NOTICE OF PRIVACY PRACTICES

Effective April 14, 2003

 

 

THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

 

If you have any questions about this notice, please contact the Comprehensive Care Center’s Privacy Officer at (615) 321-9556.

 

HOW WE MAY USE AND SHARE INFORMATION ABOUT YOU

 

For Treatment: We may disclose or share information about you with all staff who are involved in taking care of you. We may also disclose information about you to people outside of the medical center who are involved in your care.

 

For Payment: We may use and disclose information about you to an insurance company or a third party to collect payment for services you receive here, or to get prior approval or to determine whether your health plan (insurance) will cover the treatment sought.

 

For Healthcare Operations (Administrative Functions): We may use and share your personal information in order to promote quality care and perform certain administrative functions.

 

Communications with You, Your Family, and the Community: Your information may be used to notify you for appointment reminders or for other communications, such as satisfaction surveys, or fundraising. In addition, information may be shared with your family or friends, with your approval, or if we believe it is in your best interest.

 

Research: Under certain circumstances, we may use and disclose information about you for research purposes. For any research that involves the care we provide you, we will ask for your permission and fully explain how your information will be used. Research that uses information about you will receive a special review to ensure that your privacy is protected.

 

Other Situations: There are other special situations in which we may share your information. These include disclosures required by law or for public heath purposes. These will be detailed further in this Notice of Privacy Practices.

 

OTHER USES AND DISCLOSURES OF INFORMATION NOT COVERED IN THIS NOTICE OR REQUIRED BY LAW WILL BE MADE ONLY WITH YOUR WRITTEN PERMISSION.

 

 

YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION

 

As a patient here, you have certain rights regarding the information we keep about you. Further details follow in this Notice of Privacy Practices.

 

You have a right to review and obtain copies of information we keep that may be used to make decisions about your healthcare or payment for your healthcare. If you feel that information we have about you is incorrect, you may ask us to amend our records.

 

You have the right to receive a list of certain non-routine disclosures of your information. You have the right to request restrictions on how we use and disclose your information for treatment, payment, or healthcare operations (administrative functions).

 

You have the right to request that we communicate with you in another more confidential way. If you believe your privacy rights have been violated, you should contact the Comprehensive Care Center’s Privacy Officer. You may also file a complaint with the Department of Health and Human Services. This Notice is effective April 14, 2003.

 

WHO WILL FOLLOW THIS NOTICE

 

This notice applies to all of the paper and electronic medical records of your care kept by us, whether created by Comprehensive Care Center staff or some other physician or clinician outside the Comprehensive Care Center. Physicians outside of the Comprehensive Care Center involved in your care may have different policies or notices about the use and disclosure of your health information they keep outside of the Comprehensive Care Center. This notice describes the Comprehensive Care Center’s privacy practices, those of our Medical Staff while practicing at

the Comprehensive Care Center, and those of any other Comprehensive Care Center healthcare professional, staff member, volunteer, or trainee authorized to manage your health information.

 

WAYS WE MAY USE AND DISCLOSE INFORMATION ABOUT YOU

 

The following categories describe ways that we use and disclose your health information. We cannot list every use or disclosure in a category. However, all of the ways we are permitted to use and disclose information will fall into one of the categories.

 

ROUTINE SITUATIONS

 

For Treatment. We may use information about you to provide you with medical treatment or services. We may disclose information about you to the doctors, nurses, technicians, residents, care managers and case managers, students, or other staff who take care of you at the Comprehensive Care Center. For example, a doctor treating you for a particular condition may need to know if you have diabetes, because diabetes may slow the healing process. The doctor may also need to tell the nutritionist if you have diabetes so that you may receive instruction about appropriate meals to help control your diabetes. Other departments may also share information about you in order to coordinate the different care that you need, such as prescriptions, lab work, and x-rays.

 

For Payment. We may use and disclose information about you so that the treatment and services you receive here may be billed and payment may be collected from you, an insurance company, or a third party payer. For example, we may need to give your health plan (insurance provider) information about a procedure you received here so your health plan will pay us or reimburse you for the procedure. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the cost of the

treatment. We may also allow your health plan to review your records to make sure that they have paid the correct amount to the Comprehensive Care Center.

