NOTICE OF PRIVACY PRACTICES
Effective Date: March 2013.
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND
DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW
If you have any questions about this notice, please contact the Health
WHO WILL FOLLOW THIS NOTICE
This notice describes our hospital's practices and that of:
• Any health care professional authorized to enter information into
your hospital chart.
• All departments and units of the hospital.
• Any member of a volunteer group we allow to help you while you are
in the hospital.
• All Employees, staff and other hospital personnel.
All these entities, sites and locations follow the terms of this notice.
In addition, these entities, sites and locations may share medical information
with each other for treatment, payment or health care operations purposes
described in this notice.
OUR PLEDGE REGARDING MEDICAL INFORMATION
We understand that medical information about you and your health is personal. We
are committed to protecting medical information about you. We create a
record of the care and services you receive at the hospital. We need this
record to provide you with quality care and to comply with certain legal
requirements. This notice applies to all of the records of your care generated
by the hospital, whether made by hospital personnel or your personal doctor.
Your personal doctor may have different policies or notices regarding
the doctor's use and disclosure of your medical information created
in the doctor's office or clinic.
This notice will tell you about the ways in which we may use and disclose
medical information about you. We also describe your rights and certain
obligations we have regarding the use and disclosure of medical information.
We are required by law to:
• Make sure that medical information that identifies you is kept private
(with certain exceptions);
• Give you this notice of our legal duties and privacy practices with
medical information about you; and
• Follow the terms of our notice that is currently in effect.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
The following categories describe different ways that we may use and disclose
medical information. For each category of uses or disclosures we will
explain what we mean and try to give some examples. 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 the categories.
Disclosure at Your Request
We may disclose information when requested by you. This disclosure at your
request may require a written authorization by you.
We may use medical information about you to provide you with medical treatment
or services. We may disclose medical information about you to doctors,
nurses, technicians, health care students, or other hospital personnel
who are involved in taking care of you at the hospital. For example, a
doctor treating you for a broken leg may need to know if you have diabetes
because diabetes may slow the healing process. In addition, the doctor
may need to tell the dietitian if you have diabetes so that we can arrange
for appropriate meals. Different departments of the hospital also may
share medical information about you in order to coordinate the different
things you need, such as prescriptions, lab work and x-rays. We also may
disclose medical information about you to people outside the hospital
who may be involved in your medical care after you leave the hospital,
such as other acute facilities, skilled nursing facilities, home health
agencies, and physicians or other practitioners. For example, we may give
your physician access to your health information to assist your physician
in treating you.
• For Payment
We may use and disclose medical information about you so that the treatment
and services you receive at the hospital may be billed to and payment
may be collected from you, an insurance company or a third party. For
example, we may need to give your health plan information about your surgery
you received at the hospital so your health plan will pay us or reimburse
you for the surgery. We may also tell your health plan about a treatment
you are going to receive to obtain prior approval or to determine whether
your plan will cover the treatment. We may also provide basic information
about you and your health plan, insurance company or other source of payment
to practitioners outside the hospital who are involved in your care, to
assist them in obtaining payment for services they provide to you. If
you wish to pay for this hospitalization treatment out of pocket, in full,
you have the right to restrict disclosures of protected health information
to your health plan. Please contact a business office associate before
the end of your hospitalization. Refer to the Business Office phone number.
• For Health Care Operations
We may use and disclose Health Information about you for health care operation
purposes. These uses and disclosures are necessary to make sure that all
of our patients receive quality care and for our operation and management
purposes. For example, we may use Health Information to review the treatment
and services we provide to ensure that the care you receive is of the
highest quality. We may also combine medical information about many hospital
patients to decide what additional services the hospital should offer,
what services are not needed, and whether certain new treatments are effective.
We may also disclose information to doctors, nurses, technicians, medical
students, and other hospital personnel for review and learning purposes.
We may also combine the medical information we have with medical information
from other hospitals to compare how we are doing and see where we can
make improvements in the care and services we offer. We may remove information
that identifies you from this set of medical information so others may
use it to study health care and health care delivery without learning
who the specific patients are.
• Fundraising Activities
We may use medical information about you, or disclose such information
to a foundation related to the hospital, to contact you in an effort to
raise money for the hospital and its operations. You have the right to
opt out of receiving fundraising communications. If you receive a fundraising
communication, it will tell you how to opt out. We only would release
contact information, such as your name, address and phone number and the
dates you received treatment or services at the hospital.
• Hospital Directory
We may include certain limited information about you in the hospital directory
while you are a patient at the hospital. This information may include
your name, location in the hospital, your general condition (e.g., good,
fair, etc.) and your religious affiliation. Unless there is a specific
written request from you to the contrary, this directory information,
except for your religious affiliation, may also be released to people
who ask for you by name. Your religious affiliation may be given to a
member of the clergy, such as a priest or rabbi, even if they don't
ask for you by name. This information is released so your family, friends
and clergy can visit you in the hospital and generally know how you are doing.
• Marketing and Sale
Most uses and disclosures of medical information for marketing purposes,
and disclosures that constitute a sale of medical information, require
• Individuals Involved in Your Care or Payment for Your Care
We may release medical information about you to a friend or family member
who is involved in your medical care. We may also give information to
someone who helps pay for your care. Unless there is a specific written
request from you to the contrary, we may also tell your family or friends
your condition and that you are in the hospital. We also may notify your
family about your location or general condition or disclose such information
to an entity assisting in a disaster relief effort. If you arrive at the
emergency department either unconscious or otherwise unable to communicate,
we are required to attempt to contact someone we believe can make health
care decisions for you (e.g., a family member or agent under a health
care power of attorney).
Under certain circumstances, we may use and disclose Health Information
for research purposes. For example, a research project may involve comparing
the health recovery of all patients who received one medication or treatment
to those who received another, for the same condition. All research projects,
however, are subject to a special approval process. This process evaluates
a proposed research and its use of medical information, trying to balance
the research needs with patients' need for privacy of their medical
information. Before we use or disclose medical information for research,
the project will go through a special approval process, but we may, however,
disclose medical information about you to people preparing to conduct
a research project, for example, to help them look for patients with specific
medical needs, as long as the medical information they review does not
leave the hospital.
• As Required by Law
We will disclose Health Information when required to do so by international,
federal, state, or local law.
• To Avert a Serious Threat to Health or Safety
We may use and disclose Health Information when necessary to prevent or
lessen a serious threat to your health and safety or to the health and
safety of the public or another person. Any disclosure, however, will
be to someone who may be able to help prevent the threat.
• Organ and Tissue Donation
If you are an organ donor, we may release Health Information to organizations
that handle organ procurement or organ, eye or tissue transplantation
or to an organ donation bank, as necessary, to facilitate organ or tissue
donation and transplantation.
• Military and Veterans
If you are a member of the armed forces, we may release Health Information
as required by military command authorities. We may also release Health
Information to the appropriate foreign military authority if you are a
member of a foreign military.
• Workers' Compensation
We may release Health Information for workers' compensation or similar
programs. These programs provide benefits for work-related injuries or
• Public Health Risk
We may disclose Health Information for public health activities. These
activities generally include disclosures to prevent or control disease,
injury or disability; report births and deaths; report child, elder and
dependent adult abuse or neglect; report reactions to medications or problems
with products; notify people of recalls of products they may be using;
track certain products and monitor their use and effectiveness; notify
a person who may have been exposed to a disease or may be at risk for
contracting or spreading a disease or condition; and conduct medical surveillance
of the hospital in certain limited circumstances concerning workplace
illness or injury. We also may release Health Information to an appropriate
government or authority if we believe a patient has been a victim of abuse,
neglect or domestic violence; however, we will only release this information
if you agree or when we are required or authorized by law. We may also
notify emergency response employees regarding possible exposure to HIV/AIDS,
to the extent necessary to comply with state and federal laws.
• Health Oversight Activities
We may disclose Health 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.
• Lawsuits and Disputes
If you are involved in a lawsuit or a dispute, we may disclose Health Information
in response to a court or administrative order. We also may disclose Health
Information in response to a subpoena, discovery request, or other lawful
process by someone else involved in the dispute, but only if efforts have
been made to tell you about the request (which may include written notice
to you) or to obtain an order protecting the information requested.
• Law Enforcement
We may release Health Information if asked by a law enforcement official
for the following reasons: (1) in response to a court order, subpoena,
warrant, summons or similar process; (2) limited information to identify
or locate a suspect, fugitive, material witness, or missing person; (3)
about the victim of a crime if, under certain limited circumstances, we
are unable to obtain the person's agreement; (4) about a death we
believe may be the result of criminal conduct; (5) about criminal conduct
on our premises; and (6) in emergency circumstances to report a crime,
the location of the crime or victims, or the identity, description, or
location of the person who committed the crime.
• Coroners, Medical Examiners and Funeral Directors
We may release Health Information to a coroner or medical examiner. This
may be necessary, for example, to identify a deceased person or determine
the cause of death. We also may release Health Information to funeral
directors as necessary for their duties.
• National Security and Intelligence Activities
We may release Health Information to authorized federal officials for intelligence,
counter-intelligence, and other national security activities authorized by law.
• Protective Services for the President and Others
We may disclose Health Information to authorized federal officials so they
may provide protection to the President, other authorized persons or foreign
heads of state or conduct special investigations.
• Security Clearances
We may use medical information about you to make decisions, regarding your
medical suitability for a security clearance or service abroad. We may
also release your medical suitability determination to the officials in
the U.S. Department of State who need access to that information for these purposes.
• Inmates or Individuals in Custody
If you are an inmate of a correctional institution or under the custody
of a law enforcement official, we my release Health Information to the
appropriate correctional institution or law enforcement official. This
release would be made only if necessary (1) for the institution to provide
you with healthcare; (2) to protect your health and safety or the health
and safety of others; or (3) for the safety and security of the correctional
• Multidisciplinary Personnel Teams
We may disclose health information to a multidisciplinary personnel team
relevant to the prevention, identification, management or treatment of
an abused child and the child's parents, or elder abuse and neglect.
• Special Categories of Information
In some circumstances, your health information may be subject to restrictions
that may limit or preclude some uses or disclosures described in this
notice. For example, there are special restrictions on the use or disclosure
of certain categories of information -e.g., tests for HIV or treatment
for mental health conditions or alcohol and drug abuse. Government health
benefit programs, such as Medicaid, may also limit the disclosure of beneficiary
information for purposes unrelated to the program.
You have the following rights regarding Health Information we maintain about
• Right to Inspect and Copy
You have the right to inspect and copy Health Information that may be used
to make decisions about your care or payment for your care. Usually this
includes medical and billing records, but may not include some mental
To inspect and obtain a copy of medical information that may be used to
make decisions about you, you must submit your request in writing to Health
Information Management. If you request a copy of the information, we may charge a fee for the
costs of copying, mailing or other supplies associated with your request.
If needed and at your request, the hospital may provide an electronic
copy of your electronic PHI.
We may deny your request to inspect and obtain a copy in certain very
limited circumstances. If you are denied access to medical information,
you may request that the denial be reviewed. Another licensed health care
professional chosen by the hospital will review your request and the denial.
The person conducting the review will not be the person who denied your
request. We will comply with the outcome of the review.
• Right to Amend
If you feel that Health Information we have is incorrect or incomplete,
you may ask us to amend the information. You have the right to request
an amendment for as long as the information is kept by or for us.
To request an amendment, your request must be made in writing and submitted
to the Health Information Management. In addition, you must provide a reason that supports your request.
We may deny your request for an amendment if it is not in writing or does
not include a reason to support the request. In addition, we may deny
your request if you ask us to amend information that:
• Was not created by us, unless the person or entity that created the
information is no longer available to make the amendment
• Is not part of the medical information kept by or for the hospital
• Is not part of the information which you would be permitted to
inspect and copy; or
• Is accurate and complete
Even if we deny your request for amendment, you have the right to submit
a written addendum, not to exceed 250 words, with respect to any item
or statement in your record you believe is incomplete or incorrect. If
you clearly indicate in writing that you want the addendum to be made
part of your medical record we will attach it to your records and include
it whenever we make a disclosure of the item or statement you believe
to be incomplete or incorrect.
• Right to an Accounting of Disclosures
You have the right to request an accounting of certain disclosures of Health
Information we made. This is a list of the disclosures we made of medical
information about you other than our own uses for treatment, payment and
health care operations (as those functions are described above), and with
other exceptions pursuant to the law.
To request this list or accounting of disclosures, you must submit your
request in writing to the Health Information Management. Your request must state a time period which may not be longer than six
years and may not include dates before April 14, 2003. Your request should
indicate in what form you want the list (for example, on paper or electronically).
The first list you request within a 12-month period will be free. For
additional lists, we may charge you for the costs of providing the list.
We 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.
In addition, we will notify you as required by law following a breach of
your unsecured protected health information.
Right to Request Restrictions
You have the right to request a restriction or limitation on the Health
Information we use or disclose for treatment, payment, or health care
operations. In addition, you have the right to request a limit on the
Health Information we disclose about you to someone who is involved in
your care or the payment for your care, like a family member or friend.
For example, you could ask that we not share information about your surgery
with your spouse.
We are not required, however, to agree to your request, except to the extent that you request us to restrict disclosure to a health
plan or insurer for payment or health care operations purposes if you,
or someone else on your behalf (other than the health plan or insurer),
has paid for the item or service out of pocket in full. Even if you request
this special restriction, we can disclose the information to a health
plan or insurer for purposes of treating you. If we agree, we will comply
with your request unless we need to use the information in certain emergency
To request restrictions, you must make your request in writing to Health
Information Management. In your request, you must tell us 1) what information you want to limit;
2) whether you want to limit our use, disclosure or both; and 3) to whom
you want the limits to apply, for example, disclosures to your spouse.
• Right to Request Confidential Communications
You have the right to request that we communicate with you about medical
matters in a certain way or at a certain location. For example, you can
ask that we contact you only by mail or at work.
To request confidential communications, you must make your request in writing
to the Health Information Management. We will not ask you the reason for your request. Your request must specify
how or where you wish to be contacted. We will accommodate reasonable requests.
• Right to a Paper Copy of This Notice
You have the right to a paper copy of this notice. You may ask us to give
you a copy of this notice at any time. Even if you have agreed to receive
this notice electronically, you are still entitled to a paper copy of
this notice. You may obtain a copy of this notice on our website.
To request any of the above, you must make your request, in writing, to
the Privacy Officer.
CHANGES TO THIS NOTICE
We reserve the right to change this notice. We reserve the right to make
the revised or changed notice effective for Health Information we already
have as well as any information we receive in the future. We will post
a copy of the current notice at the hospital. The notice will contain
the effective date on the first page, in the top right-hand corner. In
addition, each time you register at or are admitted to the hospital for
treatment or health care services as an inpatient or outpatient, we will
offer you a copy of the current notice in effect.
If you believe your privacy rights have been violated, you may file a complaint
with this hospital and/or the Department of Health and Human Services.
All complaints must be made in writing. To file a complaint with:
• This hospital, contact the Health Information Management
• The Department of Health and Human Services, contact:
200 Independence Avenue, S.W.
Room 509F HHH Bldg.
Washington, D.C., 20201
You will not be penalized for filing a complaint.
OTHER USES OF MEDICAL INFORMATION
Other uses and disclosures of medical information not covered by this notice or
the laws that apply to us will be made only with your written permission.
If you provide us permission to use or disclose medical information about
you, you may revoke that permission, in writing, at any time. If you revoke
your permission, this will stop any further use or disclosure of your
medical information for the purposes covered by your written authorization,
except if we have already acted in reliance on your permission. You understand
that we are unable to take back any disclosures we have already made with
your permission, and that we are required to retain our records of the
care that we provided to you.