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.
Who Will Follow This Notice
This notice describes the privacy practices of Cornerstone Healthcare Group its affiliates and related companies, (collectively “we” or “us”) physicians on the hospital’s Medical Staff, our employees and other hospital personnel when they provide services at the hospital. This notice does not apply to health information that physicians or other providers create or maintain in their private offices.
Our Pledge Regarding Your Health Information
We understand that information about you and your health is personal. We are committed to protecting your health information. We create a record of the care and services you receive at the hospital, as well as records regarding payment for those services. We need these records to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care and payment generated or maintained by the hospital, whether made by hospital personnel or your physicians. Your physician may have different policies or notices regarding the physician’s use and disclosure of your health information created in the physician’s office or clinic.
This notice will tell you about the ways in which we may use and disclose health information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of health information.
We are required by federal law to make sure that health information that identifies you is kept private; to give you this notice of our legal duties and privacy practices with respect to health information about you; and to follow the terms of the notice that is currently in effect. We will also follow the relevant privacy laws of the state in which the hospital is located when those laws are more stringent than federal privacy laws.
How We May Use and Disclose Health Information About You
In certain situations, we must obtain your written authorization to use or disclose your health information. However, the following categories describe different ways in which we may use and disclose your health information without your written authorization. Note that every use or disclosure in a category will not be listed.
• For Treatment. We may use health information about you to provide you with treatment or other items and services. For example, we may disclose health information about you to physicians, nurses, technicians, medical students, or other hospital personnel who are involved in taking care of you at the hospital. Different departments of the hospital may share health information about you in order to coordinate your care. We may also disclose your health information to health care provider outside the hospital who are involved in your care or to which you will be discharged.
• For Payment. We may use and disclose health information about you so that the treatment and services you receive at the hospital may be billed, and that payment may be collected from you, an insurance company or another third party. For example, we may disclose information about services that you received at the hospital on an insurance claim submitted to your insurer for payment for the services.
• For Health Care Operations. We may use and disclose health information about you for health care operations. These uses and disclosures are necessary to run the hospital and to make sure that all patients receive quality care. For example, we may use health information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine health information about many hospital patients to decide what additional services the hospital should offer, what services are not needed, and whether certain new treatments are effective. As follow-up, we may disclose health information about you to physicians or healthcare providers who referred you to our hospital, or to your personal physician. We may also disclose information to physicians, nurses, technicians, students, and other hospital personnel for review and learning purposes.
• Treatment Alternatives. We may use and disclose health information to tell you about possible treatment options or alternative services that may be of interest to you or to provide appointment reminders.
• Business Associates. There are some services provided in our organization through contracts with business associates. When these services are contracted, we may disclose your health information to our business associates so that they can perform the job we’ve asked them to do. To protect your health information, however, we require the business associate to appropriately safeguard your information.
• Hospital Directory. Unless you object, we may include certain limited information about you in a hospital directory while you are a patient at the hospital. This information may include your name, location in the hospital, your general condition (e.g., fair, stable, etc.) and your religious affiliation. The directory information, except for your religious affiliation, may be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they don’t ask for you by name. This is so your family, friends and clergy can visit you in the hospital and generally know how you are doing.
• Name Placement. We may place your name on the door to your room, on a meal tray, and on pieces of equipment that you might use, including a wheelchair. This aids our staff in identifying your items in order to provide you the best possible care. Further, this practice will assist staff in locating your room and equipment. We also like to post letters we receive from our former patients on our bulletin boards to share with the staff. If you would write a letter and not want it to be included on these bulletin boards, please let us know.
• Disclosures to Persons Involved in Your Care. We may use or disclose your health information to a family member, friend or other person involved in your care or payment for your care when you are present for or available prior to the disclosure, if we (1) obtain your agreement; (2) provide you with the opportunity to object to the disclosure and you do not object; or (3) reasonably infer that you do not object to the disclosure. If you are not present, or the opportunity to agree or object to a use or disclosure cannot practicably be provided because of your incapacity or an emergency, we may exercise our professional judgment to determine whether a disclosure is in your best interests. If we disclose information to a family member, friend or other person, we would disclose only information that we believe is relevant to the person’s involvement with your care or payment for your care. In addition, if applicable, we may disclose health information about you to an entity assisting in a disaster relief effort.
• As Required By Law. We will disclose health information about you when required to do so by federal, state or local law.
• To Avert a Serious Threat to Health or Safety. We may use and disclose health 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. Any disclosure, however, would only be to someone able to help prevent the threat.
• Additional Services or Assistance. From time to time, you may come into contact with volunteers or staff members not normally involved in your care who will need to know certain types of information about you. For example, a volunteer may deliver magazines or newspapers to patients. They would need to know when special infection control precautions might be imposed before entering your room.
The following categories describe special situations in which we may use and disclose your health information without your written authorization.
