate or foundation may contact you to raise money for the benefit of Broe Rehabilitation Services, Inc.  We will only release demographic information, such as your name and address, and the dates you received treatment or services from Broe Rehabilitation Services, Inc.  If you do not want Broe Rehabilitation Services, Inc. or its foundation to contact you for fundraising, you must notify the Privacy Officer. Contact information for the Privacy Officer is on the last page of this Notice.

 

J.                   Individuals Involved in Your Care.  We may disclose to a family member, other relative, a close personal friend, or any other person identified by you, protected health information about you that is directly relevant to that person’s involvement with your care or payment related to your care.  We also may use or disclose protected health information about you to notify, or assist in notifying, those persons of your location, general condition, or death.  If there is a family member, other relative, or close personal friend that you do not want us to disclose protected health information about you to, please tell our staff member who is providing care to you, or notify the Privacy Officer.  Contact information for the Privacy Officer is on the last page of this Notice.

 

K.                 When Legally Required.  We will disclose your protected health information when we are required to do so by any Federal, State or local law.

 

L.                  When There are Risks to Public Health.  We may disclose your protected health information for the following public activities and purposes.  This includes reporting protected health information to a public health authority that is authorized by law to collect or receive the information for the purposes of preventing or controlling disease or, one that is authorized to receive reports of child abuse and neglect.  It also includes reporting for purposes of activities related to the quality, safety, or effectiveness of a FDA regulated product or activity.

 

M.                To Report Abuse, Neglect, or Domestic Violence.  We may notify government authorities authorized by law to receive reports of abuse neglect, or domestic violence, if we believe you are a victim of abuse, neglect, or domestic violence.  This will occur to the extent the disclosure is (a) required by law; (b) agreed to by you; or (c) authorized by law and we believe the disclosure is necessary to prevent serious harm to you or to other potential victims, or, if you are incapacitated and certain other conditions are met, a law enforcement or other public official represents that immediate enforcement activity depends on the disclosure.

 

N.                  To Conduct Health Oversight Activities.  We may disclose your protected health information to a health oversight agency for activities authorized by law, including audits, investigations, inspections, licensure or disciplinary actions.  These and similar types of activities are necessary for appropriate oversight of the health care system, government benefit programs, and entities subject to various government regulations.

 

O.                  In Connection With Judicial and Administrative Proceedings.  We may disclose your protected health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal.  We also may disclose information in response to a subpoena, discovery request, or other legal process, but only if efforts have been made to tell you about the request or to obtain an order or a signed authorization protecting the information to be disclosed.

 

P.                  For Law Enforcement Purposes.  We may disclose your protected health information to a law enforcement official for law enforcement purposes as follows:

·         As required by law.

·         In response to a court order, court-ordered warrant, subpoena, summons or similar process.

·         To identify or locate a suspect, fugitive, material witness or missing person.

·         Under certain limited circumstances, when you are the victim of a crime.

·         To a law enforcement official if the practice has a suspicion that the death was the result of a criminal conduct.

·         In an emergency in order to report a crime.

 

Q.                 To Coroners, Funeral Directors, and for Organ Donation.  We may disclose protected health information to a coroner or medical examiner for purposes such as identifying a deceased person and determining cause of death.  We may also disclose protected health information to a funeral director, as authorized by law, in order to permit the funeral director to carry out their duties.  We may disclose such information in reasonable anticipation of death.  Protected health information may be used and disclosed for cadaveric organ, eye or tissue donation purposes.

 

R.                 For Research Purposes.  We may use or disclose your protected health information for research when the use or disclosure for research has been approved by an institutional review board or privacy board that has reviewed the research proposal and research protocols to address the privacy of your protected health information.

 

S.                  For Worker’s Compensation.  The practice may release your health information to comply with worker’s compensation laws or similar programs.

 

T.                  In the Event of A Serious Threat to Health or Safety.  We may, consistent with applicable law and ethical standards of conduct, use or disclose your protected health information if we believe, in good faith, that such use or disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.

 

U.                  For Specified Government Functions.  In certain circumstances, the Federal regulations authorize the practice to use or disclose your protected health information to facilitate specified government functions relating to military and veterans activities, national security and intelligence activities, protective services for the President and others, medical suitability determinations, correctional institutions and law enforcement custodial situations.

 

II.        Uses and Disclosures Permitted Without Authorization But With Opportunity to Object

 

We may disclose your protected health information to your family member or a close personal friend if it is directly relevant to the person’s involvement in your care or payment related to your care.  We can also disclose your information in connection with trying to locate or notify family members or others involved in your care concerning your location, condition or death.

 

You may object to these disclosures.  If you do not object to these disclosures or we can infer from the circumstances that you do not object or we determine, in the exercise of our professional judgment, that it is in your best interests for us to make disclosure of information that is directly relevant to the person’s involvement with your care, we may disclose your protected health information as described.

