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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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