NOTICE OF PRIVACY PRACTICES
OF SOUTHWEST GENERAL HEALTH CENTER AND ITS MEDICAL STAFF
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND
DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW
If you have any questions regarding this Notice, please contact Southwest
General Health Center’s Privacy Officer at
440-816-4719, 18697 Bagley Road, Middleburg Hts., Ohio 44130.
This Notice of Privacy Practices describes how Southwest General Health
Center, including its staff, volunteers and other members of its workforce,
physicians and other health care professionals caring for you at Southwest
General Health Center may use and share your Protected Health Information/electronic
Protected Health Information (“PHI/ePHI"). PHI/ePHI is information
that may identify you and that describes your physical or mental health
condition and your health care services. This Notice of Privacy Practices
applies to members of the Southwest Medical Staff when they provide care
for you at Southwest General Health Center, but does not apply to their
private medical practices. Southwest and its Medical Staff are cooperating
in the protection of your health information and privacy rights, but such
cooperation should not be construed to mean that the Health Center and
members of its Medical Staff are the agents or representatives of the
other, or in any way are responsible for each other’s actions or
failure to act.
We are required by law to maintain the privacy of our patients’ PHI/ePHI
and to provide you with this notice of our legal duties and privacy practices.
We are required to follow the terms of this Notice, so long as it remains
in effect. We reserve the right to change the terms of this Notice of
Privacy Practices as necessary and any new Notice will be effective for
all PHI/ePHI maintained by us. You have a right to receive a copy of the
currently effective Notice at any registration area or information desk
in the Health Center, or a copy may be obtained by mailing a request to
the Southwest General Health Center Privacy Officer, or on our website at
I. USES AND DISCLOSURES OF YOUR PHI/ePHI
Your Authorization. The ways in which we may use or share your PHI/ePHI without separate authorization
are listed below. We are prohibited from selling your PHI/ePHI without
your authorization, as well as other uses and disclosures for which the
Privacy Rule requires your authorization (i.e. marketing purposes and
disclosure of psychotherapy notes, where appropriate). We will not use
your PHI/ePHI for any other purpose unless you have signed a form authorizing
the use or disclosure. When state or federal law requires a special consent
or authorization, we will make all reasonable efforts to obtain such consent
or authorization. You have the right to revoke an authorization to release
your information if you do so in writing, however, such revocation will
not apply to any action we have taken based on your original authorization.
Uses and Disclosures without Separate Authorization
For Treatment. We may use and share your PHI/ePHI as necessary to provide, coordinate
or manage your health care treatment. We may also share your PHI/ePHI
with another health care provider who is not associated with us but who
provides medical treatment to you. For example, doctors and nurses involved
in your care may use your medical information to plan a course of treatment
for you. This information may also be shared with other health care providers,
for instance, if you are an inpatient at the Health Center and you are
to receive home health care after being discharged, we may release your
PHI/ePHI to that home health care agency so that a plan of care can be
prepared for you. We may disclose mental health PHI/ePHI (with the exception
of psychotherapy notes) under HIPAA and state law, to other health care
providers for purposes of continuity of care.
For Payment. We may use and share your PHI/ePHI as necessary to receive payment for
the health care services provided to you. For instance, we may forward
information regarding treatment you received to your insurance company
to obtain payment for the services provided to you, unless you have paid
out of pocket in full for your health care and have requested that we
restrict disclosure of your PHI/ePHI to your health plan with respect
to such information.
For Health Care Operations. We may use and share your PHI/ePHI as necessary for our health care operations
which include clinical improvement, business management, accreditation
and licensing and defending ourselves in any legal action. For instance,
your care may be reviewed at one of our quality review committees where
we regularly review care rendered to patients. We may also, as permitted
by law, share your PHI/ePHI with another health care provider, or health
plan for their health care operations.
Our Patient Directory. If you are an inpatient here or if you are at the Health Center for some
lengthy outpatient procedures, we may direct people to your room or give
your room telephone number to anyone who calls or visits the Health Center
and asks for you by name. In some circumstances, we may also give a general
statement about your medical condition (for instance “fair”
or “critical”). Your religious affiliation may also be provided
to members of the clergy. You have the right during registration to request
that we not release this information.
Family, Friends or Others Involved in Your Care. Unless you object, we may from time to time disclose your PHI/ePHI to
family, friends, and others whom you have designated or who are with you
in the Health Center and involved in your care in order to assist in their
involvement in caring for you or paying for your care. If you are unavailable
to agree or object, or are facing an emergency medical situation or in
the case of a public disaster, we may share limited PHI/ePHI with your
family and friends or to an organization that is involved in disaster
relief efforts if we believe such a disclosure is in your best interest.
Business Associates. Certain aspects of our services may at times be performed through arrangements
with outside persons or organizations, for example, auditing services;
and at times, outside persons or organizations may assist us in our care
for you. At times it may be necessary for us to provide your PHI/ePHI
to these outside persons or organizations that assist us. In all cases,
we require these business associates to safeguard the privacy of your
information in the same manner in which we are required to safeguard your privacy.
