Thomas Hospital
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.
Thomas
Hospital is required to protect the privacy of your confidential personal
health information, referred to below as protected health information ("PHI").
This Notice of Privacy Practices (“Notice”) is provided to you as a
requirement of the privacy regulations issued under the Health Insurance Portability
and Accountability Act of 1996 ("HIPAA").
This Notice describes how Thomas Hospital may use and disclose your
PHI to carry out treatment, payment and health care operations and for other
purposes that are permitted or required by law.
This Notice also describes your rights to access and control your PHI. Thomas Hospital will make a good faith effort
to obtain from you a written acknowledgement of receipt of this Notice.
In
this Notice, Thomas Hospital provides categories that describe these uses and
disclosures and, in some cases, examples are provided to help you better
understand each category.
In
addition to the privacy protection provided under federal law, Alabama law
(referred to in this notice as the Alabama Requirements) requires us in certain
situations (i) to get your written consent (or, according to some of the
Alabama requirements, written consent from your attorney, guardian, or upon
court order) before we can use or disclose your information, or (ii) to keep
records of certain events for a period of time that is longer than what is
required under HIPAA. The Alabama
Requirements may apply:
·
If
you qualify as a patient that suffers from a sexually transmitted disease;
·
If
you qualify as a patient that receives benefits from the State of Alabama for
certain developmental disabilities or mental retardation;
·
If
you qualify as a patient that the Alabama Medicaid Program has asked us to
serve as a Case Management Service Provider for;
·
If
you qualify as a patient that receives rehabilitative services through the
Alabama Medicaid Program;
·
If
you qualify as a patient that receives certain benefits under the Alabama
Preventive Health Education Program;
·
If
you qualify as a patient that receives certain Children's Specialty Clinic
Services under the Alabama Medicaid Program;
·
To
certain disclosures of counselors, psychologists and psychiatrists of Thomas
Hospital;
·
To
certain monitoring records kept by Thomas Hospital regarding specified
diagnostic, radiology and nuclear doses;
·
To
certain disclosures of the Thomas Hospital Nursing Facility;
·
To
certain activities of the Thomas Hospital Hospice;
·
To
certain disclosures and records of the Thomas Hospital Birthing Center;
·
To
certain activities of the Thomas Hospital Mental Illness Community Program and
Adult Mental Illness Foster Care Facility; or
·
To
certain disclosures of the Thomas Hospital Pharmacy.
Uses
and Disclosures for Treatment, Payment and Health Care
Operations. Thomas Hospital may use or disclose your PHI for the purposes of
treatment, payment and health care operations, described in more detail below,
without obtaining written authorization from you.
For Treatment. Thomas Hospital may use and disclose PHI in
the course of providing, coordinating, or managing your medical treatment,
including the disclosure of PHI for treatment activities of another health care
provider. These types of uses and disclosures may generally take place between
physicians, nurses, technicians, and other health care professionals who
provide you health care services or are otherwise involved in your care. For example, if you are being treated by a
primary care physician, that physician may need to disclose PHI to a specialist
physician whom he or she consults regarding your condition, or to a nurse who
is assisting in your care.
For Payment. Thomas Hospital may use and disclose PHI in order to bill and
collect payment for the health care services provided to you. For example, Thomas Hospital may need to
give PHI to your health plan in order to be reimbursed for the services
provided to you. Thomas Hospital may
also disclose PHI to its business associates, such as billing companies, claims
processing companies and others that assist in processing health claims. Thomas Hospital may also disclose PHI to
other health care providers and health plans for the payment activities of such providers or health plans.
For Health Care Operations. Thomas
Hospital may use and disclose PHI for health care operations, including for quality
assessment and improvement. For
example, Thomas Hospital may use and disclose PHI to evaluate the treatment and
services you receive and the performance of our staff in caring for you,
provider training, underwriting activities, compliance and risk management
activities, planning and development, and management and administration of
Thomas Hospital. Other examples of
health care operations include disclosures of PHI to doctors, nurses,
technicians, students, attorneys, consultants, accountants, and others for
review and education purposes, to help make sure Thomas Hospital is complying
with all applicable laws, and to help Thomas Hospital continue to provide
health care to its patients at a high level of quality. In addition, under certain circumstances
Thomas Hospital is permitted to disclose PHI to other health care providers and
health plans for their health care operations, including their quality
assessment and improvement activities, credentialing and peer review
activities, and health care fraud and abuse detection or compliance.
These uses and disclosures may also be
limited by the Alabama Requirements.
