Joint 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.
If you have any questions about this Notice, please contact us at 1-844-763-8442 (1-844-PMETHIC)
WHO FOLLOWS THIS NOTICE
The terms of this Joint Notice of Privacy Practices apply to Prospect Crozer, LLC, doing business as Crozer Keystone, which we will call the Health System, and the Health System's owned and operated affiliated covered entities and other participants in the organized health care arrangement:
- All departments and units of our Health System’s hospitals: Crozer-Chester Medical Center, Delaware County Memorial Hospital, Springfield Hospital and Taylor Hospital.
- Our network of physician practices, which we call the Prospect Health Access Network, the physicians and other personnel employed by Health Access Network.
- Our urgent care centers, including: Pioneer Urgent Care and Crozer Keystone UrgentCare at Broomall.
- Our hospital-based physicians, with whom we contract to do most or all of their work at our hospitals, including our anesthesiologists, radiologists and pathologists.
- All of our Health System's outpatient facilities, including but not limited to Crozer-Keystone Surgery Center at Haverford, DCMH outpatient departments at Haverford, Crozer-Keystone Surgery and Endoscopy Centers at Brinton Lake, Crozer outpatient departments at Brinton Lake, Rejuvenations at Fair Acres and the Media Medical Imaging Center.
- Any health care professional authorized to enter information into your medical record.
- All employees, staff and other Health System personnel.
- Any member of a volunteer group we allow to help you while you are in one of our hospitals, physician offices or outpatient facilities.
- Students and trainees who participate in training and education at any of the facilities listed above.
These separate legal entities may share protected health information with each other as necessary to carry out treatment, payment or healthcare operations relating to the Health System's organized healthcare arrangement unless otherwise limited by law, rule or regulation, as described in this Notice.
This Joint Notice of Privacy Practices does not apply when you are visiting a non-Health System office practice or a non-Health System physician in their private medical offices.
OUR PLEDGE REGARDING HEALTH INFORMATION.
We understand that information about you and your health is personal. We are committed to protecting the privacy of your health information. We create a record of the care and services you receive at the Health System and in our affiliated hospitals, outpatient facilities or in our Health Access Network physicians' offices. We need this record to provide you with quality care and to comply with certain legal requirements. This Notice applies to all of the records of your care generated by the hospitals, outpatient facilities and our physicians' offices in the Health System. Your personal doctor, if he/she is not an employee of our Prospect Health Access Network, may have different policies or notices regarding the use and disclosure of your health information created in his/her office or clinic.
This Notice will tell you about the ways in which we may use and disclose health information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of your health information.
We are required by federal and state laws to:
- Make sure that health information that identifies you is kept private;
- Give you this Notice of our legal duties and privacy practices with respect to health
information about you; and
- Follow the terms of this Notice that is currently in effect.
HOW THE HEALTH SYSTEM MAY USE AND DISCLOSE YOUR HEALTH INFORMATION.
The following categories describe different ways that we use and disclose health information. Also, in some cases, state laws are stricter than the federal privacy standards and generally require that hospitals and health care professionals, like physicians, allow only authorized persons to see records and obtain the written authorization of the patient before releasing medical information outside of the hospital or the physician's office.
For each category of uses or disclosures described below, we will give examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose your health information, without a detailed written authorization that complies with the federal privacy standards, will fall within one of the following categories:
For Treatment. We may use health information about you to provide you with health care. We may disclose health information about you to doctors, nurses, technicians, health students, or other Health System personnel who are involved in taking care of you. Some examples are:
▪ A doctor treating you for a broken leg in one of our hospitals may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals. Different departments of the hospital also may share health information about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays.
▪ We also may disclose health information about you to people outside the Health System who may be involved in your medical care after you leave a Health System hospital, an outpatient facility or one of our physicians' offices, such as family members, clergy, or others we use to provide services that are part of your care.
For Payment. We may use and disclose health information about you so that the services you receive at the Health System may be billed to and payment may be collected from you, an insurance company or a third party. Some examples are:
▪ We may need to give your insurance company information about surgery you received at one of our hospitals so your health insurance company will pay us for the surgery.