• Organ and Tissue Donation. If you are an organ donor, we may release health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.
• Military and Veterans. If you are a member of the armed forces, we may release health information about you as required by military command authorities.
• Workers’ Compensation. If applicable, we may release health information about you for workers’ compensation or similar programs.
• Public Health Risks. We may disclose health information about you for public health activities. These activities generally include the prevention or control of disease, injury or disability; reporting of abuse, deaths or problems with medications or products; and notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition.
• Health Oversight Activities. We may disclose health information to a health oversight agency for activities authorized by law. These activities are necessary for the government to monitor the health care system, government programs, and compliance with the law.
• Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order. We may also disclose health information about you in response to a subpoena, discovery request, or other lawful process served by someone else involved in the dispute.
• Law Enforcement. We may release health information if asked to do so by law enforcement officials. For example, we may release information in response to a court order, subpoena, warrant, summons or similar process; to identify or locate a suspect, fugitive, material witness, or missing person; and to report a crime and provide information about crime victims.
• Coroners, Medical Examiners and Funeral Directors. We may release health information to a coroner or medical examiner. We may also release health information about patients of the hospital to funeral directors as necessary for them to carry out their duties.
• National Security and Intelligence Activities. Under certain limited circumstances, we may release health information about you to authorized federal officials for national security activities authorized by law.
Use and Disclosure of Health Information with Your Written Authorization
Other uses and disclosures of health information not covered by this notice or permitted/required by the laws that apply to us will be made only with your written authorization. For example, we would be required to seek your written authorization before providing certain health information to a pharmaceutical company for purposes of their marketing a product to you. If you authorize us to use or disclose health information about you, you may revoke your authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose health information about you for the purposes described in the authorization. However, we are unable to take back any disclosures we have already made with your permission and are required to retain our records of the care that we provided to you.
Organized Health Care Arrangements
In our hospital, care and services are provided to you by physicians and other practitioners on our Medical Staff, pharmacists, therapists, dieticians and other health care providers. Although these Medical Staff members are not employees of the hospital and are independent from the hospital, they cooperate to provide an integrated system of care to you. This type of integrated health care setting in which you receive care from more than one health care provider is called an organized health care arrangement (“OHCA”). We may share your health information with the providers in the OHCA for treatment, payment and health care operations of the OHCA. For example, members of the OHCA may participate in committees that review the quality of services provided in the hospital. This notice of privacy practices describes how we use and disclose your health information; however, you will receive separate notices of privacy practices from the other participants in the OHCA when they provide care to you outside the hospital, and each participant will separately address any questions or requests you might have with regard to your privacy.
Your Rights Regarding Medical Information About You
You have the following rights regarding health information we maintain about you:
• Right to Inspect and Copy. You have the right to inspect and copy your medical records, billing records, and other records that may be used to make decisions about your care or payment for your care. Usually, this includes your medical and billing records, but does not include any psychotherapy notes.
To inspect and copy your health information, you must submit your request in writing to the hospital CEO. 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 except as limited by state or federal law.
We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to health information, you may request that the denial be reviewed if the denial is made for certain reasons. Another licensed healthcare professional chosen by the hospital will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.
• Right to Amend. If you feel that health information in your medical records, billing records or other records used to make decisions about your care or payment for your care 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 hospital. To request an amendment, your request must be made in writing and submitted to the hospital CEO. In addition, you must provide a reason that supports your request.
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: (1) was not created by us, unless the person or entity that created the information is no longer available to make the amendment; (2) is not part of the health information kept by or for the hospital; (3) is not part of the information which you would be permitted to inspect and copy; or (4) 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 of your health information outside the hospital. To request this list, you must submit your request in writing to the hospital CEO. Your request must state a time period which may not be longer than six years and may not include dates before April 14, 2003. 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 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 health information we use or disclose about you for treatment, payment or health care operations purposes. You may also request a limit on the health information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. 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 emergency treatment.
To request restrictions, please make your request in writing to the hospital CEO. In your request, please tell us (1) what information you want to limit; (2) whether you want to limit our use inside the hospital, disclosure outside the hospital or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.
• Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we send all bills to a certain address. To request confidential communications, you must make your request in writing to the hospital CEO. We will not ask you the reason for your request. We will 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. To obtain a paper copy of this notice contact the hospital CEO or you may get a copy from your Case Manager.
Change to This Notice
• We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for health 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 in the hospital and on our website. Any revised notice will contain the effective date on the first page, in the top right hand corner.
Questions and Complaints
If you have a question about this notice or believe your privacy rights have been violated, you may contact the hospital’s CEO, Privacy Officer, or Corporate Compliance Hotline at 1-866-478-9319 to ask your question or file a complaint. In addition, you may file a complaint with the Office of Civil Rights of the Department of Health and Human Services. Contact information for the Office of Civil Rights is available upon request. You will not be penalized in any way for filing a complaint.