 

For Health Care Operations. We may use and share information about you for administrative functions necessary to run the Comprehensive Care Center and promote quality care. For example, we may use your information or combine it with other clinics’ or hospitals’ patient information to review the effectiveness of our treatment and services, to evaluate the performance of our staff in caring for you, or to make decision about what additional services we should offer. We may also combine the information we have about you with information from other clinics or hospitals to compare how we are doing and see where we might make improvements in the care and services that we offer. Wherever it is practical, we may remove information that identifies you. We may also disclose information to doctors, nurses, technicians, medical students, and other trainees for education and training purposes. We may share information with business associates who provide services necessary to run the Comprehensive Care Center, such as office management software or billing agencies. We will contractually bind these third parties to protect your information as we would. We may also permit your health plan or other providers to review medical records that contain information about you to help them to improving the quality of service provided to you.

 

COMMUNICATING WITH YOU AND OTHERS INVOLVED IN YOUR CARE

 

Appointment Reminders, Notices About New Services, Other Health News. We may try to contact you to remind you of, or to cancel or reschedule, an appointment you have with us. We may also use or share your information to recommend possible treatment options or health-related services or to provide information that may be of interest to you. We may also contact you to ask about the quality of the services we have provided you.

 

Fundraising Activities. We may use your name and address to contact you in an effort to raise money for the Comprehensive Care Center. We use only your name, address, and phone number, and the dates you received treatment or services from us. If you do not want to be contacted for fundraising efforts, please notify the Administrative Assistant at the Comprehensive Care Center, 345 24th Avenue North, Suite 103, Nashville, TN 37203 (615) 321-9556.

 

Individuals Involved In Your Care Or Payment For Your Care. In certain situations, we may disclose information about you with a friend or family member who is involved in your care or the payment for your care. Whenever possible, we will allow you to designate who you would like to have involved in your care. However, in emergencies or other situations in which you are unable to indicate your preference, we may need to share information about you with other individuals or organizations to coordinate your care or notify your family.

 

Research. Under certain conditions, we may use and disclose information about you for research purposes. For example, a research study may compare the health and recovery of patients who received one medication for a particular condition to those who received another medication for the same condition. Before we use or disclose information for research, the project will be approved though a special approval process that evaluates the project and its use of information and tries to balance the research needs with the patient’s need for privacy. In most cases, if the research involves your care or the use and/or disclosure of your identifiable health information, we will obtain your permission and fully explain how your information will be used. We may allow access to your health information before the approval process to a Vanderbilt researcher who is preparing to conduct a research project. For example, a researcher might want to know how many patients have a specific medical condition. Health information used for this purpose will not leave the Comprehensive Care Center.

 

SPECIAL SITUATIONS

 

As Required By Law. We will disclose information about you when required to do so by federal or state law. For example, we may release information about you in response to a valid subpoena or for communicable disease reporting to the health department.

 

To Avert a Serious Threat to Health or Safety. We may use and disclose information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. We would only disclose this information to someone able to help to prevent the threat or harmful action. These disclosures may be to law enforcement officials to respond to a violent crime, or to protect the target of a violent crime. For example, threat of harming another individual must be reported to appropriate authorities.

 

Organ and Tissue Donation. If you are an organ donor or recipient, we may release your information to organizations that handle organ procurement or organ, eye, or tissue transplantation or to an organ donation bank, as necessary to assist the organ or tissue donation and transplantation.

Military and Veterans. If you are a member of the armed forces, we may release information about you as required by military authorities. We may also release information about foreign military personnel to the appropriate foreign military authority.

 

Workers' Compensation. We may release information about you to workers' compensation programs to provide benefits for work-related injuries or illness.

 

Public Health Risks. We may disclose information about you for public health activities. These activities may include, but are not limited to, the following:

 

•to prevent or control disease, injury or disability;

•to report births and deaths;

•to report child abuse or neglect;

•to report reactions to medications or problems with products;

•to notify people of recalls of products they may be using;

•to notify a person who may have been exposed to a disease or may be at

  risk for getting or spreading a disease or condition;

•to notify the appropriate government authority if we believe a patient has been the

  victim of abuse, neglect, or domestic violence.