Other Uses and Disclosures
For Which Authorization is Not Required. In
addition to using or disclosing PHI for treatment, payment and health care
operations, Thomas Hospital may use and disclose PHI without your written
authorization under the following circumstances:
As Required by Law and Law Enforcement. Thomas Hospital may use or disclose PHI when required to do so by
applicable law. Thomas Hospital also
may disclose PHI (but only under
certain circumstances) when ordered to do so in a judicial or administrative
proceeding, to identify or locate a suspect, fugitive, material witness, or
missing person, when dealing with gunshot and other wounds, about criminal
conduct, to report a crime, the location of the crime or victims, or the
identity, description, or location of a person who committed a crime, or for
other law enforcement purposes.
For Public Health Activities and Public Health Risks. Thomas Hospital may disclose PHI (but only under certain
circumstances) to government officials in charge of collecting information
about births and deaths, preventing and controlling disease, reports of child
abuse or neglect and of other victims of abuse, neglect, or domestic violence,
reactions to medications or product defects or problems, or to notify a person
who may have been exposed to a communicable disease or may be at risk of
contracting or spreading a disease or condition and other similar activities
permitted by law.
For Health Oversight Activities. Thomas
Hospital may disclose PHI to the government for oversight activities authorized
by law, such as audits, investigations, inspections, licensure or disciplinary
actions, and other proceedings, actions or activities necessary for monitoring
the health care system, government programs, and compliance with civil rights
laws.
Coroners, Medical Examiners, and Funeral Directors. Thomas Hospital may disclose PHI to coroners and medical examiners
(and may use PHI if acting in those capacities) for the purpose of identifying
a decedent, determining a cause of death, or otherwise as necessary to enable
these parties to carry out their duties consistent with applicable law. In addition, Thomas Hospital may disclose
PHI to a funeral director as permitted by law and as needed to carry out his or
her duties.
Organ, Eye, and Tissue Donation. Thomas
Hospital may release PHI to organ procurement organizations to facilitate
organ, eye, and tissue donation and transplantation.
Research. Under certain circumstances,
Thomas Hospital may use and disclose PHI for medical research purposes.
To Avoid a Serious Threat to Health or Safety. Under certain circumstances, Thomas Hospital may use and disclose
PHI to law enforcement personnel or other appropriate persons to prevent or
lessen a serious threat to the health or safety of a person or the public.
Specialized Government Functions. Thomas
Hospital may use and disclose PHI of military personnel and veterans under
certain circumstances. Thomas Hospital
may also disclose PHI to authorized federal officials for intelligence,
counterintelligence, and other national security activities, and for the
provision of protective services to the President or other authorized persons
or foreign heads of state or to conduct special investigations. If you are an inmate of a correctional
institution or under the custody of a law enforcement official, Thomas Hospital
may disclose your PHI to the correctional institution or official in certain
circumstances.
Workers’ Compensation. Thomas
Hospital may disclose PHI to comply with workers’ compensation or other similar
laws. These programs provide benefits
for work-related injuries or illnesses.
Fundraising Activities. In certain
circumstances, some of your PHI may be used or disclosed to a related
foundation or business associate to contact you in an effort to raise money for
Thomas Hospital. The money raised in
connection with these activities would be used to expand and support Thomas
Hospital’s provision of health care and related services to the community.
Appointment Reminders; Health-related Benefits and Services; Marketing. Thomas Hospital may use and disclose your PHI to contact you and
remind you of an appointment at Thomas Hospital, or to inform you of treatment
alternatives or other health-related benefits and services that may be of
interest to you, such as disease management programs. Thomas Hospital may use and disclose your PHI to encourage you to
purchase or use a product or service through a face-to-face communication or by
giving you a promotional gift of nominal value without obtaining your express
authorization.
Disclosures to You or for HIPAA Compliance Investigations. Thomas Hospital may disclose your PHI to you or to your personal
representative (who generally is someone who has the legal authority to act on
your behalf), and is required to do so in connection with your rights described
below. Thomas Hospital also must
disclose your PHI to the Secretary of the United States Department of Health
and Human Services (the "Secretary") when requested by the Secretary
in order to investigate the compliance of Thomas Hospital with HIPAA.
These
uses and disclosures may also be limited by the Alabama Requirements.
