| When you receive services from Lifespan, you give us confidential information regarding yourself and others in your family. We create and keep a record of this private health information. We also receive additional health information from your doctor, the hospital, laboratories or other health care providers where you have received medical or health services. We consider the information we receive from you and others involved in your care very private.
We keep your records in both paper and electronic form, and we take special precautions to see that your information is not shared with others without your permission. Lifespan may use your health information for purposes of providing you treatment, obtaining payment for your care, and conducting health care operations, but we may not release or disclose this protected health information for any other purpose without your authorization. Protected Health information is defined in the Health Insurance Portability and Accountability Act of 1996 (HIPAA). To comply with HIPAA, Lifespan has established policies to guard against unnecessary disclosure of your health information. This notice serves to provide you with information about those policies.
THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED.
To Provide Treatment. Lifespan may use your health information to coordinate care within Lifespan, and with others involved in your care, such as your attending physician and other health care professionals who have agreed to assist us in coordinating care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. Lifespan also may disclose your health care information to individuals outside of the organization who are involved in your care including family members, pharmacists, suppliers of medical equipment, or other health care professionals.
To Obtain Payment. Lifespan may include your health information in invoices to collect payment from third parties for the care you receive from us. For example, we may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or Lifespan. We also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for home care and the services that will be provided to you.
To Conduct Health Care Operations. Lifespan may use and disclose health information for its own operations in order to facilitate the function of Lifespan and as necessary to provide quality care to all of our patients. Health care operations include such examples as quality assessment and improvement activities.
THE FOLLOWING IS A SUMMARY OF THE ADDITIONAL CIRCUMSTANCES IN WHICH THE HIPAA REGULATION DESCRIBES THAT YOUR HEALTH INFORMATION MAY BE USED AND OR DISCLOSED.
When Legally Required. Lifespan will disclose your health information when any Federal, State or local law requires it.
When there are Risks to Public Health. Lifespan may disclose your health information for public activities and purposes in order to:
- Conduct public health surveillance, investigations and interventions; prevent or control disease, injury or disability; and report disease, injury, vital events such as birth or death.
- Report adverse events, product defects, to track products or enable product recalls, repairs and replacements, and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
- Notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
- Notify an employer about an individual who is a member of the workforce as legally required.
To Report Abuse, Neglect Or Domestic Violence Lifespan must by law notify government authorities if we believe a patient, child or adult, is the victim of abuse, neglect or domestic violence. Lifespan will make this disclosure only when specifically required by law. In any other circumstance, the patient must agree to the disclosure.
To Conduct Health Oversight Activities. Lifespan may disclose health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. Lifespan may not disclose your health information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.
In Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose Protected Health Information about you in response to a court or administrative order. We may also disclose Protected Health Information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, if we are required to do so by State or Federal Law.
For Law Enforcement Purposes. As permitted or required by State law, Lifespan may disclose your health information to a law enforcement official for certain law enforcement purposes as follows:
- As required by law for reporting of certain types of inflicted wounds or other physical injuries pursuant to a court order, warrant, subpoena or summons or similar process.
- For the purpose of identifying or locating a suspect, fugitive, material witness or missing person.
- Under certain limited circumstances, when you are the victim of a crime.
To a law enforcement official if we have a suspicion that a patient’s death was the result of criminal conduct, including criminal conduct at a Lifespan site.
- In an emergency in order to report a crime.
To Coroners And Medical Examiners. Lifespan may disclose your health information to coroners and medical examiners for purposes of determining your cause of death or for other duties, as authorized by law.
To Funeral Directors. Lifespan may disclose your health information to funeral directors. consistent with applicable law and if necessary, to carry out their duties with respect to your funeral arrangements. If necessary to carry out their duties, Lifespan may disclose your health information prior to and in reasonable anticipation of your death.
In the Event of A Serious Threat To Health Or Safety. Lifespan may, consistent with applicable law and ethical standards of conduct, disclose your health information if we, in good faith, believe that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety, to the health and safety of our employees, or to the health and safety of the public.
