Communication Connection Speech Services – HIPAA Joint Privacy Notice describes how medical information about you may be used and disclosed and how you can obtain access to this information. Please review it carefully.
This Joint Notice is being provided to you on behalf of Communication Connection Speech Services (CCSS) and the practitioners with clinical privileges that work with CCSS with respect to services provided by CCSS (collectively referred to herein as “We” or “Our”). We understand that your medical information is private and confidential. Further, we are required by law to maintain the privacy of “protected health information.” “Protected health information” or “PHI” includes any individually identifiable information that we obtain from you or others that relates to your past, present or future physical or mental health, the health care you have received, or payment for your health care. We will share protected health information with one another, as necessary, to carry out treatment, payment or health care operations relating to the services to be rendered with CCSS.
As required by law, this notice provides you with information about your rights and our legal duties and privacy practices with respect to the privacy of PHI. This notice also discusses the uses and disclosures we will make of your PHI. We must comply with the provisions of this notice as currently in effect, although we reserve the right to change the terms of this notice from time to time and to make the revised notice effective for all PHI we maintain. You can always request a written copy of our most current privacy notice by emailing us or downloading a copy under section Forms at www.CommunicationConnection.com.
Permitted Uses and Disclosures We can use or disclose your PHI for purposes of treatment, payment and health care operations. For each of these categories of uses and disclosures, we have provided a description and an example below. However, not every particular use or disclosure in every category will be listed.
• Treatment means the provision, coordination or management of your health care, including consultations between health care providers relating to your care and referrals for health care from one health care provider to another. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to contact a physical therapist to create the exercise regimen appropriate for your treatment.
• Payment means the activities we undertake to obtain reimbursement for the health care provided to you, including billing, collections, claims management, determinations of eligibility and coverage and other utilization review activities. For example, we may need to provide PHI to your Third Party Payor to determine whether the proposed course of treatment will be covered or if necessary to obtain payment. Federal or state law may require us to obtain a written release from you prior to disclosing certain specially protected PHI for payment purposes, and we will ask you to sign a release when necessary under applicable law.
• Health care operations means the support functions of CCSS, related to treatment and payment, such as quality assurance activities, case management, receiving and responding to patient comments and complaints, therapist reviews, compliance programs, audits, business planning, development, management and administrative activities. For example, we may use your PHI to evaluate the performance of our staff when caring for you. We may also combine PHI about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose PHI for review and learning purposes. In addition, we may remove information that identifies you so that others can use the de-identified information to study health care and health care delivery without learning who you are.
Other Uses and Disclosures of Protected Health Information
• We may contact you to provide appointment reminders for treatment or medical care.
• We may contact you to tell you about or recommend possible treatment alternatives or other health-related benefits and services that may be of interest to you.
• We may disclose to your family or friends or any other individual identified by you to the extent directly related to such person’s involvement in your care or the payment for your care. We may use or disclose your PHI to notify, or assist in the notification of, a family member, a personal representative, or another person responsible for your care, of your location, general condition or death. If you are able, we will give you an opportunity to object to these disclosures, and we will not make these disclosures if you object. If you are not able, we will determine whether a disclosure to your family or friends is in your best interest, taking into account the circumstances and based upon our professional judgment.
• We will allow your family and friends to act on your behalf to pick up medical supplies and similar forms of PHI, when we determine, in our professional judgment, that it is in your best interest to make such disclosures.
• We will use or disclose PHI about you when required to do so by applicable law.
Special Situations Subject to the requirements of applicable law, we will make the following uses and disclosures of your PHI:
• Public Health Activities . We may disclose health information about you for public health activities, including disclosures:
o to prevent or control disease, injury or disability; o to report births and deaths; o to report child abuse or neglect; o 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; o to notify the appropriate government authority if we believe that an adult patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if the patient agrees or when required or authorized by law.
• Health Oversight Activities . We may disclose PHI to federal or state agencies that oversee our activities (e.g., providing health care, seeking payment, and civil rights).
• Lawsuits and Disputes . If you are involved in a lawsuit or a dispute, we may disclose PHI subject to certain limitations.