 

III.       Uses and Disclosures Which You Authorize

 

Other than as stated above, we will not disclose your health information other than with your written authorization.  You may revoke your authorization in writing at any time except to the extent that we have taken action in reliance upon the authorization.

 

IV.       Your Rights

 

You have the following rights regarding your health information:

 

A.                 Right to request restrictions.  You have the right to request a restriction or limitation on the health information we use or disclose about your for treatment, payment or health care operations.  You may also request that we restrict the uses or disclosures we make to family members or friends who may be involved in your care or for notifications purposes as described in the Notice of Privacy Practices.  Your request must state the specific restriction requested and to whom you want the restriction to apply.

 

To request a restriction, you should do so to the Privacy Officer and tell us (1) what information you want to limit; (2) whether you want to limit use or disclosure or both; and, (3) to whom you want the limits to apply (for example, disclosures to your spouse).  Contact information for the Privacy Officer is on the last page of this Notice.

 

We are not required to agree to any requested restriction.  However, if we do agree, we will follow that restriction unless the information is needed to provide emergency treatment.  Even if we agree to a restriction, either you or we can later terminate the restriction.

 

B.                  Right to receive confidential communications.  You have the right to request that we communicate with you in a certain way or at a certain location.  For example, you can ask that we only contact you by mail or at work.  We will not require you to tell us why you are asking for the confidential communication. 

 

If you want to request confidential communication, you must do so in writing to the Privacy Officer.  Contact information for the Privacy Officer is on the last page of this Notice.  Your request must state how or where you can be contacted.

 

We will accommodate your request.  However, we may, when appropriate, require information from you concerning how payment will be handled or specification of an alternative address or other method to contact you.

 

            C.         Right to inspect and copy.  With a few very limited exceptions, such as psychotherapy notes, you have the right to inspect and obtain a copy of your protected health information.  Usually, this includes medical and billing records.

 

To inspect and your health information, you may be asked to submit a written request to the Privacy Officer whose contact information is listed on the last page of this Notice.  If you request a copy of your information, we may charge you a fee for the costs of copying, mailing or other costs incurred by us in complying with your request

 

      D.         Right to amend.  You may request an amendment of protected health information about you in a designated record set for as long as we maintain this information.  In certain cases, we may deny your request for an amendment.  If we deny your request for amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal.  Requests for amendment must be in writing and must be directed to our Privacy Officer.  In this written request, you must also provide a reason to support the requested amendments.

 

            E.         Right to receive an accounting.  You have the right to request an accounting of certain disclosures of your protected health information made by the practice.  This right applies to disclosures for purposes other than treatment, payment or health care operations as described in this Notice of Privacy Practices.  We are also not required to account for disclosures that you requested, disclosures that you agreed to by signing an authorization form, disclosures for a facility directory, to friends or family members involved in your care, or certain other disclosures we are permitted to make without your authorization.  The request for an accounting must be made in writing to our Privacy Officer.  The request should specify the time period sought for the accounting.  We are not required to provide an accounting the disclosures that take place prior to April 14, 2003.  Accounting requests may not be made for periods of time in excess of six years.  We will provide the first accounting you request during any 12-month period without charge.  Subsequent accounting requests may be subject to a reasonable cost-based fee.

 

            F.         Right to obtain a paper copy of this notice.  Upon request, we will provide a separate paper copy of this notice even if you have already received a copy of the notice or have agreed to accept this notice electronically.

 

V.         Our Duties

 

The practice is required by law to maintain the privacy of your health information and to provide you with this Notice of our duties and privacy practices.  We are required to abide by terms of this Notice as may be amended from time to time.  We reserve the right to change the terms of this Notice and to make the new Notice provisions effective for all protected health information that we maintain.  If the practice changes its Notice, we will provide a copy of the revised Notice by sending a copy of the Revised Notice via regular mail or through in-person contact.

 

VI.       Complaints

 

You have the right to express complaints to the practice and to the Secretary of Health and Human Services if you believe that your privacy rights have been violated.  You may complain to the practice by contacting the practice’s Privacy Officer verbally or in writing, using the contact information below.  You will not be retaliated against in any way for filing a complaint.

 

VII.      Contact Person

 

The practice’s contact person for all issues regarding patient privacy and your rights under the Federal privacy standards is the Privacy Officer.  Information regarding matters covered by this Notice can be requested by contacting the Privacy Officer.  Complaints against the practice can be made to the Privacy Officer at (248) 474-2763, or by sending it to:

            Broe Rehabilitation Services, Inc.

            Attn:  Privacy Officer

            33634 W. Eight Mile Rd.

            Farmington Hills, MI   48335      

 

IX.       Effective Date

This Notice is effective April 14, 2003.