Fellowship Community
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.
OUR PLEDGE REGARDING MEDICAL INFORMATION
We respect the privacy of your protected health information and are committed
to maintaining our resident’s confidentiality. This Notice applies to
all information and records related to your care that our facility has received
or created. It extends to information received or created by our employees and
physicians. This Notice informs you about the possible uses and disclosures
of your protected health information. It also describes your rights and our
obligations regarding your protected health information.
We are required by law to:
• Maintain the privacy of your protected health information;
• Provide this detailed Notice to you describing our legal duties and
privacy practices relating to your protected health information; and
• Abide by the terms of the Notice that are currently in effect.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
The following categories describe different ways that we use and disclose
medical information. For each category of uses and disclosures there is an explanation
and 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.
•For Treatment. We will use and disclose your protected
health information in providing you with treatment and services. We may disclose
your protected health information to facility and non-facility personnel who
may be involved in your care such as physicians, nurses, nurse aids, personal
care aids and therapists. For example, a nurse or personal care aid caring for
you will report any change in your condition to your doctor. We may also disclose
protected health information to individuals who will be involved in your care
after you leave our facility.
•For Payment. We may use and disclose your protected
health information so that we can bill and receive payment for the treatment
and services you receive at our facility. For example, we may disclose your
protected health information to an insurance or managed care company, Medicare,
Medicaid or another third party payor for billing and payment purposes. We may
also contact Medicare or your health plan to confirm your coverage or to request
prior approval for a proposed treatment or service.
•For Health Care Operations. We may use and disclose
your protected health information for facility operations. These uses and disclosures
are necessary to manage the facility and make sure all of our residents receive
quality care. For example, we may use protected health information to review
our treatment and services and to evaluate the performance of our staff in caring
for you. We may also combine the medical information we have with medical information
from other facilities to compare how we are doing and see where we can make
improvements in the care and services we offer.
•For Payment and Health Care Operations of Another Facility.
We may disclose protected health information about you to another health care
provider if the disclosure is for the payment activities of that provider. For
example, we may disclose insurance information about a resident to an ambulance
company. In addition, we may disclose protected health information about you
to another provider if the provider has or had a relationship with you, and
the purpose of the disclosure is related to their health care operational activities,
i.e., accreditation, licensing or credentialing activities. We will limit the
information disclosed to the minimum amount needed in accordance with the request.
•Facility Directory. Unless you object, we may include
certain limited information about you in the facility directory. This information
may include your name, your room number, your phone number, your general condition
(e.g., fair, stable, etc.) and your religious affiliation. Our directory does
not include specific medical information about you. We may release information
in our directory, except for your religious affiliation, to people who ask for
you by name. We may provide the directory information, including your religious
affiliation, to any member of the clergy.
•Birthday Announcements. Unless you object, your birthday
will be recognized during our morning announcement, posted on our activity boards
and published in our Circle of Fellowship. This is so staff, friends and volunteers
can help in the celebration of your birthday.
•Fundraising Activities. Unless you object, we may use
demographic information to contact you in an effort to raise money for the facility
and its operations. We would only use contact information, such as your name,
address and phone number and the dates you received treatment or services.
•Individuals Involved in Your Care or Payment for Your Care.
We will only disclose protected health information with those friends and family
members that you have designated to be involved with your medical care. We may
also give information to someone who helps pay for your care.
•Disaster Relief. We may disclose protected health information
to an organization assisting in a disaster relief effort so that your family
can be notified about your condition, status and location.
•As Required By Law. We will disclose protected health
information when required to do so by federal, state or local law.
•Public Health Activities. We may disclose your protected
health information for public health activities. These activities generally
include the following:
•To prevent or control disease, injury or disability;
•To report deaths;
•To report abuse, neglect or domestic violence;
•To report to the FDA (Food and Drug Administration) reactions to medications
or problems with products;
•To notify residents of recalls of products they may be using;
•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
•For certain purposes involving workplace illness or injuries.
•Health Oversight Activities. We may disclose
your protected health information to a health oversight agency for activities
authorized by law. These oversight activities include, for example, audits,
investigations, inspections and licensure actions. These activities are necessary
for the government to monitor the health care system, government payment or
regulatory programs and compliance with civil rights laws.
•To Avert a Serious Threat to Health or Safety. We may
use and disclose your protected health information, when necessary, to prevent
a serious threat to your health and safety or the health and safety of the public
or another person. However, any disclosure would be made only to someone able
to help prevent the threat.
•Lawsuits and Disputes. If you are involved in a lawsuit
or a dispute, we may disclose your protected health information in response
to a court or administrative order. We may also disclose information in response
to a subpoena, a discovery request, or other lawful process by someone else
involved in the dispute, but only if efforts have been made to contact you about
the request or to obtain and order protecting the information requested.
•Law Enforcement. We may disclose your protected health information
for certain law enforcement purposes, including:
•In response to a court order, subpoena, warrant, summons or similar process;
•To identify or locate a suspect, fugitive, material witness, or missing
person;
•When information is requested about the victim of a crime, if, under
certain limited circumstances, we are unable to obtain the person’s agreement;
•To report information about a death we believe may be the result of criminal
conduct;
•To provide information about criminal conduct occurring at the facility;
and
•To report information 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.
•Military and Veterans. If you are a member
of the armed forces, we may use and disclose your protected health information
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 use or disclose
your protected health information to comply with laws relating to workers’
compensation or similar programs.
