ST. VINCENT’S HEALTH SERVICES Bridgeport, CT06606 NOTICE OF PRIVACY PRACTICES Effective April 14, 2003 Revised September 23, 2013
This notice describes how medical information about you may be used and disclosed and how you can get access to this information.
Please read it carefully. If you have any questions, please contact the Privacy Officer at the phone number on the final page of this notice.
St. Vincent’s Health Services and its related entities are required by law to:
- Make sure the medical information that may identify you (which we refer to as “protected health information” or “PHI”) is kept private
- Give you this notice of our legal duties & privacy practices with respect to medicalinformation we collect & maintain about you
- Follow the terms of the notice that is currently in effect
- Notify you if we are unable to agree to a requested restriction
- Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations
We reserve the right to change our practices and to make the new provisions effective for all protected health information we maintain. Should our information practices change, we will provide a revised notice upon your next encounter at one of our facilities, make the revised notice available on our web site or mail you a copy at your written request.
Who Will Follow These Practices
These practices will be followed by all St. Vincent’s Health Services entities, including St. Vincent’s Medical Center, the Family Health Center, the Center for Wound Healing, St. Vincent’s Behavioral Health Services, our Urgent Care Walk-In Centers, St. Vincent’s Multispecialty Group, and St. Vincent’s Special Needs Center. The practices will be followed by our entire workforce, members of the St. Vincent’s Medical Center Medical Staff, volunteers, clergy and healthcare professionals and students in training.
This notice explains your rights and certain duties we have regarding the use of your information. We will not use or disclose your information without your written authorization, except as described in this notice. If you choose to authorize use or disclosure, you can later revoke that authorization by notifying us of your decision. This information may be transmitted electronically if you receive treatment at any St. Vincent’s Health Services entity, and/or any community provider who uses the same Electronic Health Record System for the coordination of your care or for other healthcare operations.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
The following categories describe different ways that we use and disclose medical information without your prior authorization. For each category of uses or disclosure we will explain what we mean. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of these categories.
For Treatment We may use or disclose your medical information for the purpose of providing, or allowing others to provide, treatment to you. This includes psychiatric or HIV information if needed for purposes of your diagnosis and treatment. For example, your primary care physician may disclose your health information to another doctor for the purpose of a consultation. Your health information may also be shared with other people that may help you with medical care after you leave one of our facilities. If you receive treatment at any St. Vincent’s Health Services entity, and/or any community provider who uses the same Electronic Health Record system, your health information may be available to others who may use it to care for you, to coordinate your health services or for other healthcare operations.
For Payment We may use and disclose medical information about you so that the treatment and services you receive may be billed to, and payment may be collected from you, an insurance company or a third party, including a collection service. Only limited psychiatric or HIV information may be disclosed for billing purposes without your authorization. The information on the bill may include information that identifies you, as well as your diagnosis, procedures and supplies used. We may also tell your health plan about a treatment you are going to receive in order to obtain prior approval or to determine whether your plan will cover the treatment. If you wish to pay for a service out-of-pocket in full and wish that this service not be disclosed to your health plan, you may request a restriction at the time of your payment.
For Health Care Operations Members of the medical staff, the Risk Manager, or the members of various quality improvement teams may use information from your health record to assess the care and outcomes in your case and others like it. We also may combine information with other health care institutions to find how we can improve the care given. This information is used in an effort to continually improve the quality and effectiveness of the healthcare and services we provide. For example, health care operations include reviewing the competence of health care professionals, conducting training programs in which students learn to practice or improve their skills as health care professionals, accreditation, licensing, certification or credentialing activities and patient satisfaction surveys. As part of our customer service we may occasionally send greeting cards or condolences. If you do not want us to send these to you, please notify the Vice President of St. Vincent’s Medical Center Foundation, Inc. in writing at 2800 Main Street, Bridgeport, Connecticut 06606.
Business Associates There are some services provided in our organization through written contracts with business associates. Examples include physician services in radiology, anesthesiology, certain outside laboratories and a copy service that we use when making copies of your records. When these services are contracted, we may disclose your health information to our business associates so they can perform the job we’ve asked them to do and bill you or your third-party payer for services rendered. To protect your protected health information, business associates are required to appropriately safeguard your information.
Notification We may use and disclose medical information to notify you that you have an appointment for treatment or medical care at one of our facilities. We also may disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, of your location and general condition.