 

Health Oversight Activities. We may disclose information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

 

Lawsuits and Civil Proceedings. If you are involved in a lawsuit or a dispute, we may disclose information about you in response to a court or administrative order. We may also disclose information about you in response to a subpoena or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

 

Law Enforcement. We may release information about you 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;

•If you are suspected to be a victim of a crime, generally with your permission;

•About a death we believe may be the result of criminal conduct;

•About criminal conduct at the clinic; and,

•In emergency circumstances to report a crime; the location of the crime or victims; or

  the identity, description, or location of the person who committed the crime.

 

Coroners, Medical Examiners and Funeral Directors. We may release information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release information about patients of the clinic to funeral directors as necessary to carry out their duties.

 

National Security and Intelligence Activities. We may release information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

 

Protective Services for the President and Others. We may disclose your information to authorized federal officials in order to protect the President, other authorized persons, and foreign heads of state, or to conduct special investigations.

 

Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose information about you to the correctional institution or law enforcement official. This disclosure 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.

 

YOUR RIGHTS REGARDING INFORMATION ABOUT YOU

 

You have the following rights regarding information we maintain about you:

 

Right to Inspect and Obtain Copies. You have the right to review and obtain copies of information that may be used to make decisions about your care. Usually, this includes medical and billing records, but does not include psychotherapy notes. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to information, you may request that the denial be reviewed. Another licensed health care professional

chosen by the Comprehensive Care Center will review your request and the denial. The person conducting the review will not be the same person who denied your request. We will comply with the outcome of the review. To inspect and copy information that may be used to make decisions about you, you must submit your request in writing to the Medical Records Manager. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. If your request only concerns billing information, you may call us at (615) 321-9556 and ask to speak with the Billing Specialist.

 

Right to Request Amendments. If you feel that information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for the Comprehensive Care Center. To request an amendment, your request and the reason for your request must be made in writing and submitted to Medical Records Manager. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that was not created by us, unless the person or entity that created the information is no longer available to make the amendment. In that case, we would consider the request. We may deny the request if the information is not part of the information kept by or for the Comprehensive Care Center. We may deny the request if the information is not part of the information you would be permitted to inspect and copy, or if the information is accurate and complete.

 

Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of certain disclosures made about you that were not related to the routine uses listed above. This list will not include disclosures prior to April 14, 2003, those that you have specifically authorized, or those made directly to you. You must submit your request for an accounting of disclosures in writing to the Medical Records Manager. It must state a time period that may not be longer than six years and should indicate in what form you want the list (for example, on paper versus in an electronic file). The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the estimated cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

 

Right to Request Restrictions. You have the right to request a restriction or limitation on the use or disclosure of information about you for treatment, payment, administrative functions, or with individuals involved in your care.

 

We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment. To request restrictions, you must make your request in writing to the Medical Records Manager. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure, or both; and (3) to whom you want the limits to apply.

 

Right to Request 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 at work or at a post office box. To request confidential communications, you must make your request in writing to the Medical Records Manager. We will not ask you the reason for your request. We will seek to accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

 

Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. You may obtain a copy of this notice at our website, http://www.compclinic.org, or in person at the Comprehensive Care Center reception desk. You may also request a copy from us at the Comprehensive Care Center, Medical Records Manager, 345 24th Avenue North, Suite 103, Nashville, TN 37203

 

CHANGES TO THIS NOTICE

 

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for information we already have about you as well as any information we receive in the future. We will post a copy of the current notice prominently in the Comprehensive Care Center. The notice will contain the effective date on the first page, in the top right-hand corner. We will notify you of changes at the time of your first visit following the change, when you check in at the reception desk.

 

COMPLAINTS

 

If you believe your privacy rights have been violated, you may file a complaint with the Comprehensive Care Center or with the Secretary of the Department of Health and Human Services. To file a complaint with the Comprehensive Care Center, submit your complaint in writing to us at:

 

Comprehensive Care Center

ATTENTION: Privacy Officer

345 24th Avenue North, Suite 103

Nashville, TN 37203.

 

To file a complaint with the Secretary of the Department of Health and Human Services:

 

Region IV, Office for Civil Rights

U.S. Department of Health and Human Services

Atlanta Federal Center

61 Forsyth Street, SW, Suite 3B70

Atlanta, GA 30303-8909

Telephone: (404) 562-7886. FAX (404) 562-7881. TDD (404) 331-2867

 

You will not be penalized for filing a complaint.

 

OTHER USES OF INFORMATION

 

Other uses and disclosures of information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us specific authorization to use or disclose information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain our records of the care that we provided to you.