•Coroner, Medical Examiners and Funeral Directors. We
may release your protected health information to a coroner, medical examiner,
funeral director, or, if you are an organ donor, to an organization involved
in the donation of organs and tissue. This may be necessary, for example, to
identify a deceased person or determine the cause of death.
•National Security and Intelligence Activities: Protective Services
for the President and Others. We may disclose protected health information
to authorized federal officials conducting national security and intelligence
activities or as needed to provide protection to the President of the United
States, certain other persons or foreign heads of state or to conduct certain
special investigation.
CERTAIN STRICTER REQUIREMENTS THAT WE FOLLOW
Several state laws may apply to your protected health information that
set a stricter standard than the protections offered under the federal health
privacy regulations. Stricter state law in Pennsylvania will for example, limit
us from disclosing medical records containing HIV related information; medical
records containing drug and alcohol abuse information; and medical records containing
psychiatric and psychological treatment. State law dictates to whom and under
what circumstances disclosure is appropriate. Generally, release of this information
is contingent upon your specific consent, or pursuant to a court order.
OTHER USES OF MEDICAL INFORMATION
Other uses and disclosures of your protected health information not
covered by this Notice or the laws that apply to us will be made only with your
written Authorization. You may revoke your Authorization to use and disclose
protected health information in writing, at any time. If you revoke your Authorization,
we will no longer use or disclose your protected health information for the
purposes covered by the Authorization. We are unable to take back any disclosures
we have already made with your permission, and we are required to retain our
records of the care that we provided to you.
YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION
You have the following rights regarding medical information we maintain
about you:
•Right to Inspect and Copy. You have the right to inspect
and copy medical or billing records that may be used to make decisions about
your care, subject to some limited exceptions. We must allow you to inspect
your records within 24 hours of your request, excluding holidays and weekends.
If you request copies of the records, we must provide you with copies within
2 business days of the request. We may charge a reasonable fee for the cost
of copying and mailing your requested information.
We may deny your request to inspect and copy in certain very limited circumstances.
If you are denied access to protected health information, you may request that
the denial be reviewed. Another licensed health care professional chosen by
the facility will review your request and the denial. The person conducting
the review will not be the person who originally denied your request. We will
comply with the outcome of the review.
•Right to Amend. If you feel that medical information
we have about you is incorrect or incomplete, you may ask us to amend the information.
You have the right to request the facility to amend any protected health information
maintained by the facility for as long as the information is kept by or for
the facility. To request an amendment, your request must be in writing and must
state the reason for the requested amendment.
We may deny your request for an amendment if the information:
•Is not in writing or does not include a reason to support the request;
•Was not created by us, unless the originator of the information is no
longer available to make the amendment;
•Is not part of the protected health information maintained by or for
the facility;
•Is not part of the protected health information to which you have a right
or access; or
•Is already accurate and complete, as determined by the facility.
If we deny your request for amendment, we will give you a written denial including
the reasons for the denial and the right to submit a written statement disagreeing
with the denial.
•Right to Request Restrictions. You have the right to
request a restriction or limitation on the protected health information we use
or disclose about you for treatment, payment, or health care operations. You
also have the right to restrict the protected health information we disclose
about you to a family member, friend or other person who is involved in your
care or the payment for your care. This request must be made in writing. For
example, you could ask that we not use or disclose information about a surgery
you had.
We are not required to agree to your request. If we do agree, we will
comply with your request unless the information is needed to provide you emergency
treatment or the release of information is required by law.
•Right to an Accounting of Disclosures. You have the
right to request an “Accounting of Disclosures” of your protected
health information. This is a listing of certain disclosures of your medical
information made by the facility on your behalf, but does not include disclosures
for treatment, payment and health care operations or when the disclosure is
authorized.
To request this list of Accounting of Disclosures, you must submit your request
in writing to the Director of Health Information. Your request must state a
time period that may not be longer than six years from the date of your request
and may not include dates before April 14, 2003. An accounting will include,
if requested: the disclosure date, the name of the person or entity that received
the information and address, if known, a brief description of the information
disclosed, and a brief statement of the purpose of the disclosure. The first
accounting provided in a 12 month period will be free. For providing additional
lists, we may charge you our costs.
•Right to Request Confidential Communications. You have
the right to request that we communicate with you concerning protected health
matters in a certain manner or at a certain location. For example, you can request
that we contact you only at a certain phone number. We will accommodate your
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.
CHANGES TO THIS NOTICE
We reserve the right to change this Notice and to make the revised
or new Notice provisions effective for all protected health information already
received and maintained by the facility as well as for all protected health
information we receive in the future. We will promptly revise and distribute
this Notice whenever there is a material change to the uses or disclosures,
your individual rights, our legal duties, or other privacy practices stated
in this Notice. We will post a copy of the Notice in the facility. In addition,
we will distribute a copy of the revised Notice to all residents currently residing
in the facility at the time of the revision.
COMPLAINTS
If you feel your privacy rights have been violated, you may file a
complaint in writing to the facility or with the Office of Civil Rights in the
United States Department of Health and Human Services. To file a complaint with
the facility contact Linda Cook, Director of Admissions/Social Service at 610-769-4312
or Pamela Lackman, Privacy Officer at 610-769-4347. We will not retaliate against
you if you file a complaint.
FOR FURTHER INFORMATION
If you have any questions about this Notice or would like further information
concerning your privacy rights, please contact Linda Cook, Director of Admissions/Social
Service at 610-769-4312 or Pamela Lackman, Privacy Officer at 610-769-4347
EFFECTIVE DATE: April 14, 2003