Alternative Treatment – Health Related Benefits and Services We may use and disclose medical information to tell you about alternative treatment options or health-related benefits or services that may be of interest to you. For example, you may receive notices of classes on subjects such as Managing Diabetes, Coping with Cancer, Living with Congestive Heart Failure or Caring for a Child with Disabilities.
Fundraising Activities We may communicate with you as part of our fundraising activities, but you have the right to opt out of receiving such communications. If you do not want to be contacted for fundraising efforts, you must notify the Vice President of St. Vincent’s Medical Center Foundation, Inc. in writing at 2800 Main Street, Bridgeport, CT 06606.
Patient Directories We may include certain limited information about you in the general directory while you are a patient on a general medical/surgical unit at St. Vincent’s MedicalCenter. This directory does not include patients who are being treated in any of our mental health units or facilities. This information includes your name, location in the hospital, your condition such as satisfactory, serious, or critical, and your religious affiliation. The directory information, except for your religious affiliation, may also be released to people who ask for you by name. This is so your family, friends and clergy can visit you and generally know how you are doing. If you do not want to have your name and other information included in the directory, you must notify the person who is registering you at the time of admission/treatment. We also may include your name on locator boards in clinical areas, such as the emergency department, to assist the staff in knowing the specific treatment area where you are located.
Communication with Individuals Involved in Your Care or Payment for Your Care Health professionals, using their best judgment, may disclose to a family member, or any other person you identify, health information relevant to that person’s involvement in your care or payment related to your care. In addition, we may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.
Research We may use and disclose health information about you for officially approved research as permitted by law, when a waiver of authorization is obtained from an Institutional Review Board, or through a limited set of information. Otherwise, we will only use or disclose your information for research with your specific authorization.
As Required by Law We will disclose information about you when required to do so by federal, state or local law or in response to a valid subpoena. By law we will disclose information to your employer if you are involved in an injury, work related illness or for workplace surveillance. We may release your health information to authorized federal officials for lawful intelligence, counterintelligence, and other national security activities. We may also disclose your information to provide protection to the President or other persons or foreign heads of state or for the conduct of special investigations.
To Avert a Serious Threat to Health or Safety We may use and disclose information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
For Certain Law Enforcement Purposes We may disclose information about you to report certain injuries, such as gunshot wounds, or to assist in identifying or locating a suspect, fugitive, material witness or missing person. In such cases limited identification and clinical information would be disclosed. Disclosure might be made for suspected victims of crime, or to disclose the death of an individual who may have died as the result of a crime. We also would disclose information relevant to a crime committed on the premises of one of our facilities.
To Funeral Directors or Coroners We may disclose information to a funeral director as necessary to carry out their duties and to a coroner for purposes of identifying the deceased person or determining the cause of death.
Organ & Tissue Donation We may disclose health information to organ procurement organizations or other entities engaged in procurement, banking or transplantation of organs for the purpose of tissue donation and transplant.
Military & Veterans If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
Workers’ Compensation We may release medical information about you to the extent authorized by and to the extent necessary to comply with laws relating to workers’ compensation or similar programs established by law. These programs provide benefits for work-related injuries or illness
Public Health As required by law, we may disclose medical information about you for public health activities. These activities generally include the following:
– To prevent or control disease, injury or disability
– To report births, deaths & certain diseases – To report child abuse or neglect
– To report suspected abuse
– To report reactions to medications or problems with products
– To notify people of recalls of products they may be using
– To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
Health Oversight Activities We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
WHEN YOUR WRITTEN AUTHORIZATION IS REQUIRED
We must obtain your written authorization before using or disclosing your psychotherapy notes (if any), except that (i) the originator of the psychotherapy notes may use them for treatment; (ii) we may use or disclose them for our own mental health training programs; and (iii) we may use or disclose them to defend ourselves in a legal action or other proceeding brought by you.
We must obtain your written authorization before using or disclosing your PHI for marketing purposes, except for face-to-face communications made by us to you or a promotional gift of nominal value provided by us to you.
We will not sell or offer to sell any individually identifiable health information.
Other uses and disclosures of your PHI not covered by this Notice will be made only with your written authorization.
Your Health Information Rights Although your health record is the physical property of the healthcare provider or facility that compiled it, the information contained within it belongs to you.
You have the right to:
- Request Restrictions on the use and disclosure of your protected health information for treatment, payment or operations purposes or notification purposes. We will consider your request and work to accommodate it when possible, but we are not legally required to accept it, except when you request that we not disclose information to your health plan about services for which you paid out-of-pocket in full. In those cases we will honor your request unless the disclosure is necessary for your treatment or is required by law. In some cases, we have the right to revoke the restriction as long as we notify you before doing so. In other cases we will need your permission before we can revoke the restriction. You may submit a written request to the Privacy Officer listed on the final page of this notice.
