NOTICE OF PRIVACY PRACTICES

EAR, NOSE, THROAT & FACIAL PLASTIC ASSOCIATES OF MONTGOMERY COUNTY, LTD

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU MAY GAIN ACCESS TO THIS INFORMATION.  WE ARE REQUIRED BY THE FEDERAL PRIVACY RULE TO PROVIDE YOU WITH THIS NOTICE. WE ARE REQUIRED TO MAINTAIN THE PRIVACY OF YOUR HEALTH INFORMATION AND TO PROVIDE YOU WITH NOTICE OF OUR LEGAL DUTIES AND PRIVACY PRACTICES WITH RESPECT TO YOUR PROTECTED INFORMATION. THIS POLICY IS EFFECTIVE 4/14/03.

 PLEASE READ IT CAREFULLY

If you have any questions regarding this notice, please contact:

Privacy Officer, Ear, Nose, Throat & Facial Plastic Associates of Montgomery County, Ltd.

306 West Logan Street, Norristown,              PA 19401             Phone: 610-275-6153 Fax: 610-278-7709

YOUR HEALTH INFORMATION: Generally speaking, your protected health information is any information that relates to your past, present or future physical or mental health or condition, the provision of health care to you or payment for health care provided to you, and individually identifies you or reasonably can be used to identify you. Your medical and billing records at our practice are examples of information usually regarded as protected health information.

USES AND DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION: We may use and disclose your protected health information for treatment, payment and healthcare operation purposes. Not every possible use or disclosure will be listed.

TREATMENT: We may use and disclose your protected healthcare information for treatment purposes. Treatment includes the provision, coordination or management of healthcare services to you by one or more healthcare providers.  We may disclose health information about you to our office personnel who are involved with your care.

Different personnel in our office may share information about you and disclose information to people who do not work in our office in order to coordinate your care. We may share information with an outside laboratory, radiology center, hospital, medical equipment supply company, pharmacy, or home health agency or other health care facility where we are treating or referring you.

We may share and discuss your medical information with an outside physician to whom we have referred you for care or are consulting regarding you. We may share and discuss your information with another healthcare provider who seeks information for the purpose of treating you. We may also share information with the physician or healthcare provider who referred you to us for treatment. 

We may call patients by name in our waiting room. We may contact you to provide appointment reminders, change or schedule appointments, including leaving messages on your answering machine and mailing you postcard reminders. We may contact you to provide test results, respond to your questions or prescription requests, or call concerning your medical condition. We may leave messages on your telephone answering machine.

PAYMENT: We may use and disclose your protected health information for our payment purposes as well as payment purposes of other healthcare providers and health plans. Payment uses and disclosures include activities conducted to obtain payment for the care provided to you or so that you can obtain reimbursement for that care.

Sharing information with your health insurer to obtain payment, verify eligibility for coverage, whether a proposed treatment is covered by your insurance, provide supplemental information or records to support medical necessity or quality audit review, for coordination of benefits, or to submit a medical claim form on your behalf.

We may share or disclose your demographic information with other healthcare providers who seek this information to obtain payment for healthcare services provided to you.

Mailing you bills in envelopes with our practice name and return address. Providing a bill to a family member or other person designated as responsible for payment for services rendered to you.

Providing information to a collection agency, our attorney, consumer-reporting agency, or in a legal action for the purposes of securing payment.

HEALTH CARE OPERATIONS: We may use and disclose your protected health information for our healthcare operation purposes as well as certain healthcare operation purposes of other healthcare providers and health plans. Some examples of this purpose include.

Quality assessment and improvement activities such as reviewing the competence, qualifications, or performance of healthcare professionals, conducting training programs for medical and other students, population based activities relating to improving health or reducing healthcare costs, healthcare fraud and abuse detection and compliance programs, and conducting medical review, legal services and auditing functions.               

Other business management and general administrative activities, such as resolution of patient grievances, business planning and development activities such as cost management. For accreditation, certification, licensing, and compliance activities. Sharing information regarding patients to entities interested in purchasing our practice or turning over patient records to entities that have purchased our practice.

USES AND DISCLOSURES FOR OTHER PURPOSES: We may use and disclose your protected health information for other purposes. This generally describes purposes by category and includes examples. Not every use or disclosure will be listed.

Individuals involved in care or payment for care: We may disclose your protected health information to someone involved in your care or payment for your care, such as a spouse, family member or close friend. Such as if you have surgery, we may discuss your physical limitations with a family member assisting in your care.

Notification Purposes: We may use and disclose your protected health information to notify, or assist in notification of a family member, personal representative, or other person responsible for your care, regarding your location, general condition, or death.  We may also disclose information to a disaster relief entity, such as the Red Cross.

Required by Law: We may disclose protected health information when required by federal, state or local law. Examples are mandatory reporting requirements such as birth, death, child abuse, disease prevention and control, vaccine-related injuries, medical device-related deaths, and serious injuries, gunshot and other injuries by deadly weapon or criminal act, driving impairments and blood alcohol testing.

Other Public Health Activities: Including public health reporting such as: communicable disease reports, child abuse and neglect reporting: OSHA requirements for workplace surveillance and injury reports: public health warnings to third parties at risk of a communicable disease or condition: and adverse event reports.

