JOINT NOTICE OF HEALTH INFORMATION PRIVACY PRACTICES

EFFECTIVE DATE:  February 11, 2005                         REVISION NUMBER:       003

THIS JOINT 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.

OUR PLEDGE REGARDING HEALTH RECORD INFORMATION:
Bethany Medical Rural Health Clinic, Crestview Nursing Home, Inc., Harrison County Community Hospital (HCCH), North Missouri Family Health Center, the Medical Staff, Nurse Practitioners, Physician Assistants, Harrison County Community Hospital’s Home Health Services, and the Clinics located in Bethany, Missouri understand that medical information about you and your health is personal.  We are required by law to maintain the privacy of protected health information (PHI) and to provide our patients with notice of our duties with respect to their PHI.  This Joint Notice of Health Information Privacy Practices describes the personal information we collect, and how and when we use or disclose that information.  It also describes your rights as they relate to your protected health information.  This notice applies to all of the records of your care generated by the facilities listed above, whether made by facility personnel, Medical Staff, Nurse Practitioners/Physician Assistants, and Clinics.  This Notice is effective as of the date set forth above, and applies to all protected health information (PHI) as defined by federal regulations.

UNDERSTANDING YOUR HEALTH RECORD INFORMATION
Each time you visit a record of your visit is made.  Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment.  This information, often referred to as your health or medical record, serves as a:

· Basis for planning your care and treatment;
· Means of communication among the many health professionals who contribute to your care;
· Legal document describing the care you received;
· Means by which you or a third-party payer can verify that services billed were actually provided;
· A tool in educating health professionals;
· A source of data for medical research;
· A source of information for public health officials charged with improving the health of this state and the nation;
· A source of data for our planning and marketing;
· A tool with which we can assess and continually work to improve the care we render and the outcomes we achieve. 

Understanding what is in your record and how your health information is used helps you to: ensure its accuracy, better understand who, what, when, where, and why others may access your health information, and make more informed decisions when authorizing disclosure to others. 

YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU
The medical record that we compile, use and maintain is at all times the physical property of the Bethany Medical Rural Health Clinic, Crestview Nursing Home, Inc., HCCH, North Missouri Family Health Center, the Medical Staff, Nurse Practitioners, Physician Assistants, Harrison County Community Hospital Home Health Services or the Clinics in Bethany, Missouri. Notwithstanding this fact, you have certain rights with respect to the information included in the medical record.  You have the right to:

·  Obtain a paper copy of this Notice of Privacy Practices upon request;
·   Inspect and obtain a copy of your health record upon payment of reasonable copy expenses;
·   Amend your health record;
·  Obtain an accounting of disclosures of your health information;
·   Request a restriction on certain uses and disclosures of your information; and;
·   Revoke your authorization to use or disclose information except to the extent that action has already been taken.

OUR RESPONSIBILITIES
Bethany Medical Rural Health Clinic, Crestview Nursing Home Inc., Harrison County Community Hospital, North Missouri Family Health Center and Harrison County Community Hospital Home Health Services are required to
 

· Maintain the privacy of your health information;

· Provide you with this Notice as to our legal duties and privacy practices with respect to information we collect and maintain about you;

· Abide by the terms of this notice:

·  Notify you if we are unable to agree to a requested restriction, and

· Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.

·  Accommodate your request for an accounting of disclosures.

We reserve the right to make changes to this notice and our privacy practices in order to remain compliant with HIPAA regulations.  We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future.  We will post a copy of the current Joint Notice of Privacy Practices in the hospital.  The Joint Notice will contain the revision number and effective date.  In addition, each time you register at or are admitted to the hospital for treatment or health care services the current notice in effect will be available.  Also you can call or write our contact person to obtain the most recent version of this notice.  The current version of this notice will be posted on HCCH’s website. http://www.hcchospital.org

We will not use or disclose your health information without your authorization, except as described in this Joint Notice.  We will also discontinue to use or disclose your health information after we have received a written revocation of the authorization according to the procedures included in the authorization. 