▪ We may tell your health plan about a treatment/service you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment/ service.
For Health Care Operations. We may use and disclose health information about you for healthcare operations. These uses and disclosures are necessary to run the Health System and make sure that all of our patients receive quality care. Some examples are:
▪ We may use health information to review and improve the quality of our treatment and services and to evaluate the performance of our staff in caring for you.
▪ We may also combine health information about many Health System patients to decide what additional services the hospitals, outpatient facilities and our physicians should offer, what services are not needed, and whether certain new treatments are effective.
▪ We may also disclose information to doctors, nurses, technicians, medical students, and other Health System personnel for review and learning purposes.
Appointment Reminders. We may use and disclose your health information to contact you as a reminder that you have an appointment for treatment or medical care at one of our hospitals, outpatient facilities or physicians' offices.
Treatment Alternatives. We may use and disclose your health information to send you information or tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefits and Services. We may use and disclose your health information to tell you about or send you newsletters and other information about health topics and health-related benefits or services that may be of interest to you.
For Health Information Exchange. We may participate in one or more health information exchanges (HIEs) and may electronically share your health information for treatment, payment and healthcare operations purposes with other participants in the HIEs. HIEs allow your health care providers to efficiently access and use your pertinent medical information necessary for treatment and other lawful purposes.
If you do not opt-out of this exchange of information, we may provide your health information to the HIEs in which we participate in accordance with applicable law.
Hospital Directories. Unless you object, we may include certain limited information about you in one of our Health System hospital's directories while you are a patient at any of the hospitals. This directory information is so that family, friends, and clergy can visit you in the hospital and generally know how you are doing.
▪ This information may include your name, location in the hospital, and your general condition (e.g., fair, stable, etc.). Your religious affiliation will be included if you agree to have it included and it will only be released to members of the clergy.
▪ The directory information, except for your religious affiliation, will be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they don't ask for you by name.
▪ You can tell us if you do not want to be included in our hospital directories and we will not include this limited information.
Individuals Involved in Your Care or Payment for Your Care.
▪ We may release health information about you to a friend or family member who is involved in your health care.
▪ We may also give information to someone who pays or helps to pay for your care or whose insurance or health plan pays for your care.
▪ We may tell your family or friends your condition and that you are in one of our Health System hospitals.
▪ We may disclose health information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.
Research. The Health System is involved in research with human beings as participants. All such research is reviewed by an Institutional Review Board (IRB), which is a committee that reviews research to protect the health, welfare and privacy of the research participants. Under certain circumstances, we may use and disclose your health information for research purposes. We will almost always ask for your specific authorization if the researchers will have access to your name, address or other information that identifies you, or who will be involved in your care at the Health System. The Health System is permitted to use and disclose your health information for research in certain situations, including:
▪ We may use and disclose health information about you without authorization when the IRB determines that there is a small risk of harm, the research could not reasonably be carried out if specific written consent and authorization were required, and the information is needed for the research.
▪ We may use and disclose health information about you to people preparing to conduct a research project (for example, to help look for patients with specific medical needs or types of illnesses) so long as the health information identifying you does not leave the Health System.
▪ We may use and disclose private health information needed for research involving deceased individuals.
▪ We may use and disclose health information about you from which many, but not all, identifiers have been removed where there is an agreement with the person receiving the information to protect the privacy of the information.
As Required by Law. We will disclose your health information when required to do so by federal, state or local law.
To Avert a Serious Threat to Health or Safety. We may use and disclose your 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. Any disclosure, however, would only be to someone able to help prevent the threat.
- Organ and Tissue Donation. If you are an organ donor, we may release your health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.
- Workers' Compensation. We may release your health information for workers' compensation or similar programs that provide benefits for work-related injuries or illness.
Public Health Risks. We may disclose your health information for public health activities. These activities generally include the following:
▪ to prevent or control disease, injury or disability;
▪ to report births and deaths;
▪ to report child abuse or neglect;
▪ to report reactions to medications or problems with products;
▪ to notify people of recalls of products they may be using;
▪ 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;
▪ to notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when we are required or authorized by law.
