|
HIPAA: Notice of Privacy Practices
This Notice Describes How Medical InformationAbout You May Be Used and
Disclosedand How You Can Get Access To This Information.Please Review
It Carefully.Changes On This Notice Will Not Be Honored.
We understand that information about you and your health is very personal
and therefore, we will strive to protect your privacy as required by
law. We will only use and disclose your personal health information as
allowed by applicable law.
We are committed to excellence in the provision
of state-of-the-art health care services through the practice of patient
care, education, and research. Therefore, as described below, your health
information will be used to provide you care and may be used to educate
health care professionals and for research. We train our staff and workforce
to be sensitive about privacy and to respect the confidentiality of your
personal health information.
We are required by law to maintain the privacy
of our patients' personal health information and to provide you
with notice of our legal duties and privacy practices with respect to
your personal health information. We are required to abide by the terms
of this Notice of Privacy Practices so long as it remains in effect.
We reserve the right to change the terms of this Notice of Privacy Practices
as necessary and to make the new Notice of Privacy Practices effective
for all personal health information maintained by us. You may receive
a copy of any revised notice at any of our hospitals or doctors' offices,
or a copy may be obtained by mailing a request to the UPHS Privacy Office,
Office of Audit, Compliance and Privacy, 3819 Chestnut Street, Suite
214, Philadelphia PA 19104.
The terms of this Notice of Privacy Practices
apply to the following entities owned and operated by and/or affiliated
with the Trustees of the University of Pennsylvania: the University of
Pennsylvania Health System and its subsidiaries and affiliates, including
but not limited to the Hospital of the University of Pennsylvania, Pennsylvania
Hospital, Penn Presbyterian Medical Center, the Clinical Practices of
the University of Pennsylvania (CPUP), Clinical Care Associates (CCA),
Clinical Health Care Associates of New Jersey, P.C. (CHCA), Surgery Center
of Pennsylvania Hospital, Penn Medicine at Radnor, Penn Center for Rehabilitation
and Care, Penn Home Infusion Therapy, Wissahickon Hospice, Penn Care
at Home, the Ruth and Raymond Perelman Center for Advanced Medicine,
Presbyterian Anesthesiology Foundation, Presbyterian Multi-Specialty
Group Practice Foundation, the University of Pennsylvania School of Medicine,
Good Shepherd Penn Partners, Good Shepherd Penn Partners Specialty Hospital
at Rittenhouse, Good Shepherd Penn Partners Penn Therapy and Fitness,
and the physicians, licensed professionals, employees, volunteers, and
trainees seeing and treating patients at each of these care settings.
This Notice of Privacy Practices does not apply when visiting a non-CPUP,
non-CCA or non-CHCA physician in their private medical office.
USES AND DISCLOSURES OF YOUR PERSONAL HEALTH INFORMATION
The following categories detail the various ways in which we may use
or disclose your personal health information. For each category of
uses or disclosures, we will give you illustrative examples. It should
be noted that while not every use or disclosure will be listed, each
of the ways we are permitted to use or disclose information will fall
into one of the following categories.
Your Authorization. Except as
outlined below, we will not use or disclose your personal health information
for any purpose unless you have signed a form authorizing the use or
disclosure. This form will describe what information will be disclosed,
to whom, for what purpose, and when. You have the right to revoke that
authorization in writing, except to the extent we have already relied
upon it.
Uses and Disclosures for Treatment. We will make uses and disclosures
of your personal health information as necessary for your treatment.
For instance, doctors, nurses, and other professionals involved in
your care will use information in your medical record to plan a course
of treatment for you that may include procedures, medications, tests,
etc. We may also disclose your personal health information to institutions
and individuals outside the University of Pennsylvania Health System
and the University of Pennsylvania School of Medicine that are or will
be providing treatment to you.
Uses and Disclosures for Payment. We
will make uses and disclosures of your personal health information
as necessary for payment purposes. For instance, we may forward information
regarding your medical procedures and treatment to your insurance company
to arrange payment for the services provided to you or we may use your
information to prepare a bill to send to you or to the person responsible
for your payment.
