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Uses and Disclosures of
Protected Health Information
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 IT CAREFULLY. THE
PRIVACY OF YOUR MEDICAL INFORMATION IS IMPORTANT TO US.
Our Legal Duty
We are required by applicable federal and state laws
to maintain the privacy of your protected health information. We are also required to give you this notice
about our privacy practices, our legal duties, and your rights concerning your
protected health information. We must
follow the privacy practices that are described in this notice while it is in
effect. This notice takes effect
We reserve the right to change our privacy practices
and the terms of this notice at any time, provided that such changes are
permitted by applicable law. We reserve
the right to make the changes in our privacy practices and the new terms of our
notice effective for all protected health information that we maintain,
including medical information we created or received before we made the
changes.
You
may request a copy of our notice (or any subsequent revised notice) at any
time. For more information about our
privacy practices, or for additional copies of this notice, please contact us
using the information listed at the end of this notice.
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Uses and Disclosures of
Protected Health Information
We will use and disclose
your protected health information about you for treatment, payment, and health
care operations.
Following are examples of the types of uses and
disclosures of your protected health care information that may occur. These
examples are not meant to be exhaustive, but to describe the types of uses and
disclosures that may be made by our office.
Treatment: We will use and disclose
your protected health information
to provide, coordinate or manage your health care and any related services.
This includes the coordination or management of your health care with a third
party. For example, we would disclose your protected health information, as
necessary, to a home health agency that provides care to you. We will also
disclose protected health information to other physicians who may be treating you. For example, your protected health
information may be provided to a physician to whom you have been referred to
ensure that the physician has the necessary information to diagnose or treat
you.
In addition, we may disclose your protected health
information from time to time to another physician or health care provider
(e.g., a specialist or laboratory) who, at the request of your physician,
becomes involved in your care by providing assistance with your health care
diagnosis or treatment to your physician.
Payment: Your protected health
information will be used, as needed, to obtain payment for your health care
services. This may include certain activities that your health insurance plan
may undertake before it approves or pays for the health care services we
recommend for you, such as: making a determination of eligibility or coverage
for insurance benefits, reviewing services provided to you for protected health
necessity, and undertaking utilization review activities. For example,
obtaining approval for a hospital stay may require that your relevant protected
health information be disclosed to the health plan to obtain approval for the
hospital admission.
Health Care
Operations:
We may use or disclose, as needed, your protected health information in order
to conduct certain business and operational activities. These activities
include, but are not limited to, quality assessment activities, employee review
activities, training of students, licensing, and conducting or arranging for
other business activities.
For example, we may use a sign-in sheet at the
registration desk where you will be asked to sign your name. We may also call
you by name in the waiting room when your doctor is ready to see you. We may
use or disclose your protected health information, as necessary, to contact you
by telephone or mail to remind you of your appointment.
We will share your protected health information with
third party “business associates” that perform
various activities (e.g., billing, transcription services) for the practice.
Whenever an arrangement between our office and a business associate involves
the use or disclosure of your protected health information, we will have a
written contract that contains terms that will protect the privacy of your
protected health information.
We may use or disclose your protected health
information, as necessary, to provide you with information about treatment
alternatives or other health-related benefits and services that may be of
interest to you. We may also use and disclose your protected health information
for other marketing activities. For example, your name and address may be used
to send you a newsletter about our practice and the services we offer. We may
also send you information about products or services that we believe may be
beneficial to you. You may contact us to request that these materials not be
sent to you.
Uses and
Disclosures Based On Your Written Authorization: Other uses and disclosures of your protected health
information will be made only with your authorization, unless otherwise
permitted or required by law as described below.
You may give us written authorization to use your
protected health information or to disclose it to anyone for any purpose. If you give us an authorization, you may
revoke it in writing at any time. Your
revocation will not affect any use or disclosures permitted by your
authorization while it was in effect.
Without your written authorization, we will not disclose your health
care information except as described in this notice.
Others
Involved in Your Health Care: Unless you object, we may disclose to a
member of your family, a relative, a close friend or any other person you
identify, your protected health information that directly relates to that
person’s involvement in your health care. If you are unable to agree or object
to such a disclosure, we may disclose such information as necessary if we
determine that it is in your best interest based on our professional judgment.
We may use or disclose protected health information to notify or assist in
notifying a family member, personal representative or any other person that is
responsible for your care of your location, general condition or death.
Marketing: We may use your protected
health information to contact you with information about treatment alternatives
that may be of interest to you. We may
disclose your protected health information to a business associate to assist us
in these activities. Unless the
information is provided to you by a general newsletter or in person or is for
products or services of nominal value, you may opt out of receiving further
such information by telling us using the contact information listed at the end
of this notice.
Research;
Death; Organ Donation: We may use or disclose your
protected health information for research purposes in limited circumstances. We may disclose the protected health
information of a deceased person to a coroner, protected health examiner,
funeral director or organ procurement organization for certain purposes.
