Notice of Privacy Practices
This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review this notice carefully.
Purpose of this Notice
In general, any information that concerns your health, health care, or payment for that care, is considered confidential and protected by Women’s Health Options Network (WHON). This Notice describes Women’s Health Options Network’s privacy practices, specifically how we use and disclose your medical information and what rights you have with respect to this information. This information may include your name, address, and other identifying data, or information on your health or the health services that have been or may be furnished to you. WHON requires that all of its employees, volunteers, and independent contractors comply with these privacy practices with respect to medical information that is used or disclosed by WHON.
The Use and Disclosure of Medical Information
With your consent, we may use and disclose your protected health information for most treatment, payment, and healthcare operations purposes.
Protected health information means any personal health information, including demographic information (age, family size, income, address, etc.) collected from a patient by a health care provider that could potentially identify the individual.
Treatment means the provision, coordination, or management of health care and related services. For example, information about your medical history may be sent to a laboratory that is performing a Pap test in order to assist the pathologist in making an accurate diagnosis or many of the people who work for WHON may use or disclose your health information to treat you or assist in your treatment.
Payment primarily means we may use and disclose your protected health information in order to bill and collect payment for the services and items you may receive. For example, we may contact your health insurer to certify that you are eligible for benefits and we may provide your insurer with details regarding your treatment to determine if your insurer will cover, or pay for your treatment.
Health care operations cover a range of activities that are necessary to the operations of WHON. Examples of the ways in which we may use and disclose your information for our operations are that we may use your protected health information to evaluate the quality of care you received from us or to conduct cost management and business planning activities.
Appointment reminders. We may use and disclose your protected health information to contact you and remind you of an appointment. Appointment reminders will be sent to an address selected by you. If you wish to be contacted by phone, a message would not be left on an answering machine unless directed by you to do so.
For research purposes. With your authorization, we may release your protected health care information for research purposes, such as tracking a particular disease.
We may use and disclose your PHI in the following circumstances without obtaining your prior authorization or giving you an opportunity to object. In special circumstances we may use or disclose your protected health information in the following manner.
Public health authority. We may disclose your health information to public authorities that are authorized by law to collect information for the purpose of:
- Reporting a birth, death, disease or injury, as required by law
- Reporting child abuse or about victims of neglect or domestic violence
- Preventing or controlling disease or injury
- Notifying a person regarding potential exposure to a communicable disease
- Notifying a person regarding a potential risk for spreading or contracting a disease or condition
- Reporting reactions to drugs or problems with products or devices
- Notifying individuals if a product or device they may be using has been recalled
Health oversight activities. We may disclose your protected health information to a health oversight agency for activities authorized by law. Oversight activities can include for example, investigations, inspections, audits, surveys, licensure and disciplinary actions, civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.
Lawsuits and similar proceedings. We may disclose your health care information in response to a court or administrative order if you are involved in a lawsuit or similar proceeding. We may also disclose your health care information in response to a discovery request, subpoena, or other lawful process by another party involved in a dispute, but only if we have made an effort to inform you of the request or to obtain an order protecting the information the party has requested.
Law enforcement. We may release your protected health care information if asked to do so by a law enforcement official:
- Regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement
- Concerning a death we believe has resulted from criminal conduct
- Regarding criminal conduct at our offices
- In response to a warrant, summons, court order, subpoena, or similar legal process
- To identify/locate a suspect, material witness, fugitive or missing person
- In an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity or location of the perpetrator).
Serious threats to health or safety. We may use or disclose your protected health information to avert a serious and imminent threat to a person’s or the public’s health and safety. We will only make disclosures to a person or organization able to help prevent the threat.
Notification and/or communication: With your family or for disaster relief, unless you tell us you object to such disclosures.
Military. We may disclose your protected health information if you are a member of U.S. or foreign military forces (including veterans) and if required by appropriate authorities.
National security. We may disclose your health care information to federal officials for intelligence and national security activities authorized by law. We may also disclose your information to federal officials in order to protect the President, officials or foreign heads of state, or to conduct investigations.