Fundraising. From time to time we may contact you to raise money as part of our charitable
fundraising efforts. You have the right to opt out of receiving fundraising
Appointments, Health Products and Services. We may contact you to remind you about an appointment, inform you about
test results or to inform you about possible treatment options and alternatives
or health-related products or services that might be of interest to you.
Alternative Means of Communication. You have the right to request we communicate with you by particular means
or locations, such as if you wish appointment reminders not to be left
on voice mail or if you do not wish for mail to be sent to your home.
We will honor reasonable requests. You should make such requests by contacting
the Southwest General Health Center Privacy Officer.
Research. In limited circumstances, we may use and share your PHI/ePHI for research
purposes. For example, a research organization may wish to compare outcomes
of all patients who received a particular drug and will need to review
a series of medical records. In all cases, either your specific authorization
will be obtained or your privacy will be protected by strict confidentiality
requirements applied by the Institutional Review Board that reviews research
conducted at the Health Center or by applicable law.
To Public Health Authorities and Government Oversight Agencies. We may release your PHI/ePHI to public health authorities for any purpose
required by law such as reporting of certain diseases and injuries, births
and deaths and for required health investigations. We may also release
your PHI/ePHI if required by law to a government oversight agency conducting
audits, licensure review or similar activities.
Abuse, Neglect and Law Enforcement. We may release your PHI/ePHI if such information causes us to suspect abuse
or neglect which we are required or permitted by law to report to authorities.
We may also release your PHI/ePHI as required by law if we believe you
are a victim of abuse, neglect or violence. We may also release your PHI/ePHI
to law enforcement officials as required or permitted by law to report
wounds, injuries and suspicion of certain crimes.
Food and Drug Administration. We may release your PHI/ePHI to the Food and Drug Administration or its
designee, if necessary, to report such things as adverse reactions, product
defects, or to participate in product recalls.
Releases to Employers. We may release your PHI/ePHI to your employer when we have provided services
to you at the request of your employer to determine workplace-related
illness or injury. We may also release your PHI/ePHI to workers’
compensation agencies, if necessary, for your workers’ compensation
Judicial and Administrative Activities. We may release your PHI/ePHI if required to do so by court order or validly
issued subpoena or for any other official judicial or governmental administrative action.
Funeral Directors/Coroners/Organ Donation Agencies. We may release your PHI/ePHI to coroners and/or funeral directors consistent
with law and we may also release your PHI/ePHI, if necessary, to arrange
an organ or tissue donation from you or a transplant for you.
For Public Health Reasons or the Safety of Others. We may release your PHI/ePHI in limited instances if we suspect a serious
threat to someone else’s or the public’s health or safety,
such as to notify persons that they have been exposed to a communicable
disease or are in danger, or in cases of investigating outbreaks of disease.
Military/National Security. We may release your PHI/ePHI as required by armed forces services if you
are a member of the military; we may also release your PHI/ePHI if required
by law for national security or intelligence activities.
Other Disclosures Required By Law. We may use your PHI/ePHI if we are otherwise required by law to share
II. RIGHTS THAT YOU HAVE
Access to Your PHI/ePHI. You have the right to inspect and request copies of your PHI/ePHI that
we keep. We will charge you a reasonable cost-based fee for such copies
and any postage. You must make such requests in writing to the Southwest
General Health Center Medical Records Department. If you are denied access
to your records, you have the right to an explanation as to the legal
basis for the denial and to object to such denial by contacting the Privacy Officer.
Amendments to Your PHI/ePHI. You have the right to request that the PHI/ePHI we maintain about you
be changed or corrected. We are not obligated to make all requested changes
but will give each request careful consideration. All requests must be
in writing and must state the reasons for the change requested. If a change
you request is made by us, we may also notify others who have copies of
the uncorrected record if we believe that such notification is necessary.
You may obtain an amendment request form from the Privacy Officer.
Accounting for Sharing of Your PHI/ePHI. You have the right to know to whom we shared your PHI/ePHI for reasons
other than your treatment, payment for our services or our operations.
The first accounting in any 12-month period is free; you will be charged
a reasonable cost-based fee for each subsequent accounting you request
within the same 12-month period. Requests must be made in writing, and
forms are available from the Privacy Officer.
Restrictions on Use and Sharing of Your PHI/ePHI. You have the right to request us to restrict how we use and release your
PHI/ePHI. We are not required to agree to your restriction request but
will attempt to accommodate reasonable requests when appropriate. You
have the right to terminate any agreed-to restriction at any time. You
also have the right to restrict disclosures of your PHI/ePHI to your health
plan with respect to health care for which you have paid out of pocket in full.
Breach Notification. You have the right to receive notification of breaches of your unsecured PHI/ePHI.
Complaints. If you believe your privacy rights have been violated, you can file a
complaint with the Privacy Officer. You may also file a complaint with
the Secretary of the U.S. Department of Health and Human Services in Washington,
D.C. within 180 days of a violation of your rights. There will be no retaliation
against you for filing a complaint.
Acknowledgment of Receipt of Notice. You will be asked to sign an acknowledgment form that you received this
Notice of Privacy Practices.
If you have questions or need further assistance regarding this Notice,
you may contact the Privacy Officer at 440-816-4719, 18697 Bagley Road,
Middleburg Hts., Ohio 44130.
This Notice of Privacy Practices is effective August 1, 2013.