Victims of abuse, neglect or domestic violence:  We may use and disclose information for purposes of reporting including elder abuse to the Department of Aging or abuse of a nursing home patient to the Department of Public Welfare.

Health oversight activities:  We may use and disclose protected health information for purposes of health oversight activities authorized by law. Activities could include audits, inspections, investigations, licensure actions and legal proceedings. For example, we may comply with a Drug Enforcement Agency inspection of patient records

Judicial and administrative proceedings: We may use and disclose protected health information in judicial and administrative proceedings in response to a court order or subpoena, discovery request or other lawful process.

Law enforcement purposes: Comply with legal process or requirement such as a search warrant, mandatory reporting of gun shot wounds or a death suspected to have resulted from criminal activity, provide information regarding a crime victim or information for identification or location purposes. Providing information regarding a crime on our premises or reporting a crime in an emergency.

Coroners/medical examiners/funeral directors: We may use and disclose protected information for purposes of providing information as necessary to carry out their duties.

Organ and tissue donation: For the purposes of facilitating organ, eye and tissue donation and transplantation to entities engaged in the procurement, banking, or transplantation of cadaver organs, eyes or tissue.

Threat to public safety: We may use and disclose protected information for purposes involving a threat to public safety, including protection of a third party from harm and identification and apprehension of a criminal

Specialized government functions: Such as: Military and veterans activities, national security and intelligence, protective services for the President and others, medical suitability determinations for the Department of State, correctional institutions and other law enforcement custodial situations.

Workers’ compensation and similar programs: We may use and disclose protected health information as authorized by and to the extent necessary to comply with laws relating to workers’ compensation or similar programs, established by law, that provide benefits for work-related injuries or illness without regard to fault. This would include submitting a claim for payment to the employer’s workers’ compensation carrier if we treated you for a work injury.

Business associate: A business associate, such as a billing company, an accounting firm, or law firm, may perform certain functions of the practice. We may disclose protected information to our associates and allow them to create and receive protected information of our behalf. For example, we may share with our billing company information regarding your care and payment for your care so that the company can file health insurance claims and bill you or another responsible party.

Creation of de-identified information: We may use protected health information about you in the process of de-identifying the information. For example, we may use your health information in the process of  removing those aspects, which would identify you so that the information can be disclosed to a researcher without your authorization.

Incidental disclosures: We may disclose protected health information as a by-product of an otherwise permitted use or disclosure. For example, other patients may overhear your name being called in the waiting room.

USES AND DISCLOSURES WITH AUTHORIZATION: For all other purposes, which do not fall under a category listed above, we will obtain a written authorization to use or disclose your protected health information. Your authorization can be revoked at any time except that we have relied on the authorization.

PATIENT PRIVACY RIGHTS

FURTHER RESTRICTION ON USE OR DISCLOSURE: You have the right to request that we further restrict use and disclosure of your protected health information to carry out treatment, payment, or health care operations, to someone who is involved in their care or payment for your care, or for notification purposes. We are not required to agree to a request for further restriction. To request a restriction, you must submit a written request to our privacy officer. The request must tell us: what information you want to restrict: how you want the information restricted: and to whom you want the restriction to apply.

CONFIDENTIAL COMMUNICAITON: You have a right to request that we communicate your protected health information to you by a certain means or at a certain location. For example, you may request that we only contact you by mail or at work. We are not required to agree to requests for confidential communications that are unreasonable. You must submit your request in writing to the privacy officer. You must tell us how or where you want us to contact you and if another entity is responsible for payment, the request must explain how payment will be handled.

ACCOUNTING OF DISCLOSURES: You have a right to obtain, upon request, an “accounting” of certain disclosures of your health information by us (or a business associate for us). This right is limited to disclosures within six years of the request and other limitations. In limited circumstances, we may charge you for providing the accounting.  You must submit your request in writing to the privacy officer, designating the applicable time period.

INSPECTION AND COPYING:  You have a right to inspect and obtain a copy of your protected health information that we maintain in a designated records set. This right is subject to limitations and we may impose a charge for the labor and supplies involved in providing copies. To exercise your right of access, you must submit your request in writing to the privacy officer. Your request must include: a description of the health information for which access is being requested; state how you want to access the information (inspection, copy, mailing of a copy); specify requested form or format; and include the mailing address if applicable.

RIGHT TO AMENDMENT: You have the right to request that we amend protected health information that we maintain about you if the information is incorrect or incomplete. This right is subject to limitations. To request an amendment, you must submit a written request to our privacy officer. The request must specify each change that you want and provide a reason to support each requested change.

CHANGES TO THIS NOTICE: We reserve the right to change this notice at any time. We further reserve the right to make any change effective for all protected health information that we maintain at the time of the change – including information that we created or received prior to the effective date of the change. We will post a copy of our current notice in the waiting room for the practice. At any time, patients may review the current notice by contacting the privacy officer.

COMPLAINTS: If you believe that we have violated your privacy rights, you may submit a complaint to the privacy officer or the Secretary of Health and Human Services. To complain to the practice, submit a written complaint to our privacy officer. We will not retaliate against you for filing a complaint.

LEGAL EFFECT OF THIS NOTICE:  This notice is not intended to create contractual or other rights independent of those created in the federal privacy rule.