Uses and Disclosures for Health Care Operations. We will use
and disclose your personal health information as necessary, and as permitted
by law, for health care operations. This is necessary to run the University
of Pennsylvania Health System and the University of Pennsylvania School
of Medicine and to ensure that our patients receive high quality care
and that our health care professionals receive superior training. For
example, we may use your personal health information in order to conduct
an evaluation of the treatment and services we provide, or to review
the performance of our staff. And, for education and training purposes,
your health information may also be disclosed to doctors, nurses, technicians,
medical students, residents, fellows and others.
Our Facility Directory. We use information to maintain a directory
function listing your name, room number, general condition and, if you wish,
your religious affiliation. Unless you choose to have your information excluded
from this directory, the information, excluding your religious affiliation, will
be disclosed to anyone who requests it by asking for you by name. This information,
including your religious affiliation, may also be provided to members
of the clergy, even if they don’t ask for you by name. Please let
our staff know when you check in or register if you would like to have
your information excluded from this directory function.
Persons Involved In Your Care. Unless you object, we may in our
professional judgment disclose to a member of your family, a close friend,
or any other person you identify, your personal health information to
facilitate that person’s involvement in caring for you or in payment
for that care. We may use or disclose personal health information to
assist in notifying a family member, personal representative or any other
person that is responsible for your care of your location and general
condition. We may also disclose limited personal health information
to a public or private entity that is authorized to assist in disaster
relief efforts in order for that entity to locate a family member or
other persons that may be involved in some aspect of caring for you.
Fundraising. We may contact you, at times in coordination with
your physician, to donate to a fundraising effort on our behalf. If we
contact you for fundraising purposes, you will be provided with the opportunity
to opt out of receiving any future solicitations.
Appointments and Services. We may use your personal health information
to remind you about appointments or to follow up on your visit.
Health
Products and Services. We may from time to time use your personal
health information to communicate with you about treatment alternatives
and other health-related benefits and services that may be of interest
to you.
Research. We may use and disclose your personal health information
as permitted by law for research, subject to your explicit authorization,
and/or oversight by the University of Pennsylvania Institutional Review
Boards (IRBs), committees charged with protecting the privacy rights
and safety of human subject research, or similar committee. In all cases
where your specific authorization has not been obtained, your privacy
will be protected by confidentiality requirements evaluated by such committee.
For example, the IRB may approve the use of your health information with
only limited identifying information to conduct outcomes research to
see if a particular procedure is effective.
Business Associates. Certain
aspects and components of our services are performed through contracts
with outside persons or organizations, such as auditing, accreditation,
legal services, etc. At times it may be necessary for us to provide certain
of your personal health information to one or more of these outside persons
or organizations who assist us with our payment/billing activities and
health care operations. In such cases, we require these business associates
to appropriately safeguard the privacy of your information.
Other Uses
and Disclosures. We are permitted or required by law to make certain
other uses and disclosures of your personal health information without
your consent or authorization. Subject to conditions specified by law:
- We
may release your personal health information for any purpose required
by law;
- We may release
your personal health information for public health activities, such
as required reporting of disease, injury, and birth and death, and
for required public health investigations;
- We may release your
personal health information to certain governmental agencies if we
suspect child abuse or neglect; we may also release your personal health
information to certain governmental agencies if we believe you to be
a victim of abuse, neglect, or domestic violence;
- We may release
your personal health information to entities regulated by the Food
and Drug Administration if necessary to report adverse events, product
defects, or to participate in product recalls;
- We may release
your personal health information to your employer when we have provided
health care to you at the request of your employer for purposes related
to occupational health and safety; in most cases you will receive notice
that information is disclosed to your employer;
- We may release
your personal health information if required by law to a government
oversight agency conducting audits, investigations, inspections and
related oversight functions;
- We may use or disclose your personal
health information in emergency circumstances, such as to prevent a
serious and imminent threat to a person or the public;
- We may
release your personal health information if required to do so by a
court or administrative order, subpoena or discovery request; in most
cases you will have notice of such release;
- We may release your
personal health information to law enforcement officials to identify
or locate suspects, fugitives or witnesses, or victims of crime, or
for other allowable law enforcement purposes;
- We may release
your personal health information to coroners, medical examiners, and/or
funeral directors;
- We may release your personal health information
if necessary to arrange an organ or tissue donation from you or a transplant
for you;
- We may release your personal health information if
you are a member of the military for activities set out by certain
military command authorities as required by armed forces services;
we may also release your personal health information if necessary for
national security, intelligence, or protective services activities;
and
- We may release your personal health information if necessary
for purposes related to your workers’ compensation benefits.
