Effective Date: April 14, 2003 Notice of Privacy Practices
MERS/MISSOURI GOODWILL INDUSTRIES- EMPLOYMENT TRAINING DIVISION, (“MMGI-ETD”)
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.
MMGI-ETD is required by law to maintain the privacy of your Protected Health Information (“PHI”) and to provide you with notice of its legal duties and privacy practices with respect to your PHI and to comply with the terms of our Notice of Privacy Practices currently in effect. PHI is any information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services. If you have questions about any part of this notice or if you want more information about the privacy practices at MMGI-ETD please contact the MMGI-ETD, Privacy Official, 1727 Locust St., St. Louis, Missouri 63103 1-800-727-6320 or 314-241-3464.
You may obtain PDF copy of this Notice at this link: :http://mersgoodwill.org/hipaa/HIPAA_2004.pdf .
I. How MMGI-ETD May Use or Disclose Your Health Information
MMGI-ETD collects health information about you and stores it in a chart which is your record. We need this information to provide you with quality care and to create a record of the care and services you receive at MMGI-ETD. MMGI-ETD is committed to protecting the privacy of your health information. The law permits MMGI-ETD to use or disclose your health information for the following purposes:
A. Uses and Disclosures for Treatment Payment and Healthcare Operation.
1. Treatment. We may use PHI about you to provide you with medical treatment or services. For example, we may disclose PHI about you to doctors, psychologists, pharmacists, nurses, social workers, therapists, technicians, or other personnel involved in providing services to you. Different departments of MMGI-ETD may also share PHI about you in order to coordinate the different services you need.
2. Payment. We may use and disclose PHI about you so that the treatment and services you receive at MMGI-ETD or other providers from whom you receive treatment or services, may be billed to, and payment may be collected from, you, an insurance company, a third party, Medicaid or other payor. For example, we may disclose certain case management information to Medicaid in order to be paid for the services we perform. To the extent possible, our staff and outside contractors or consultants will make reasonable efforts to assure that the use and disclosure of your personal health information is conducted in a secure and confidential manner.
3. Health Care Operations. MMGI-ETD may use and disclose PHI about you for agency operations. These uses and disclosures are necessary to manage the operation and to monitor your quality of care. For example, we may use personal health information to evaluate our agency’s services, including the performance of our staff. We may also use personal health information for training purposes or to develop new policies, procedures, or programs that may benefit you or other individuals we support. Your medical information may be shared with survey reviewers and other accreditation bodies in accordance with current and on-going operating procedures.
4. Information provided to you. We may also provide certain services by contracting with third parties, referred to as Business Associates. In some cases, we will need to disclose your PHI to a Business Associate in order for them to provide the appropriate services to you. We will only disclose your PHI to a Business Associate after we have received adequate contractual assurances from them that they will safeguard and keep confidential your PHI.
B. Uses and Disclosures With the Opportunity For You to Object
1. Notification and communication with family. We may disclose your health information to notify or assist in notifying a family member, your personal representative or another person responsible for your care about your location, your general condition or in the event of your death. If you are able and available to agree or object, we will give you the opportunity to do so prior to making this notification. If you are unable or unavailable to agree or object, our health professionals will use their best judgment in communication with your family and others.
2. Directory. Unless you object, we will maintain a directory of clients to whom MMGI-ETD presently provides services. We will confirm your eligibility or participation in a program if someone calls to obtain such confirmation and inquiries by name. 3. Treatment Alternatives and Reminders. Unless you object, we may use or disclose your PHI as necessary to contact you to remind you of appointments or services. We may also contact you to make you aware of other services that may benefit you or for which you may be eligible.
C. Uses and Disclosures of Your PHI For Other Specific Purposes We May Make Without Your Consent or Authorization, or Opportunity to Object
1. Required by law. We may use and disclose your PHI as required by federal, state or local law. The use or disclosure will be limited to the requirements of the relevant law.
2. Public health. We may disclose your PHI to public health authorities for purposes related to: preventing or controlling disease, injury or disability; reporting abuse or neglect; reporting domestic violence; reporting to the Food and Drug Administration problems with products and reactions to medications; and reporting disease or infection exposure.
3. Health oversight activities. We may disclose your PHI to health agencies, including state rehabilitation agencies during the course of audits, investigations, inspections, licensure and other proceedings.
4. Judicial and administrative proceedings. We may disclose your PHI in the course of any administrative or judicial proceeding as required by a court order or subpoena.