Inmates. We may disclose your protected health information to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official. Disclosure for these purposes would be necessary:
- for the institution to provide health care services to you,
- for the safety and security of the institution, and/or
- to protect your health and safety or the health and safety of other individuals.
Worker’s Compensation. We may share your protected health information regarding work-related illnesses and injuries in order to comply with workers’ compensation laws.
Your Individual Rights
You have a number of rights with respect to your protected health information. They include:
Confidential communication. You have the right to request that we communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than at work. In order to request a type of confidential communication, you must notify your health care provider and specify the requested method of contact, or location where you wish to be contacted.
Requesting restrictions. You have a right to request a restriction in our use or disclosure of your protected health information for treatment, payment, or health care operations. Additionally, you have the right to request that we restrict our disclosure of your protected health information to only certain individuals involved in your care or the payment for your care, such as family members and friends. We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you. In order to request a restriction to our use of your health care information, contact the Office Manager at the office where you are receiving your care. Your request must be in writing and must describe in a clear and concise fashion:
- the information you want restricted;
- whether you are requesting to limit WHON’s use, disclosure, or both; and
- to whom you want the limits to apply.
Inspection and copies. You have the right to inspect and obtain a copy of your medical records and billing records, but not including psychotherapy notes. You must submit your request to the Office Manager at the office where you are receiving your care in order to inspect and/or obtain a copy of your medical records. We must act on your request within 30 days of receipt of your request. We may charge a reasonable fee for costs of copying, mailing, labor and supplies associated with your request. We may deny your request but you may request a review of our denial by a licensed health care professional chosen by us and who was not involved in the original denial.
Amendment. You may ask us to amend your protected health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by WHON. Your request must be made in writing and submitted to the Office Manager at the office where you are receiving your care. You must provide us with a reason that supports your request for amendment. We will deny your request if you fail to submit your request in writing. Also, we may deny your request to amend information that is in our opinion:
- accurate and complete
- not part of the health care information kept by or for the practice
- not part of the health care information which you would be permitted to inspect and copy, or
- not created by us, unless the individual or entity that created the information is not available to amend the information.
Accounting of disclosures. All of our patients have the right to request an “accounting of disclosures”. An “accounting of disclosures” is a list of certain non-routine disclosures our practice has made of your health care information for non-treatment or operations purposes. Use of your protected health information as part of patient care in WHON offices is not required to be documented. Examples of this would be: the nurse practitioner sharing information with the clinic assistant; or the billing department using your information to file your insurance claim. In order to obtain an accounting of disclosures, you must submit your request in writing to the Office Manager at the office where you are receiving your care. All requests for “accounting of disclosures” must state a time period, which may not be longer than six (6) years from the date of disclosure and may not include dates before April 14, 2003. We must act on your request within 60 days of receipt. If we are unable to comply with your request within 60 days, we are permitted a 30 day extension and will notify you in writing when the accounting of disclosures will be available. The first list you request within a 12-month period is free of charge, but we may charge you for additional lists within the same 12-month period. We will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.
Right to a paper copy of this notice. You are entitled to receive a paper copy of this Notice of privacy practices. You may ask us to give you a copy of this Notice at any time.
Right to file a complaint. If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the Department of Health and Human Services. To file a complaint with us, contact the Patrick Thornton, CNM at (412) 247-5717. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
Right to provide an authorization for other uses and disclosures. WHON will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law. You may revoke an authorization at any time except to the extent we have already used or disclosed information in reliance on your authorization.
WHON is required by law to maintain the privacy of protected health information and to provide individuals with notice of our legal duties and privacy practices with respect to protected health information.
The terms of this notice apply to all records containing your health care information that are created by WHON. We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this Notice will be effective for all of your records that WHON has created in the past, or for any of your records that we may create or maintain in the future. WHON will post a copy of our current Notice in our offices in a visible location at all times, and you may request a copy of our most current Notice at any time.
If you have questions regarding this notice or our health information privacy policies, please contact the Patrick Thornton, CNM at (412) 247-5717 for further information.
We are also required to abide by this Notice.
EFFECTIVE DATE: APRIL 14, 2003
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