For Specified Government Functions. In certain circumstances, Federal regulations authorize Lifespan to use or disclose your health information to facilitate specified government functions relating to military personnel and veterans, national security and intelligence activities, protective services for the President and others, medical suitability determinations, and relating to inmates in law enforcement custody.
For Worker’s Compensation. Lifespan may release your health information as permitted by Michigan law, for worker’s compensation or similar programs.
Business Associates. Certain of our business operations may be performed by other businesses. In order for these “business associates” to perform the required service (billing, accounting, etc.) we may need to disclose your health information to them so they can perform the job we ask them to do. To protect you, we require our business associates to safeguard your health information.
Appointment Reminders and Treatment Alternatives. Lifespan may use your health information to contact you with appointment reminders, or tell you about treatment alternatives or other health-related benefits and services that may be of interest to you.
For Fundraising Activities. Lifespan may use your name, address, and phone number to contact you about raising funds for the organization.
AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION
Other than is stated above, Lifespan will not disclose your health information without your written specific authorization. If you or your legally authorized representative authorizes Lifespan to use or disclose your health information, you may revoke that authorization in writing at any time.
YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION
You have the following rights regarding your protected health information that Lifespan creates and/or maintains in your personal records.
- Right to request restrictions. You may request restrictions on certain uses and disclosures of your health information and payment information. However, Lifespan is not required to agree to your request. If you wish to make a request for restrictions, please contact Lifespan.
- Right to receive confidential communications. You have the right to receive confidential communications of Protected Health Information by alternative means or at alternative locations. Lifespan will accommodate reasonable requests.
- Right to inspect and copy your health information. You have the right to inspect and/or copy your health information, including billing records. A request to inspect and/or receive a copy of your records containing your health information may be made to the Lifespan records manager at the address listed at the end of this notice. Lifespan may charge a cost-based fee for copying and assembling costs associated with your request.
- Right to amend health care information. You or your legally authorized representative has the right to request that Lifespan amend your records, if you believe that your protected health information is incorrect or incomplete. That request may be made as long as the information is maintained by and retained at Lifespan. A request for an amendment of records must be made to the records manager at the address given at the end of this notice. By law, Lifespan may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by Lifespan’s records, if the health information you wish to amend is not part of the health information you or your representative are permitted to inspect and copy or if, in the opinion of Lifespan, the records containing your health information are accurate and complete.
- Right to an accounting. You or your legally authorized representative have the right to request an accounting of disclosures of your health information made by Lifespan for certain reasons, including reasons related to public purposes authorized by law. The request for an accounting must be made to the records manager at the address listed at the end of this notice. The request should specify the time period for the accounting starting on or after April 14, 2003. Accounting requests may not be made for periods of time in excess of six (6) years. Accounting requests are subject to a cost-based fee.
- Right to a copy of this notice. You have the right to a copy of this notice at any time, even if you have received this notice previously. To obtain a copy, please contact the Lifespan office.
DUTIES OF LIFESPAN
Lifespan is required by law to maintain the privacy of your health information and to provide to you and your representative this Notice of its duties and privacy practices. Lifespan is required to abide by the terms of this Notice as may be amended from time to time. Lifespan reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all health information that it maintains. If Lifespan changes its Notice, Lifespan will provide you with the revised notice upon request, and post the new notice in our offices. You or your personal representative have the right to express complaints to Lifespan and to the Secretary of the Department of Health and Human Services if you or your representative believe that your privacy rights have been violated. Any complaints to Lifespan should be made to the office of Risk Management for Lifespan at the address listed at the end of this notice. Lifespan encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.
CONTACT PERSON
Lifespan has designated the Director of Risk Management as its contact person for all issues regarding patient privacy and your rights under the Federal privacy standards. You may contact the Director in writing at the address listed below or call the Director’s office at (800) 254-5939.
HOW TO CONTACT LIFESPAN
Office of Risk Management
Lifespan
166 E. Goodale Avenue
Battle Creek, MI 49017-2728
EFFECTIVE DATE
This Notice is effective April 14, 2003.
Revised February 4, 2004 |