Uses and Disclosures
That May be Made With Your Agreement or Opportunity to Object. You will have the opportunity to agree or
object to these uses and disclosures of PHI that Thomas Hospital may make:
Patient Directories. Unless you object, Thomas
Hospital may use some of your PHI to maintain a directory of individuals at
Thomas Hospital. This information may
include your name, your location in the facility, your general condition (e.g. fair, stable, etc.), and your
religious affiliation (which will only be disclosed to members of the clergy).
Except for your religious affiliation, the information may be disclosed to
other persons who ask for you by name.
Under limited circumstances, we may use your PHI for facility directory
purposes in certain emergency situations.
Disclosures to Individuals Involved in Your Health
Care or Payment for Your Health Care. Unless you
object, Thomas Hospital may disclose some of your PHI to a family member, other
relative, friend, or other persons you identify. Thomas Hospital may also notify those people about your location
or condition. When you are unable to
agree or object, Thomas Hospital may still disclose your PHI in certain
circumstances.
These
uses and disclosures may also be limited by the Alabama Requirements.
Uses and Disclosures of PHI
For Which Authorization is Required. Other
types of uses and disclosures of your PHI not described in this Notice will be
made only with your written authorization, which you have the right, with some
limitations, to revoke in writing.
Regulatory Requirements. Thomas Hospital is required by law to maintain the privacy of
your PHI, to provide individuals with notice of its legal duties and privacy
practices with respect to PHI, and to abide by the terms described in this
Notice. (That is, the version that is
currently in effect.) Thomas Hospital
reserves the right to change the terms of this Notice and of its privacy
policies, and to make the new terms applicable to all of the PHI it
maintains. Before Thomas Hospital makes
an important change to its privacy policies, it will promptly revise this
Notice and post a new Notice in all applicable areas and on Thomas Hospital’s
website.
Individual Rights. You have the following
rights regarding your PHI:
·
You may
request that Thomas Hospital restrict the use and disclosure of your PHI. Thomas Hospital is not required to agree to
any restrictions you request, but if Thomas Hospital does so it will be bound
by the restrictions to which it agrees except in certain emergency situations.
·
You have
the right to request that communications of PHI to you from Thomas Hospital be
made by particular means or at particular locations. For instance, you might request that communications be made at
your work address, or by e-mail rather than regular mail. Your requests must be made in writing and
sent to our Privacy Officer. Thomas
Hospital will accommodate your reasonable requests.
·
Generally,
you have the right to inspect and copy your PHI that Thomas Hospital maintains,
provided that you make your request in writing to our Privacy Officer. If you request copies of your PHI, Thomas
Hospital may impose a reasonable fee to cover copying, postage, and related
costs. Thomas Hospital may deny access
in certain circumstances. If Thomas Hospital
denies access to your PHI, it will explain the basis for denial and whether you
have an opportunity to have your request and the denial reviewed by a licensed
health care professional (who was not involved in the initial denial decision). If Thomas Hospital does not maintain the PHI
you request and if it knows where that PHI is located, it will tell you how to
redirect your request.
·
If you
believe that your PHI maintained by Thomas Hospital contains an error or needs
to be updated, you have the right to request that Thomas Hospital correct or
supplement your PHI. Your request must
be made in writing to our Privacy Officer, and it must explain why you are
requesting an amendment to your PHI. In
certain circumstances, you have the right to amend your PHI. We may deny your request in certain
circumstances.
·
You
generally have the right to request and receive a list of certain disclosures
of your PHI Thomas Hospital has made at any time during the six (6) years prior
to the date of your request (provided that such a list would not include
disclosures made prior to April 14, 2003).
You should submit any such request to the Medical Records
Department. Thomas Hospital will provide
the first list to you at no charge. For
additional lists, Thomas Hospital 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 to you.
·
You have
the right to receive a paper copy of this notice upon request, even if you have
agreed to receive this notice electronically.
You can receive a copy of this notice at our Web site,
www.thomashospital.com. To obtain a
paper copy of this notice, please contact our Privacy Officer.
·
You may
complain to Thomas Hospital if you believe your privacy rights with respect to
your PHI have been violated by contacting our Director of Quality Management
and submitting a written complaint.
Thomas Hospital will in no manner penalize you or retaliate against you
for filing a complaint regarding Thomas Hospital’s privacy practices. You also have the right to file a complaint
with the Secretary of the Department of Health and Human Services.
If you have any questions about this notice, please
contact Wanda Winfree, Director of Quality Management at 750 Morphy Avenue, Fairhope,
Alabama 36533, (251) 990-1607, wwinfree@thomashospital.com.
Effective Date: April 14th, 2003