5. Law enforcement. We may disclose your PHI to a law enforcement Officer for purposes such as identifying or locating a suspect, fugitive, material witness or missing person, complying with a court order or subpoena and other law enforcement purposes. 6. Deceased person information. We may disclose your PHI to coroners, medical examiners and funeral directors or state rehabilitation agencies.
7. Public safety. We may disclose your PHI to appropriate persons in order to prevent or lessen a serious and imminent threat to the health or safety of a particular person or the general public.
8. Specialized government functions. We may disclose your PHI for military, national security, and prisoner purposes. 9. Worker’s compensation. We may disclose your PHI as necessary to comply with worker’s compensation laws.
Only the minimum necessary health information will be disclosed to accomplish the above purposes. In addition, if Missouri law materially limits or prohibits any of the uses and disclosures described above, each such use and disclosure described above must reflect the more stringent law.
II. Your Authorization is Required For Other Uses of PHII
Except as described in this Notice of Privacy Practices, MMGI-ETD will not use or disclose your health information without your written authorization. If you do authorize MMGI-ETD to use or disclose your health information for another purpose, you may revoke your authorization in writing at any time.
III. Your Health Information Rights
1. You have the right to request restrictions on certain uses and disclosures of your PHI. MMGI-ETD is not required to agree to the restriction that you requested. We ask that such requests be made in writing. Appropriate forms may be obtained from MMGI-ETD’s Privacy Official listed below.
2. You have the right to inspect and copy your health information. In order to inspect or copy your PHI, you must submit a written request to us. We may charge you a reasonable fee for the cost of such copies. By law, your access to inspect or copy certain records, such as psychotherapy notes or information complied in anticipation of litigation may be limited. Depending on the circumstances, a decision to deny access may be reviewable.
3. You have the right to request or receive confidential communications regarding PHI in a certain manner at a certain location. For example, you may request that we contact you at home rather than at work. We will not request an explanation as to the basis for the request. You must make any such request in writing to the Privacy Official. We will accommodate reasonable requests.
4. You have a right to request that MMGI-ETD amend your PHI that is incorrect or incomplete. MMGI-ETD is not required to change your PHI and will provide you with information about any denial to amend and how you request a review. We ask that such requests be made in writing. Appropriate forms may be obtained from MMGI-ETD’s Privacy Official listed above. If we deny your request, you have the right to file a statement of disagreement and to have your statement included with any subsequent disclosure.
5. You have a right to receive an accounting of disclosures of your PHI made by MMGI-ETD, except that MMGI-ETD does not have to account for the disclosures for treatment payment, health care operations, information provided to you, and certain government functions of section I and II of this Notice of Privacy Practices. You may request a list of disclosures made by MMGI-ETD for a period of up to six (6) years prior to your request. Disclosures made prior to April 14, 2003, are not subject to this accounting. The first list provided in any 12-month time period is free, but we may charge you for additional lists provided within that 12-month time period.
6. You have a right to receive a paper copy of this Notice of Privacy Practices at any time. To obtain a copy, please contact the Privacy Official, or see our web site as listed above.
If you would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, contact the MMGI-ETD Privacy Official at 1-800-727-6320 or 314-241-3464.
IV. Changes to this Notice of Privacy Practices
MMGI-ETD reserves the right to amend this Notice of Privacy Practices at any time in the future, and to make the new provisions effective for all information that it maintains, including information that was created or received prior to the date of such amendment. Until such amendment is made, MMGI-ETD is required by law to comply with this Notice. Revised notices will be available at the MMGI-ETD, and may be communicated via the MMGI-ETD web site, through local operations publications, meetings, or other approved distribution channels, from time to time.
If you believe that your rights have been violated regarding HIPAA, you may file a complaint with us. Complaints about this Notice of Privacy Practices or how MMGI-ETD handles your health information, must be in writing and directed to:
Attn: Privacy Official
1727 Locust St.
St. Louis, Missouri 63103
For further information about this process, call 1-800-727-6320 or 314-241-3464. This number is not to be used to register a complaint, as complaints must be submitted in writing as stated above.
If you are not satisfied with the manner in which this office handles a complaint, you may submit a formal complaint to:
Department of Health and Human Services Office of Civil Rights Hubert H. Humphrey Bldg.
200 Independence Avenue, S.W.
Room 509F HHH Building
Washington, DC 20201
You may also address your compliant to one of the regional Offices for Civil Rights. A list of these offices can be found online at http://www.hhs.gov/ocr/regmail.html. All complaints must be in writing, name the entity that is subject to the complaint, describe the act(s) or omission(s) being complained about; and be filed within 180 days of when the person filing the complaint knew or should have known that the act or omission occurred.
Effective as of April 14, 2003