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.
If you have questions about this notice, please contact the Privacy Officer at Peoples Community Health Clinic, 905 Franklin St, Waterloo, IA 50703 (319) 874-3000.
OUR PLEDGE REGARDING MEDICAL INFORMATION:
We understand that medical and dental information about you and your health is personal. We are committed to protecting medical and dental information about you. We create a record of the care and services you receive at Peoples Community Health Clinic. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all records of your care generated by our Practice.
This notice will tell you about the ways in which we may use and disclose medical and dental information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical and dental information.
We are required by law to:
- Make sure that medical and dental information that identifies you is kept private;
- Give you this notice of our legal duties and privacy practices concerning medical and dental information about you; and
- Follow the terms of the notice that is currently in effect.
HOW WE MAY USE AND DISCLOSE MEDICAL AND DENTAL INFORMATION ABOUT YOU
We use and disclose medical and dental information in many ways. For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.
- For Treatment. We may use medical and dental information about you to provide you with treatment or services. We may disclose medical and dental information about you to dentists, hygienists, doctors, nurses, technicians, nursing and medical and dental students, or hospital personnel who are involved in taking care of you. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for nutritional counseling. We also may share medical and dental information about you to coordinate the different things you need, such as dental care, prescriptions, lab work and diagnostic testing. We also may disclose medical and dental information about you to people who may be involved in your medical and dental care such as family members, clergy, rehabilitation centers, etc.
- For Payment. We may use and disclose medical and dental information about you so that the treatment and services you receive at Peoples Community Health Clinic may be billed for and payment may be collected from you or on your behalf from an insurance company or a third-party payer. For example, we may need to give your health or dental plan information about testing that you received at our Practice so your health or dental plan will pay us or reimburse you for those services. We may also tell your health or dental plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
- For Health Care Operations. We may use and disclose medical and dental information about you for our Peoples Community Health Clinic operations. These uses and disclosures are necessary to run our organization and make sure that all of our patients receive quality care. For example, we may use medical and dental information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical and dental information about many Peoples Community Health Clinic patients to decide what additional services our Practice should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to dentists, hygienists, doctors, nurses, technicians, nursing and medical and dental students, and other personnel for review and learning purposes. We may also combine the medical and dental information we have with medical and dental information from other similar organizations to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical and dental information so others may use it to study health care and health care delivery without learning who the specific patients are.
- Organized Health Care Arrangement. We participate in an organized health care arrangement (OHCA) with other Community Health Centers that are members of Iowa Health Centers for Accountability West, LLC, d.b.a. IowaHealth+. The OHCA engages in clinical, operational and payment activities, such as quality assessment and improvement activities, shared purchasing, and cost savings activities. The other entities participating in the OHCA have access to your medical information for treatment, payment and health care operations purposes as described above in this Notice. We will follow this Notice of Privacy Practices with respect to all information obtained from the other organizations in the OHCA. Each of the other covered entities will follow their own Notice of Privacy Practices with respect to information obtained from us through the OHCA. Peoples Community Health Clinic is part of an organized health care arrangement including participants in OCHIN. A current list of OCHIN participants is available at ochin.org. As a business associate of Peoples Community Health Clinic, OCHIN supplies information technology and related services Peoples Community Health Clinic and other OCHIN participants. OCHIN also engages in quality assessment and improvement activities on behalf of its participants. For example, OCHIN coordinates clinical review activities on behalf of participating organizations to establish best practice standards and assess clinical benefits that may be derived from the use of electronic health record systems. OCHIN also helps participants work collaboratively to improve the management of internal and external patient referrals. Your personal health information may be shared by Peoples Community Health Clinic with other OCHIN participants or a health information exchange only when necessary for medical treatment or for the health care operations purposes of the organized health care arrangement. Health care operation can include, among other things, geocoding your residence location to improve the clinical benefits you receive. Personal health information may include past, present, and future medical information as well as information outlined in the Privacy Rules. The information, to the extent disclosed, will be disclosed consistent with the Privacy Rules or any other applicable law as amended from time to time. You have the right to change your mind and withdraw this consent, however, the information may have already been provided as allowed by you. This consent will remain in effect until it is revoked by you in writing. If requested, you will be provided with a list of entities to which your information has been disclosed.
- Appointment Reminders. We may use and disclose medical and dental information to contact you as a reminder that you have an appointment for treatment or medical care at Peoples Community Health Clinic.
- Treatment Alternatives. We may use and disclose medical and dental information to talk about or recommend possible treatment options or alternatives that may be of interest to you.
- Health Related Benefits and Services. We may use and disclose medical and dental information to tell you about health-related benefits or services that may be of interest to you.
- Consumer Board and Fundraising. We may use certain information (name, address, telephone number or e-mail information, age, date of birth, gender, health insurance status, dates of service, department of service information, treating physician information or outcome information) to contact you for the purpose of joining our Board of Directors as a Consumer Advocate and for raising money for Peoples Community Health Clinic. You will have the right to opt out of receiving such communications with each solicitation. For the same purpose, we may provide your name to our institutionally related foundation. Fundraising money will be used to expand and improve the services and programs we provide for the community. You are free to opt out of fundraising solicitation, and your decision will have no impact on your treatment or payment for services at Peoples Community Health Clinic.
