HIPAA 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.
EFFECTIVE DATE: SEPTEMBER 23, 2013
Our Health System’s Pledge to You
This notice is intended to inform you of the privacy practices followed by Wyoming County Community Health System. Individually identifiable information about your past, present, or future health or condition, the provision of health care to you, or payment for the health care is considered “Protected Health Information” (PHI). We are required to extend certain protections to your PHI, and to give you this notice about our privacy practices that explains how, when, and why we may use or disclose your PHI. Except in specified circumstances, we must use or disclose only the minimum necessary PHI to accomplish the purpose of the use or disclosure.
We are required to follow the privacy practices described in this notice, though we reserve the right to change our privacy practices and the terms of this notice at any time. If we do so, we will post a new notice in all registration areas. You may request a copy of the new notice from any patient registration area, and it will also be posted on our website at www.wcchs.net.
The privacy practices described in this notice will be followed by all employees, medical staff, trainees, students and volunteers at any of our locations.
Uses and Disclosures of Health Information
Health Care Operations. We use and disclose health information about you in order to perform plan administration functions such as quality assurance activities, resolution of internal grievances, and evaluating plan performance. For example, we review claims experience in order to understand participant utilization and to make plan design changes that are intended to control health care costs.
Payment. We may also use or disclose identifiable health information about you without your written authorization in order to determine eligibility for benefits, seek reimbursement from a third party, or coordinate benefits with another health plan under which you are covered. For example, a health care provider that provided treatment to you will provide us with your health information.
Treatment. We may disclose your PHI to doctors, nurses, and other health care personnel who are involved in providing your health care. For example, your PHI will be shared among members of your treatment team, or with our central Pharmacy Department.
As permitted or required by law. We may also use or disclose your health information without your written authorization for other reasons as permitted by law. We are permitted by law to share information, subject to certain requirements, in order to communicate information on health-related benefits or services that may be of interest to you, respond to a court order, or provide information to further public health activities (e.g. preventing the spread of disease) without your written authorization. We are also permitted to share health information during a corporate restructuring such as a merger, sale, or acquisition. We will also disclose health information about you when required by law, for example, in order to prevent serious harm to you or others.
Fundraising Activities. We may use information about you to contact you in an effort to raise money for our health system and its operations with disclosure to Wyoming Community Hospital Foundation. This will exclude all patients receiving Behavioral Health Services. Information released will be limited to your name, address and phone number and the dates you received treatment or services. If you do not want to be contacted for fundraising efforts, you must notify the system’s Privacy Officer in writing.
Uses and Disclosures That Require your Authorization. Without your authorization, we are expressly prohibited to use or disclose your protected health information for marketing purposes. We may not sell your protected health information without your authorization. We may not use or disclose most psychotherapy notes contained in your protected health information. We will not use or disclose any of your protected health information that contains genetic information that will be used for underwriting purposes.
Uses and Disclosures Not Requiring Consent or Authorization. The law provides that we may use/disclose your PHI without consent or authorization in the following circumstances:
When required by law. We may disclose PHI when a law requires that we report information about suspected abuse, neglect, or domestic violence, or relating to suspected criminal activity, or in response to a court order. We must also disclose PHI to authorities who monitor compliance with these privacy requirements.
For Public health activities. We may disclose PHI when we are required to collect information about disease or injury, or to report vital statistics to the public health authority.
For Health oversight activities. We may disclose PHI to another agency responsible for monitoring the health care system for such purposes as reporting or investigation of unusual incidents.
Relating to decedents. We may disclose PHI relating to an individual’s death to coroners, medical examiners, or funeral directors, and to organ procurement organizations relating to organ, eye, or tissue donations or transplants.
For research purposes. In certain circumstances, and under supervision of a privacy board, we may disclose PHI to assist with medical/psychiatric research.
To avert threat to health or safety. In order to avoid a serious threat to health or safety, we may disclose PHI as necessary to law enforcement or other persons who can reasonably prevent or lessen the threat of harm.
For specific government functions. We may disclose PHI of military personnel and veterans in certain situations, to correctional facilities in certain situations, to government programs relating to eligibility and enrollment, and for national security reasons, such as protection of the President.
Uses and disclosures requiring you to have an opportunity to object. In the following situations, we may disclose your PHI if we inform you about the disclosure in advance and you do not object. However, if there is an emergency situation and you cannot be given your opportunity to object, disclosure may be made if it is consistent with any prior expressed wishes and disclosure is determined to be in your best interests. You must be informed and given an opportunity to object to further disclosures as soon as you are able to do so.
To families, friends, or others involved in your care. We may share with these people information directly related to your family’s, friend’s, or other person’s involvement in your care, or payment for your care. We may also share PHI with these people to notify them about your location, general condition, or death.
Patient Directories. Your name, location, general condition, and religious affiliation may be put into our patient directory for use by clergy and callers or visitors who ask for you by name.
Pursuant to your Authorization. When required by law, we will ask for your written authorization before using or disclosing your identifiable health information. If you choose to sign an authorization to disclose information, you can later revoke that authorization to cease any future uses or disclosures.
Right to Inspect and Copy. In most cases, you have a right to inspect and copy the health information we maintain about you. Your request to inspect or review your health information must be submitted in writing to the person listed below.
Right to an Accounting of Disclosures. You have a right to receive a list of instances where we have disclosed health information about you for reasons other than treatment, payment, or related administrative purposes.
Right to receive notice of a breach. We will notify you if your protected health information has been breached.
Right to Amend. If you believe that information within your records is incorrect or if important information is missing, you have a right to request that we correct the existing information or add the missing information.
Right to Request Restrictions. You may request in writing that we not use or disclose information for treatment, payment, or other administrative purposes except when specifically authorized by you, when required by law, or in emergency circumstances. We will consider your request, but are not legally obligated to agree to those restrictions.
Right to Request Confidential Communications. You have a right to receive confidential communications containing your health information. We are required to accommodate reasonable requests. For example, you may ask that we contact you at your place of employment or send communications regarding treatment to an alternate address.
Right to Request Restriction on certain disclosures to your health plan if the disclosure is purely for carrying out payment or health care operations and the requested restriction is for services paid out-of-pocket.
To receive this notice. You have a right to receive a paper copy of this Notice of Privacy Practices and or an electronic copy by email, or view our Notice of Privacy Practices on our website at www.wcchs.net.
Our Legal Duties
We are required by law to protect the privacy of your information, provide this notice about information practices, and follow the information practices that are described in this notice.
We may change our policies and this notice at any time. If we make a significant change in our policies, we will provide you with a revised copy of this notice. You can also request a copy of our notice at any time. For more information about our privacy practices, contact the person listed below.
If you have any questions or complaints, please contact:
LuAnne Roberts, Privacy Officer U.S. Department of Health & Human Services
Wyoming County Community Health System 200 Independence Avenue, S.W.
400 North Main Street -or- Washington, D.C. 20201
Warsaw, NY 14569 Toll Free Phone: 1-877-696-6775
585-786-8940, ext. 4877 web site: www.hhs.gov/ocr
Mr. Joseph McTernan, CEO
If you are concerned that we have violated your privacy rights, or you disagree with a decision we made about access to your records, you may contact the person listed above. You also may send a written complaint to the U.S. Department of Health and Human Services – Office of Civil Rights.