Public Health
and Safety: We may disclose your
protected health information to the extent necessary to avert a serious and
imminent threat to your health or safety, or the health or safety of
others. We may disclose your protected
health information to a government agency authorized to oversee the health care
system or government programs or its contractors, and to public health
authorities for public health purposes.
Health
Oversight: We may disclose protected health information to a health
oversight agency for activities authorized by law, such as audits, investigations
and inspections. Oversight agencies seeking this information include government
agencies that oversee the health care system, government benefit programs,
other government regulatory programs and civil rights laws.
Abuse
or Neglect: We may disclose your protected health information to a public
health authority that is authorized by law to receive reports of child abuse or
neglect. In addition, we may disclose your protected health information if we
believe that you have been a victim of abuse, neglect or domestic violence to
the governmental entity or agency authorized to receive such information. In
this case, the disclosure will be made consistent with the requirements of
applicable federal and state laws.
Food
and Drug Administration: We may disclose your protected health information to a
person or company required by the Food and Drug Administration to report
adverse events, product defects or problems, biologic product deviations; to
track products; to enable product recalls; to make repairs or replacements; or
to conduct post marketing surveillance, as required.
Criminal
Activity: Consistent with applicable federal and state laws, we may
disclose your protected health information, if we believe that the use or
disclosure is necessary to prevent or lessen a serious and imminent threat to
the health or safety of a person or the public. We may also disclose protected
health information if it is necessary for law enforcement authorities to
identify or apprehend an individual.
Required by
Law: We may use or disclose your protected health
information when we are required to do so by law. For example, we must disclose your protected
health information to the U.S. Department of Health and Human Services upon
request for purposes of determining whether we are in compliance with federal
privacy laws. We may disclose your
protected health information when authorized by workers’ compensation or
similar laws.
Process and
Proceedings: We may disclose your protected health
information in response to a court or administrative order, subpoena, discovery
request or other lawful process, under certain circumstances. Under limited circumstances, such as a court
order, warrant or grand jury subpoena, we may disclose your protected health
information to law enforcement officials.
Law
Enforcement: We may disclose limited information to a law
enforcement official concerning the protected health information of a suspect,
fugitive, material witness, crime victim or missing person. We may disclose the protected health information
of an inmate or other person in lawful custody to a law enforcement official or
correctional institution under certain circumstances. We may disclose protected health information
where necessary to assist law enforcement officials to capture an individual
who has admitted to participation in a crime or has escaped from lawful
custody.
Access: You have the right to look at
or get copies of your protected health information, with limited exceptions.
You must make a request in writing to the contact person listed herein to
obtain access to your protected health information. You may also request access
by sending us a letter to the address at the end of this notice. If you request copies, we will charge
you $.50 for each page, $10
per hour for staff time to locate and copy your protected health information,
and postage if you want the copies mailed to you. If you prefer, we will
prepare a summary or an explanation of your protected health information for a
fee. Contact us using the information
listed at the end of this notice for a full explanation of our fee structure.
Accounting of
Disclosures: You have the right to
receive a list of instances in which we or our business associates disclosed
your protected health information for purposes other than treatment, payment,
health care operations and certain other activities after
Restriction
Requests: You have the right to
request that we place additional restrictions on our use or disclosure of your
protected health information. We are not
required to agree to these additional restrictions, but if we do, we will abide
by our agreement (except in an emergency).
Any agreement we may make to a
request for additional restrictions must be in writing signed by a person
authorized to make such an agreement on our behalf. We will not be bound unless our agreement is
so memorialized in writing.
Confidential
Communication: You have the right to
request that we communicate with you in confidence about your protected health
information by alternative means or to an alternative location. You
must make your request in writing.
We must accommodate your request if it is reasonable, specifies the
alternative means or location, and continues to permit us to bill and collect
payment from you.
Amendment: You have the right to request that we amend your
protected health information. Your
request must be in writing, and it must explain why the information should be
amended. We may deny your request if we
did not create the information you want amended or for certain other
reasons. If we deny your request, we
will provide you a written explanation.
You may respond with a statement of disagreement to be appended to the
information you wanted amended. If we
accept your request to amend the information, we will make reasonable efforts
to inform others, including people or entities you name, of the amendment and
to include the changes in any future disclosures of that information.
Electronic
Notice: If you receive this notice
on our website or by electronic mail (e-mail), you are entitled to receive this
notice in written form. Please contact
us using the information listed at the end of this notice to obtain this notice
in written form.
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Questions and Complaints
If you want more information about our privacy practices or
have questions or concerns, please contact us using the information below.
If you believe that we may
have violated your privacy rights, or you disagree with a decision we made
about access to your protected health information or in response to a request
you made, you may complain to us using the contact information below. You also may submit a written complaint to
the U.S. Department of Health and Human Services. We will provide you with the address to file
your complaint with the U.S. Department of Health and Human Services upon
request.
We
support your right to protect the privacy of your protected health
information. We will not retaliate in
any way if you choose to file a complaint with us or with the U.S. Department
of Health and Human Services.
Name of Contact Person: Harris Finkelstein, Privacy Officer
Telephone: 703-858-7887 Fax: 703-858-7453
Address: