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 READ IT CAREFULLY.
Effective
Date: April 14, 2003
Purpose: Federal
law requires Surgical Associates, S.C. to inform its patients about the ways
that Surgical Associates, S.C. may use and disclose your protected health
information. In addition, federal law requires Surgical Associates, S.C. to
inform patients of your rights regarding disclosures of your health
information.
It is the policy of Surgical Associates, S.C. to keep
medical information confidential and not disclose patient protected health
information without your consent, authorization or as specifically allowed by
the federal privacy law or other federal or state law as described in this
notice. We are required to abide by the terms of our Privacy Notice that is
currently in effect.
All Surgical Associates, S.C. patients have a right to read
this notice. Any question about Surgical Associates, S.C.’s privacy practices
or questions you may have regarding possible violations of your privacy may be
directed to Surgical Associates, S.C. clinic personnel. To facilitate
complaints, Surgical Associates, S.C. requests that you use our complaint form
available at the clinic reception desk. This form will be sent to the Surgical
Associates, S.C. Privacy Officer who will address any concerns. No patient will
be retaliated against for filing a complaint.
All forms and policies referred to in this document are
available to you through Surgical Associates, S.C. Reception and through the
Surgical Associates, S.C. Privacy Officer.
The Surgical Associates, S.C. Privacy Officer can be
reached at:
Surgical Associates, S.C.; Attn: Privacy Officer; 425 Pine
Ridge Blvd., Suite 200, Wausau, WI
54401; (715) 847-2022.
In addition to filing a complaint at Surgical Associates,
S.C., any patient may also contact the federal government directly,
specifically the Department of Health and Human Services at the contact
information below:
The U.S. Department of Health and
Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
(202) 619-0257
Toll Free: 1-877-696-6775
Email: hhsmail@os.dhhs.gov
USES
AND DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION
Surgical Associates, S.C. may use and disclose protected
health care information without your consent or authorization in certain
circumstances. For purposes of treatment, payment and health care operations,
Surgical Associates, S.C. may make use of or disclose your information once you
have signed our Consent to Use Protected
Health Information form. State and federal law allow Surgical
Associates, S.C. to use/disclose your protected health information in other defined
circumstances as well. Except in treatment circumstances, Surgical Associates,
S.C. will make efforts to limit the information used or disclosed to that which
is minimally necessary. Following are a listing of these circumstances and
examples of uses and disclosures to assist your understanding of our privacy
practices.
1.
Treatment: Once you
sign a consent, Surgical Associates, S.C. will use your protected health
information in order to treat you in the Surgical Associates, S.C., to
facilitate appropriate transfer of information to consulting specialists or
referral center of health care (e.g., the hospital or surgical centers), and to
ensure continuity of care and coordinate your health care through case
management.
Examples of this type of
disclosure follow. Surgical Associates, S.C. doctors and nursing staff will
need to access your health information regarding medications and ongoing
medical problems to best manage your care at Surgical Associates, S.C.. In
addition, we may need to send selective information to specialists. For
example, we might send EKG or cholesterol results to a cardiologist to consult
him or her. To ensure optimal continuity of care, Surgical Associates, S.C.
will send pertinent copies of X-rays and labs to a hospital so as to avoid
repeating tests and to prepare the health care providers at the hospital for
your arrival.
2.
Payment: Surgical
Associates, S.C. will use and disclose your health information to send bills
and to collect payment from you, your insurance company and other third-parties
for services you have received at Surgical Associates, S.C..
Examples of this type of
disclosure include sending health information about dates of service and type
of service/procedures performed to your health insurance company in order to
receive reimbursement. In addition, some health insurance companies require
pre- certification for some procedures and Surgical Associates, S.C. may have
to disclose the type of procedure to be performed and the diagnosis justifying
the procedure.
3.
Health
Care Operations: In order to ensure quality care for our patients,
Surgical Associates, S.C. engages in numerous health care operations. These
health care operations include, but are not limited to:
·
Care management and case coordination
·
Guideline and protocol development
·
Administrative and business management activities
·
Business planning and development
·
Training, accreditation, certification, licensing or
credentialing
·
Health care improvement and quality management programs
·
Health care cost-reduction programs
·
Staff competence and provider reviews
·
Legal and accounting services
·
Medical review and auditing
·
Investigating and resolving internal grievances
Some specific examples of how
Surgical Associates, S.C. would use your protected health information in its
health care operations include the following:
·
Removal of personal identifying information from your
record so that it can be used to help evaluate guideline use for chronic health
problems like back pain, depression, asthma or hyperlipidemia.
·
Evaluation of medications you have been issued from a
pharmacy to decide which medications are most cost effective.
·
Conducting patient satisfaction surveys each year. Surgical
Associates, S.C. may reference your chart if you comment in the survey that you
were not satisfied with the care you received.
·
Presenting patient cases to national review and
certification boards as part of ongoing training. If your information is used
in a case presentation it would be de-identified.
·
Using and disclosing your medical information to recommend
treatment options that may be of interest to you.
4.
Federal,
State of Local Law: Surgical Associates, S.C. will disclose your protected
health information when required to do so by state, federal or local law.
For example, Surgical Associates,
S.C. will report gunshot wound information and information about suspicious
burns to the local police or sheriff.
5.
Public
Health Policy: Surgical Associates, S.C. will disclose your health
information to public health departments and agencies if required to do so by
law.
For example, diseases such as
hepatitis, TB and certain sexually transmitted diseases are reported to public
health departments. Additionally, some adverse side effects are reported to the
FDA.
6.
Organ
and tissue donation: If needed, Surgical Associates, S.C. may disclose
protected health information to relevant organization to facilitate organ and
tissue donation and transplantation.
7.
Research: Surgical
Associates, S.C. sometimes participates in research studies for new treatments
and would share protected health information with the research organization. In
these circumstances, any Surgical Associates, S.C. patient participating in the
research study would sign a separate consent to be in the study and to share
specific health information.
8.
Circumstances
of Serious and Imminent Threat to Health or Safety: If there
is a serious and imminent threat to your health or safety or the health or
safety of the public or another person, Surgical Associates, S.C. may disclose
your protected health information.
9.
Victims
of Abuse or Neglect: Surgical Associates, S.C. will notify the
appropriate government authority if Surgical Associates, S.C. believes a
patient has been the victim of abuse or neglect.
For example, Surgical Associates,
S.C. will contact Child Protective Services in cases of suspected or alleged
child abuse.
10.
Coroners
and Medical Examiners: Surgical Associates, S.C. may disclose information
to a coroner or medical examiner to assist with determining the cause of a
death.
For example, if a patient dies
and their death is investigated by the medical examiner, the medical examiner
may contact Surgical Associates, S.C. to determine what health problems the
patient may have had and what medications the patient was taking prior to
his/her death.
11.
Health
Oversight Activities: Surgical Associates, S.C. may disclose protected
health information to certain health oversight activities authorized by law
including audits, investigations, accreditations, licensure or disciplinary
activities.
For example, the Department of
Health and Human Services is authorized to access protected health information
to investigate violations of the HIPAA Privacy Rule.
12.
Worker’s
Compensation: Surgical Associates, S.C. may disclose your medical
records to worker’s compensation departments for the benefit of treatment and
case management of work-related injuries.
For example, if you injure your
back at work, Surgical Associates, S.C. may release recommendations on your
diagnosis, treatment, work modification/time off and expected length of illness
to the worker’s compensation department.
13.
Government
Functions: In some circumstances, Surgical Associates, S.C. can
disclose your protected health information for specific government activities.
Examples of these include:
·
Inmates and Law Enforcement Custody: If you are an inmate,
Surgical Associates, S.C. may disclose medical information to the correctional
institute or law enforcement as necessary.
·
Medical Suitability Determinations: Surgical Associates,
S.C. may disclose your protected health information to the Department of State
for use in making medical suitability determinations.
·
Military and Veterans: If you are a member of the armed
forces, Surgical Associates, S.C. may disclose your protected health
information to the government to facilitate military missions.
·
National Security and Intelligence: If authorized by law,
Surgical Associates, S.C. may disclose your protected health information for
intelligence, counter-terrorism and national security activities.
·
Protective Services for the President and Others: In order
to provide protection to the president or foreign heads of state, Surgical
Associates, S.C. may need to disclose your protected health information, only
if authorized by law.
14.
Judicial
Proceedings: Surgical Associates, S.C. may release protected health
information in response to a court order.
Examples of these kinds of
disclosures include:
·
In response to a subpoena, court order, warrant or summons.
·
Identification or location procedures of suspects,
fugitives, material witnesses or missing persons.
·
Release of information concerning the victim of a crime
(only in circumstances where efforts have been made to inform you about the
request or efforts have been made to protect the information requested).
·
Information about a death Surgical Associates, S.C.
believes may be the result of criminal activity.
·
Information about criminal activities that occur at
Surgical Associates, S.C..
·
In emergency circumstances to report a crime, the location
of a crime or victims, or the identity, description or location of the person
who committed the crime.
DISCLOSURES
THAT YOU MAY OBJECT TO
Unless you object, Surgical Associates, S.C. may also use
or disclose limited medical information in the following situations:
1.
Surgical Associates, S.C. 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.
2.
Surgical Associates, S.C. currently does not use your
health information for fundraising purposes. If Surgical Associates, S.C. chose
to use your information for fundraising, Surgical Associates, S.C. would get
your approval for this disclosure prior to any release of information.
3.
Surgical Associates, S.C. currently does not use your
information for external marketing purposes and will not use any health
information for marketing unless you have given specific consent for this
disclosure. Please see the Marketing Policy for full
details.
4.
Surgical Associates, S.C. will release medical information
to a family member or friend regarding your condition only as you specifically
designate and have consented to. This is fully detailed in the Facility Directory Policy.
Any other uses or disclosures will be made only with your
written authorization and you may revoke this authorization in writing at any
time. Surgical Associates, S.C. requests that you use our Authorization for Release of Medical Information and our Revocation of Authorization to Release Medical Information forms for
these purposes.
Patient
Rights Regarding Protected Health Information
As a patient, you have numerous rights regarding how your
protected health information is used. Your rights include the following:
1.
You
have a right to request that we restrict our uses and disclosures of protected
health information. For example, Surgical Associates, S.C. will permit a patient to request that it restrict uses or
disclosures of protected health information about the patient to carry out
treatment, payment or health care operations; disclosures of protected health
information directly relevant to the involvement of a family member, personal
representative or another person responsible for the care of the patient; or to
entities involved in disaster relief purposes. The circumstances in which you can
request restrictions are detailed in the Policy for Requesting Restrictions of
Protected Health Care Information. It is important to understand that
Surgical Associates, S.C. is not
required to agree to requests for restrictions.
2.
You have a right to receive communications that contain
protected health information at alternative locations or by alternative means.
For example, patients may request that Surgical Associates, S.C. contact them
at work for appointment reminders rather than at home provided that the patient
provides Surgical Associates, S.C. with his or her work contact number.
However, Surgical Associates, S.C. will not honor a request for alternative
contact methods unless the patient provides sufficient alternative address or
contact information. These are detailed in the Policy for
Requesting Restrictions of Protected Health Care Information.
3.
You have the right to inspect and copy your protected
health information. Surgical Associates, S.C. requests that you use the Authorization for Release of Medical Information form when
exercising this right. Surgical Associates, S.C. may charge a reasonable fee
for the costs of copying, mailing or preparing summary information that
responds to your request. You should know that in certain limited circumstances,
the law allows Surgical Associates, S.C. to deny your request to inspect and
copy your records. The full policy and procedures regarding this are detailed
in the Policy on Individual Access to Protected
Health Information.
4.
You have the right to have changes made to your protected
health information if you feel it is inaccurate. Surgical Associates, S.C.
requests that you use our Request for Amendment of
Health Information form to request these changes. Surgical Associates, S.C.
will review your request and make the changes if we believe they are
appropriate. Surgical Associates, S.C. will also distribute these changes to
health care providers that you ask be made aware of the change or to others we
believe should know of the change. Under some circumstances, Surgical
Associates, S.C. may deny your request for an amendment to your protected
health information. Surgical Associates, S.C. will provide a written response
to your request for an amendment and in this response will provide detailed
information on how you may review the changes or appeal the denial. Your right
to amend health care information is fully detailed in the Patient Request To Amend Medical Records Policy.
5.
You have a right to receive an accounting of our
disclosures of your protected health information by Surgical Associates, S.C..
This accounting will not include disclosures of your health information made
for treatment, payment or health care operations. Surgical Associates, S.C.
requests that you use the Request for Accounting of
Protected Health Information form to receive this log. Your request must specify a time
period for the accounting, which may be no longer than six years. Surgical
Associates, S.C. will provide the first accounting to you in any 12-month
period free-of-charge. After this, Surgical Associates, S.C. may charge a fee
but we will notify you of the fee before we process the request. You have the
right to withdraw your request once you have learned that your request will
require you to pay a fee. The full details of our policy and procedures for
receiving a log of disclosures of your protected health information and the
circumstances in which disclosures will not be provided in the accounting is
described in the Policy on Accounting of
Disclosures of Protected Health Information.
6.
You have a right to receive a paper copy of this Privacy
Notice at any time. If you have received an electronic version of this Privacy
Notice you may also request a paper copy. Paper copies are available through
Reception or may be printed from our web site. You may call or write Reception
at: Surgical Associates, S.C.; 425
Pine Ridge Blvd., Suite 200, Wausau, WI
54401; (715) 847-2022.
Distribution
and Revision of the Privacy Notice
Surgical Associates, S.C. is required by federal law to
maintain the privacy of protected health information and to provide patients
with notice of its legal duties and to abide by the terms of this Privacy
Notice. Surgical Associates, S.C. will distribute this privacy notice to all
clinic patients who will be seen on or after the effective date. Surgical
Associates, S.C. will post the notice in a clear and prominent location in all
of its clinics and on its web site. Surgical Associates, S.C. will provide the
Privacy Notice via email to any requesting patient who agrees to an electronic
notice. Surgical Associates, S.C. patients may, at any point, withdraw their
agreement to an electronic Privacy Notice. Any patient who receives an
electronic Privacy Notice may also obtain a paper copy if requested.
Surgical Associates, S.C. is allowed to make revisions to
the Privacy Notice. If revisions are made, the notice of these revisions will
be distributed to current patients of Surgical Associates, S.C. within 60 days
of a revision as well as information on how to obtain a copy of the revised
Privacy Notice.
Other:
All forms and policies referred to in this Privacy Notice are available for you at Surgical Associates, S.C. Reception or through the Surgical Associates, S.C. Privacy Officer.