- Individuals Involved in Your Care or Payment for Your Care. We may release medical and dental information about you to a friend or family member who is involved in your medical and dental care. We may also give information to someone who helps pay for your care. We may also tell your family or friends your condition and that you have been seen in our office. In addition, we may disclose medical and dental information about you to a friend or family member should an emergent situation arise while you are at our office.
- Under certain circumstances, we may use and disclose medical and dental information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical and dental information, trying to balance the research needs with patients’ need for privacy of their medical information. Before we use or disclose medical and dental information for research, the project will have been approved through this research approval process, but we may, however, disclose medical and dental information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical and dental needs, so long as the medical information they review does not leave our organization. We will always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care.
- As Required by Law. We will disclose medical and dental 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 medical and dental 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.
- For All Other Uses and Disclosures. All other uses and disclosures of information not contained in this Notice of Privacy Practices will not be disclosed without your authorization.
- Organ and Tissue Donation. If you are an organ donor, we may release medical 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 medical and dental information about you as required by military command authorities. We may also release medical and dental information about foreign military personnel to the appropriate foreign military authority.
- Workers’ Compensation. We may release medical information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.
- Public Health Risk. We may disclose medical and dental information about you for public health activities. These activities generally include 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 contracting 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. We will only make this disclosure if you agree or when required or authorized by law.
- Health Oversight Activities. We may disclose medical and dental 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 Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical and dental information about you in response to a court or administrative order. We may also disclose medical and dental information about you in response to a subpoena, discovery request, 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 medical and dental information 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;
- About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
- About a death we believe may be the result of criminal conduct;
- About criminal conduct at the Practice; 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 medical and dental 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 medical and dental information about patients to funeral directors as necessary to carry out their duties.
- National Security and Intelligence Activities. We may release medical and dental 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 medical and dental information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
- If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical and dental information about you to the correctional institution or law enforcement official. This release would be necessary: (1) for the institution to provide you with health care; (2) to protect your health and safety of the health and safety of others; or (3) for the safety and security of the correctional institution.
YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU
You have the following rights regarding medical and dental information we maintain about you:
- Right to Inspect and Copy. You have the right to inspect and copy medical and dental information that may be used to make decisions about your care. Usually, this includes medical/dental and billing records, but does not include psychotherapy notes. To inspect and copy medical and dental information that may be used to make decisions about you, you must submit your request in writing to the Privacy Officer. 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. You have the right to request electronic copies of your health information.
We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical and dental information, you may request, in writing, that the denial be reviewed. Another licensed health care professional chosen by Peoples Community Health Clinic will review your request and the denial. The person conducting the review will not be the person who previously denied your request. We will comply with the outcome of the review.
- Right to Amend. If you feel that medical and dental information, we have about you is incorrect or incomplete, you may ask us to include additional information in your medical and dental record. You have the right to request an amendment for as long as all of the information, both old and new, is kept by or for Peoples Community Health clinic. To request an amendment, your request must be made in writing and submitted to our Privacy Officer. 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:
- Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
- Is not part of the medical and dental information kept by or for our Practice;
- Is not part of the information which you would be permitted to inspect and copy; or
- 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 the disclosures we made of medical and dental information about you, excluding disclosures for the purpose of treatment, payment and healthcare operations.
To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer. Your request must state a period of time, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). 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 medical and dental information we use or disclose about you for treatment, payment, or health care operations. You also have the right to request a limit on the medical and dental 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 with emergency treatment. To request restrictions, you must make your request in writing to our Privacy Officer. 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, for example, disclosures to your spouse.
- Right to Request Confidential Communication. You have the right to request that we communicate with you about medical and dental matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.
To request confidential communications, you must make your request in writing to our Privacy officers. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must tell us how or where you wish to be contacted. If you do not tell us how or where you wish to be contacted, we do not have to comply with your request.
- Right to Restrict Release of Information for Certain Services. You have the right to restrict the disclosure of information regarding services for which you have paid in full or on an out-of-pocket basis. This information can be released only upon your written authorization.
- 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.
To obtain a paper copy of this notice, ask any of our office staff or our Privacy Officer or you may write to our Practice at Peoples Community Health Clinic, 905 Franklin Street, Waterloo, IA 50703.
- Right to Breach Notification. You have the right to be notified of any breach of your unsecured healthcare information.
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 medical and dental 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 our office. The notice will contain the effective date on the first page. In addition, we will offer you a copy of the current notice in effect by displaying that you may receive a paper copy of the notice upon request.
OTHER USES OF MEDICAL INFORMATION
Other uses and disclosures of medical and dental information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose medical and dental information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose medical and dental 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 permission, and that we are required to retain our record of the care that we provided to you.
If you believe your privacy rights have been violated, you may file a complaint with our practice or with the Secretary of the Department of Health and Human Services. To file a complaint with Peoples Community Health Clinic, please write to the Privacy Officer at Peoples Community Health Clinic, 905 Franklin Street, Waterloo, IA 50703. All complaints must be submitted in writing. We do not have a formal complaint form.
You will not be penalized for filing a complaint.