Confidentiality of Alcohol and Drug Abuse Patient
Records, HIV-Related Information, and Mental Health Records. The
confidentiality of alcohol and drug abuse patient records, HIV-related
information, and mental health records maintained by us is specifically
protected by state and/or Federal law and regulations. Generally, we
may not disclose such information unless you consent in writing, the
disclosure is allowed by a court order, or in limited and regulated
other circumstances.
RIGHTS THAT YOU HAVE
Access to Your Personal Health
Information. Generally, you have the right to access, inspect, and/or
copy personal health information that we maintain about you. Unless
you are currently a patient in our hospital or during a scheduled appointment
with a clinician, requests for access must be made in writing and be
signed by you or your representative. We will charge you for a copy
of your medical records in accordance with a schedule of fees established
by applicable state law. You may obtain an access request form from
the doctor’s office or Medical Records department
of the hospital you visited.
Amendments to Your Personal Health Information. You have the right
to request that personal health information that we
maintain about you be amended or corrected. We are not obligated to make
all requested amendments but will give each request careful consideration.
All amendment requests, in order to be considered by us, must be in writing,
signed by you or your representative, and must state the reasons for
the amendment/correction request. If an amendment or correction you request
is made by us, we may also notify others who work with us and have copies
of the uncorrected record if we believe that such notification is necessary.
Please note that even if we accept your request, we may not delete any
information already documented in your medical record. You may obtain
an amendment request form from the doctor’s office or Medical Records
department of the hospital you visited.
Accounting for Disclosures of
Your Personal Health Information. You have the right to receive an
accounting of certain disclosures made by us of your personal health
information except for disclosures made for purposes of treatment, payment,
and healthcare operations or for certain other limited exceptions. This
accounting will include only those disclosures made in the six years
prior to the date on which the accounting is requested but, in no event
will include disclosures made prior to April 13, 2003. Requests must
be made in writing and signed by you or your representative. Accounting
request forms are available from the doctor’s office or Guest Services
department of the hospital you visited. The first accounting in any 12-month
period is free; you will be charged a fee of $20 for each subsequent
accounting you request within a 12-month period.
Restrictions on Use and
Disclosure of Your Personal Health Information. You have the right
to request restrictions on certain of our uses and disclosures of your
personal health information for treatment, payment, or health care operations.
For example, you may request that we do not share your health information
with a certain family member. A restriction request form can be obtained
from the doctor’s
office or Guest Services department of the hospital you visited. We are
not required to agree to your restriction request but will attempt to
accommodate reasonable requests when appropriate and we retain the right
to terminate an agreed-to restriction if we believe such termination
is appropriate. In the event we have terminated an agreed upon restriction,
we will notify you of such termination.
Confidential Communications. You have the right to request communications
regarding your personal health information from us by alternative means
or at alternative locations and we will accommodate reasonable requests
by you. You must request such confidential communication in writing to
each department to which you would like the request to apply.
Paper Copy
of Notice. As a patient you retain the right to obtain a paper copy of
this Notice of Privacy Practices, even if you have requested such copy
by e-mail or other electronic means. Our Notice may also be obtained
on our website at http://www.uphs.upenn.edu/.
ADDITIONAL INFORMATION
Complaints. If you believe your privacy rights have been violated,
you may file a complaint in writing with the doctor’s office or
Guest Services department of the hospital you visited. You may also file
a complaint with the Secretary of the U.S. Department of Health and Human
Services in Washington D.C. All complaints must be made in writing and
in no way will affect the quality of care you receive from us.
For further information. If you have questions or need further assistance
regarding this Notice of Privacy Practices, you may contact us in writing at
UPHS Privacy Office, Office of Audit, Compliance and Privacy, 3819 Chestnut
Street, Suite 214, Philadelphia PA 19104, or by telephone at (215) 898-7260,
or by e-mail at privacy@uphs.upenn.edu.
Effective Date. This Notice of Privacy Practices is effective May 5, 2008.
|