USES AND DISCLOSURE FOR TREATMENT, PAYMENT AND HEALTHCARE OPERATIONS.

We will use your health information for Treatment. 

For example:  Information obtained by a nurse, physician, or other member of your healthcare team will be recorded in your record and used to determine the course of treatment that should work best for you.  Your physician will document in your record his or her expectations of the members of your healthcare team.  Members of your healthcare team will then record the actions they took and their observations.  In that way, the physician will know how you are responding to treatment.  We will also provide your physician or referring healthcare provider with copies of various reports that should assist him or her in treating you once you are discharged. 

We will use your health information for Payment.

For example: A bill may be sent to you or any third party payer that you have identified.  The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, procedures, and supplies used. 

We will use your health information for Healthcare Operations. 

For example:  Members of the medical staff, the risk or quality improvement manager, or members of the quality improvement team may use information in your health record to assess the care and outcomes in your case and others like it.  This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and service we provide. 

Business Associates:  There are some services provided in our organization through agreements with third parties.  An example would be an agreement with a company that takes your older health records and transfers them into a different format like microfilm or computer disk for condensed storage of the information.  When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we have asked them to do.  To protect your health information, however, we require the business associate to appropriately safeguard your information. 

Directory:  Unless you notify us that you object, we will use your name, location in the facility, general condition, and religious affiliation for directory purposes.  This information may be provided to members of the clergy and except for religious affiliation, to other people who ask for you by name. 

Notification:  We may use or disclose information to notify or assist in notifying a family member, personal representative or another person responsible for your care, your location and general condition. 

Communication with family:  Health professionals, using their best judgment, may disclose to a family member, other relative, close personal friend or any other person you identify, health information relevant to that person’s involvement in your care or payment related to your care.  You have the right to notify us as to who should be included or not included on this list. 

Research:  We may disclose information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information. 

Coroners, Funeral Directors and Medical Examiners:  We may disclose health information to coroners, funeral directors and medical examiners consistent with applicable law to carry out their duties. 

Organ procurement organizations:  Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant. 

Appointment Reminders and Other Contacts:  We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. 

Fundraising:  We may contact you as part of a fund-raising effort. 

Food and Drug Administration (FDA):  We may disclose to the FDA health information relative to adverse events with respect to food, supplements, product and product defects, or post marketing surveillance information to enable product recalls, repairs or replacement. 

Marketing:  We may, with your advanced authorization, use your information for marketing purposes. 

Workers compensation:  We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law. 

Public health:  As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability. 

Use of Psychotherapy Notes:  Unless we obtain an authorization permitting another use, we may use any psychotherapy notes in your record only for treatment, payment or health care operations.  The Healthcare Provider maintains the ability to use certain disclosures with respect to oversight of psychotherapy notes or to defend ourselves in a legal action. 

Correctional institution:  Should you be an inmate of a correctional institution or in custody of law enforcement, we may disclose to the institution or agents thereof health information necessary for your health and the health and safety of other individuals. 

Law enforcement:  We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena. 

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. 

Federal law makes provision for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public. 

Military and 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.  Upon your separation or discharge from military services your information may be released on order for the Department of Veterans Affairs to determine if you are eligible for certain benefits. 

FOR MORE INFORMATION OR TO REPORT A PROBLEM 

If you have questions and would like additional information, you may contact appropriate facilities’ Privacy Officer. 

 If you believe your privacy rights have been violated, you can file a complaint with the above facilities’ Privacy Officer or with the Office for Civil Rights, U.S. Department of Health and Human Services.  There will be no retaliation against you for filing a complaint with either the Privacy Officer or the Office for Civil Rights.  The address for the OCR is listed below:

Office for Civil Rights
U.S. Department of Health and Human Services
200 Independence Avenue. S.W.
Room 509F, HHH Building
Washington, D.C. 20201