- Limit Communications You have the right to receive confidential communications about your own information by alternative means or at alternative locations. This means you may, for example, designate that we contact you only in writing or contact you at work rather than at home. To request alternative means or alternative locations, you must submit your request in writing to the Privacy Officer listed on the final page of this notice.
- Inspect and have copies made of your health record by submitting a written request to the Health Information Services Department at St. Vincent’s Medical Center. In accordance with Connecticut regulations, you may be charged a fee for the cost of copying and mailing. Despite your general right to access your information, it may be denied in some limited circumstances. For example, access may be denied if you are an inmate at a correctional institution or if you are a participant in a research program that is still in process.Access to information that was obtained from someone other than a health care provider under a promise of confidentiality can be denied if allowing you access would reasonably be likely to reveal the source of the information. The decision to deny access under these circumstances is final and not subject to review.
In addition, access may be denied if: (1) access to the information is reasonably likely to endanger the life and physical safety of you or anyone else, (2) the information makes reference to another person and your access would reasonably be likely to cause harm to that person, or (3) you are the personal representative of another individual and a licensed health care professional determines that your access to the information would cause substantial harm to the patient or someone else. If access is denied for these reasons, you have the right to have the decision reviewed by a health care professional who did not participate in the decision. If access is ultimately denied, the reasons will be provided to you in writing.
- Request Amendment You may request that your health information be amended. The request may be denied if the information in question (1) was not created by us (unless you show that the original source of the information is no longer available to make amendments), (2) is not part of our records, (3) is not the type of information that would be available for you to inspect, or (4) is accurate and complete. If your request is denied, you may submit a written statement disagreeing with the denial, which we will keep on file and include with future disclosures of the information to which it relates. Requests must be submitted in writing to the Privacy Officer listed on the final page of this notice
- An Accounting of Disclosures You have the right to an accounting of disclosures of your health information made during the 6 year period preceding the date of your request. However, the accounting won’t include disclosures: (1) made to you, (2) of information contained in our facility directory, or to those persons involved in your health care or for purposes of notifying your family or friends about your whereabouts, (3) for national security or intelligence purposes, (4) to correctional institutions or law enforcement officials who had you in custody at the time of disclosure, (5) that occurred prior to April 14, 2003, (6) made pursuant to an authorization signed by you, (7) that are part of a limited data set, (8) that are incidental to another authorized use/disclosure, (9) made to health oversight agencies, but only if the agency or official asks us not to account to you and only for the limited time covered by the request. The accounting will include the date of each disclosure, the name of the entity or person who received the information, that person’s address if known, and a brief description of the information and the purpose of the disclosure. To request an accounting of disclosures, submit a request in writing to the Privacy Officer listed on the final page of this notice.
- Paper Copy of this Notice You have the right to obtain a paper copy of this Notice upon request.
- Breach Notification We are required to notify you in the event of a breach of your unsecured PHI.
- Complaints You can complain to us and to the federal Office of Civil Rights of the Department of Health and Human Services if you believe your privacy rights have been violated. To lodge a complaint with us, please register a written complaint with our Privacy Officer at St. Vincent’s MedicalCenter, 2800 Main St., Bridgeport, CT06606. Should you have any concerns, you may phone the Privacy Officer at 203-576-5050. You may also contact the Compliance Officer at St. Vincent’s MedicalCenter by calling 203-576-5551.To file a complaint with the Office of Civil Rights you must file the complaint in writing, either on paper or electronically. You must name the individual or entity that is the subject of the complaint and describe the acts or omissions believed to be in violation of the requirements. Your complaint must be filed within 180 days of when you knew or should have known the act or omission occurred. Individuals registering complaints will not be subject to retaliation in any form.
St. Vincent’s Medical Center
2800 Main Street
Bridgeport, CT 06606
NOTIFICATION OF ORGANIZED HEALTH CARE ARRANGEMENT BETWEEN
ST. VINCENT’S MEDICALCENTER AND ST. VINCENT’S MEDICAL STAFF
St. Vincent’s MedicalCenter, the members of its Medical Staff (including your physician) and other health care providers affiliated with St. Vincent’s MedicalCenter have agreed, as permitted by law, to share your health information among themselves for purposes of treatment, payment or health care operations. This enables us to better address your health care needs.