Health Oversight Activities. We may disclose your health information to a health oversight agency for activities authorized by law. These oversight activities include: 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 your health information in response to a court or administrative order, but only the health information requested in the order. We may also disclose your health information in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute if efforts have been made to tell you about the request prior to release of the information or to obtain an order protecting the information requested.
Law Enforcement. We may release health information for certain law enforcement purposes including:
▪ To comply with a court order or a court-order, subpoena, warrant, summons or similar process.
▪ To comply with a legal requirement, for example, mandatory reporting of gunshot wounds.
▪ To respond to a request for information for identification or location purposes.
▪ To respond to a request for information about a crime victim if, under certain limited circumstances, we are unable to obtain the crime victim's agreement to the disclosure.
▪ To report a death we believe may be the result of criminal conduct.
▪ To provide information about criminal conduct that occurs on Health System property
▪ In emergency circumstances to report a crime, the location or victims of the crime, or the identity, description, or location of the person who committed the crime.
Coroners, Medical Examiners and Funeral Directors. We may release health information to a coroner or medical examiner as necessary to identify a deceased person or determine the cause of death, or to funeral directors as necessary to carry out their duties.
Special Government Functions. We may release your health information for purposes involving specialized government functions including:
▪ Military and veterans' activities, if you are a member of the armed forces and as required by military command authorities.
▪ National security and intelligence activities: to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
▪ Protective services for the President and others: to authorized federal officials so they may provide protection of the President, other authorized persons, or foreign heads of state, or in order to conduct special investigations.
▪ Medical suitability determinations for the Department of State.
▪ For inmates of correctional institutions and under the custody of a law enforcement official: to correctional institutions or law enforcement officials as necessary for the institution to provide healthcare and to protect your health and safety or the health and safety of others.
YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU.
You have the following rights regarding health information we maintain about you:
Right to Inspect and Copy. You have the right to inspect and copy health information that may be used to make decisions about your care. This usually includes medical and billing records, but does not include psychotherapy notes. To inspect and copy your medical and/or billing records, send a request in writing to the Privacy
Officer at the address listed at the end of this Notice:
▪ If you request a copy of the record, 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 your medical and/or billing records in certain very limited circumstances. If you are denied access to health information, you may request that the denial be reviewed. Another licensed healthcare professional chosen by the Health System will review your request and the denial. The person conducting the review will not be the same person who denied your request. We will comply with the outcome of the review.
▪ If your health information is maintained in an electronic format (known as an electronic medical record or an electronic health record), you have the right to request that an electronic copy of your record be given to you or transmitted to another individual or entity. We will make every effort to provide access to your health information in the form or format you request, if it is readily producible in such form or format. If the health information is not readily producible in the form or format you request your record will be provided in either our standard electronic format or if you do not want this form or format, a readable hard copy form. We may charge you a reasonable, cost-based fee for the labor associated with transmitting the electronic medical record.
Right to Request Amendment. If you feel that health 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 the Health System. This right is subject to limitations. To request an amendment, you must submit your request in writing to the Privacy Officer at the address listed at the end of this Notice. In addition, you must provide a reason that supports your request.
▪ We have the right to 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 the person or entity that created the information is no longer available to make the amendment;
▪ is not part of the medical information kept by or for the Health System;
▪ 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 health information that were not covered by your written authorization or consent and were not made for the purposes of treatment, payment, or health care operations, or certain other limited purposes for which accountings are not required.
▪ To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer at the address listed at the end of this Notice.
▪ Your request must state a time period, which can be no longer than six years prior to the date of your request. Your request should indicate in what form you want the list, that is, in paper form or electronic copy.
▪ We will not charge a fee for the first list you request within a 12-month period.
▪ For additional accountings, 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 your health information we may use or disclose for treatment, payment or health care operations.
You have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for your care, or for notification purposes, such as a family member or friend. For example, you could request that we not use or disclose information about a surgery that you had.
▪ We are not required to agree to your request except if the disclosure is related to services for which you paid out of pocket in full, as described below. If we do agree, we will comply with your request for a restriction, unless the information is needed to provide you with emergency treatment.
