This NOTICE describes how medical information about you may be used or disclosed and how you can get access to this information. Please review it carefully. If you have questions, please contact Comprehend’s Privacy Officer, whose name and number is at the end of this NOTICE.
Who Will Comply With This Notice
This notice describes Comprehends practices and that of:
· any health care professional authorized to enter information into your medical record.
· all employees, staff and other personnel who may have access to your medical record and the protected health information (PHI) contained therein.
Our Pledge Regarding Your Medical Information
We are required by law to:
· make sure that medical information that identifies you is kept private;
· give you this Notice of our legal duties and privacy practices with respect to medical information about you; and
· follow the terms of the Notice that is currently in effect.
For Treatment. 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, therapists, or other personnel who are involved in your treatment. For example, your PHI may be shared among members of a treatment team or your PHI may be shared with outside entities performing ancillary services relating to your treatment, such as lab work or home health services. Similarly, your doctor may share your medical information with a pharmacy when calling in a prescription.
For Payment. We may use and disclose medical information about you so that the treatment and services you receive at Comprehend 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 to Medicaid, Medicare, Vocational Rehabilitation or your private insurance carrier or health plan information about the care you have received, so that they will pay us or reimburse you for treatment. We may also tell these entities about treatment you are going to receive in order to obtain prior approval or to determine whether your plan will cover the treatment.
For Health Care Operations. We may use and disclose medical information about you in the normal course of operating programs. These uses and disclosures are necessary to insure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. Since we are an integrated system, we may disclose your PHI to designated staff in our central office or other support services and programs. Also, we may share your medical information with entities that review our activities for the purposes of certification or licensure.
We May Use and Disclose Medical Information About You Without Your Authorization in Special Circumstances (Also applies to uses and disclosures from Alcohol or Drug Records)
When Required By Law. We will disclose medical information about you when required to do so by federal, state or local law. Such activities might include reporting to the appropriate governmental agency incidents of child abuse , neglect or domestic violence.
To Avert a Serious Threat to Health or Safety. We may use and disclose medical 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.
Public Health Risks. 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 and deaths;
· 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.
Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order.
Coroners We may release medical information to a coroner. This may be necessary, for example, to identify a deceased person or determine the cause of death.
Unless You Object, We May Use or Disclose Your PHI In The Following Circumstances:
Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at Comprehend. However, you have the right to request that we send your information to an alternate address or by an alternative means. See “Client’s Right To Request Confidential Communication.”
Individuals Involved in Your Care or Payment for Your Care
We may share with a family member, relative or other person identified by you, PHI directly related to that persons involvement in your care or payment for your care.
Any Other Use or Disclosure Requires an Authorization From You
For uses and disclosures beyond treatment, payment and operation purposes, we are required to have your written authorization, unless the use or disclosure falls within one of the exceptions listed above. Authorizations can be revoked at any time to stop future uses/disclosures, except to the extent that we have already undertaken an a use or disclosure.
Your Rights Regarding Your Medical Information
You have the following rights regarding medical information we maintain about you:
Right to Inspect and Request Copy of Your Medical Record You have the right to inspect and/or request a copy of medical information that may be used to make decisions about your care. This includes items in the designated medical record and usually billing records, but it does not include psychotherapy notes.
To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to Comprehend’s Privacy Officer. We will respond to your request within 30 days. 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.
We may deny your request to inspect and 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 Comprehend 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 medical information we have about you 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 Comprehend. To request an amendment, your request must be made in writing and submitted to our Privacy Officer. 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 you can prove the creator of the information is no longer available to amend the record)
· The information is not part of the records used to make decisions about you;
· Is not part of the information which you would be permitted to inspect and copy; or
· Is accurate and complete.
Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures we made of your medical information. The “accounting of disclosures” will detail when, to whom, for what purpose and the content of the disclosure. This list will not contain disclosures made in the context of treatment, payment or operations, made to or requested by you, required by law, or made to individuals involved in your care.
To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer. 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, 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.
Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical 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 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.
To request restrictions, you must make your request in writing to our Privacy Officer. 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 only contact you at work or by mail.
To request confidential communications, you must make your request in writing to our Privacy Officer. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
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 at our website, www.comprehendinc.com or at any of Comprehend’s offices.
Right to File a Complaints If you believe your privacy rights have been violated, you may file a complaint with Comprehend or with the Secretary of the Department of Health and Human Services. All complaints must be submitted in writing. To file a complaint with Comprehend, contact:
Donna Riggs, Privacy Officer
611 Forest Avenue, Maysville KY 41056
564-4016, ext.15
To contact the Department of Health and Human Services you may call or write to the following address:
200 Independence Avenue, S.W.
Washington, D.C. 20201
Telephone: 202-619-0257