▪ To request restrictions you must make your request in writing to the Privacy Officer at the address listed at the end of this Notice.
▪ 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 Restrictions for Out-of-Pocket Payments. If you paid out-of- pocket (that is, you asked us not to bill your health plan) in full for a specific item or service, you have the right to ask that your health information related to that item or service not be disclosed to a health plan for purposes of payment or healthcare operations. We will honor that request unless required by law not to do so request
Right to Request Confidential Communications. You have the right to request that our hospitals, outpatient facilities and physicians communicate with you about health matters in a certain way or at a certain location. For example, you may ask that we contact you only at work or only by mail, or not by email. To request confidential communications, you must make your request in writing by contacting the Privacy Officer at the address listed at the end of this Notice. We will accommodate all reasonable requests but are not required to agree to requests for confidential communications that we decide are unreasonable.
▪ We will not ask you the reason for your request. Your request must specify how or where you wish to be contacted. In addition, if another individual or entity is responsible for payment for your health care, then your request must explain how payment will be handled.
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.
▪ To obtain a paper copy of this Notice, contact the Health System Privacy Officer at 1-844-763-8442
Right to Breach Notification. You have the right to be notified in writing in the event of the occurrence of a reportable breach, as defined in HIPAA laws and rules, involving your protected health information.
CHANGES TO THIS NOTICE.
We reserve the right to change this Notice. We reserve the right to make the revised or changed Notice effective for health information we already have about you, as well as any information we receive in the future. We will make a copy of the current Notice easily available by posting at all of our hospitals, outpatient facilities and network physicians' offices. On the first page, in the top right-hand corner, the Notice will contain the effective date. In addition, each time you register for treatment at or are admitted to any of the Health System's hospitals, outpatient facilities or physician practices, we will make a copy of the current Notice available to you upon your request.
If you believe your privacy rights have been violated, you may file a complaint with the Health System or with the Secretary of the Department of Health and Human Services. To file a complaint with the Health System, contact the Health System Privacy Officer at 1-844-763-8442 or in writing at the address listed below. All complaints should be submitted within 180 days of when you knew or should have known of the suspected violation.
To file a complaint or with the federal Secretary of the Department of Health and Human Services, use the following address.
US Department of Health and Human Services
200 Independence Avenue, SW Washington, DC 20201
For additional information, you may call the Department at 202-619-0257 or toll free at 877-696-6775, or visit the Office for Civil Rights website at: http://www.hhs.gov/ocr/hipaa.
The Health System, its hospitals, its outpatient facilities and its Health Access Network of physicians will not retaliate against you or penalize you in any way for filing a complaint
OTHER USES OF HEALTH INFORMATION.
Other uses and disclosures of your health information not covered in this Notice or the laws that apply to us will be made only with your written authorization. In the following circumstances, we will always require an authorization from you or your authorized representative.
▪ Highly confidential information. Federal and State laws require special privacy protections for certain highly confidential information about you. This includes health information that is: 1) maintained in psychotherapy notes; 2) documentation related to mental health or developmental disabilities services; 3) drug and alcohol abuse, prevention, treatment and referral information; 4) information related to HIV status, testing and treatment as well as any information related to the treatment or diagnosis of sexually transmitted diseases; and 5) health information related to genetic testing. Generally, we must obtain your authorization to release this type of health information. However, there are limited circumstances under the law when this type of health information may be released without your consent. For example, certain sexually transmitted diseases must be reported to the Department of Health.
▪ Marketing Purposes. Except as permitted under this Notice or as permitted by law, we will seek your written permission before using or sharing your health information for marketing purposes or selling your information.
▪ If you provide us with authorization to use or disclose your health information, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose your health information for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain a record of the care that we provided to you.
For requests involving your records, such as amendments, copies, access to records, accounting of disclosures, please contact:
Prospect Crozer, LLC
100 West Sproul Road, Pavilion II Springfield, PA 19064
To request confidential communications, copies of this Notice, or to file a complaint, contact:
Prospect Crozer, LLC
100 West Sproul Road, Pavilion II Springfield, PA 19064