• Law Enforcement . We may release health information if asked to do so by a law enforcement official.
o In response to a court order, subpoena, warrant, summons or similar process; o To identify or locate a suspect, fugitive, material witness, or missing person; o About the victim of a crime under certain limited circumstances; o About a death we believe may be the result of criminal conduct; o About criminal conduct on our premises; or o In emergency circumstances, to report a crime, the location of the crime or the victims, or the identity, description or location of the person who committed the crime.
• National Security and Intelligence Activities . We may release PHI about you to authorized federal officials for intelligence, counter-intelligence, other national security activities authorized by law or to authorized federal officials so they may provide protection to the President or foreign heads of state.
• Serious Threats . As permitted by applicable law and standards of ethical conduct, we may use and disclose PHI if we, in good faith, believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public or is necessary for law enforcement authorities to identify or apprehend an individual.
Other Uses of your Health Information Certain uses and disclosures of PHI will be made only with your written authorization , including uses and/or disclosures: (a) for marketing purposes; and (b) that constitute a sale of PHI under the Privacy Rule. Other uses and disclosures of PHI not covered by this notice or the laws that apply to us will be made only with your written authorization. You have the right to revoke that authorization at any time, provided that the revocation is in writing, except to the extent that we already have taken action in reliance on your authorization.
Note Genetic information and certain special conditions related to minors may enjoy certain special confidentiality protections under applicable State and Federal law. Any disclosures of these types of records will be subject to these special protections . Your Rights
1. You have the right to request restrictions on our uses and disclosures of PHI for treatment, payment and health care operations. However, we are not required to agree to your request. We are, however, required to comply with your request if it relates to a disclosure to your health plan regarding health care items or services for which you have paid the bill in full. To request a restriction, you may make your request in writing and send it to: Communication Connection Speech Services, P.O. Box 1510, Sequim, WA 98382.
2. You have the right to reasonably request to receive confidential communications of your PHI by alternative means or at alternative locations. To make such a request, you may submit your request in writing us at the address above.
3. You have the right to inspect or obtain a copy of the PHI contained in our records, except:
(i) for information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding;
(ii) for PHI obtained from someone other than us under a promise of confidentiality when the access requested would be reasonably likely to reveal the source of the information.
In order to inspect or obtain a copy your PHI, you may submit your request in writing to the address above. If you request a copy, we may charge you a fee for the costs of copying and mailing your records, as well as other costs associated with your request.
We may also deny a request for access to PHI under certain circumstances if there is a potential for harm to yourself or others. If we deny a request for access for this purpose, you have the right to have our denial reviewed in accordance with the requirements of applicable law.
4. You have the right to request an amendment to your PHI but we may deny your request for amendment if we determine that the PHI or record that is the subject of the request:
(i) was not created by us, unless you provide a reasonable basis to believe that the originator of PHI is no longer available to act on the requested amendment;
(ii) is not part of your medical or billing records or other records used to make decisions about you;
(iii) is not available for inspection as set forth above; or
(iv) is accurate and complete.
In any event, any agreed upon amendment will be included as an addition to, and not a replacement of, already existing records. In order to request an amendment to your health information, you must submit your request in writing to the address above, along with a description of the reason for your request.
5. You have the right to receive an accounting of disclosures of PHI made by us to individuals or entities other than to you for the six years prior to your request, except for disclosures :
(i) to carry out treatment, payment and health care operations as provided above;
(ii) incidental to a use or disclosure otherwise permitted or required by applicable law;
(iii) pursuant to your written authorization;
(iv) to persons involved in your care or for other notification purposes as provided by law;
(v) for national security or intelligence purposes as provided by law;
(vi) to correctional institutions or law enforcement officials as provided by law; (vii) as part of a limited data set as provided by law
To request an accounting of disclosures of your PHI, you must submit your request in writing to the address above. Your request must state a specific time period for the accounting (e.g., the past three months). The first accounting you request within a twelve (12)-month period will be free. For additional accountings, we may charge you for the costs of providing the list. We will notify you of the costs involved, and you may choose to withdraw or modify your request at that time before any costs are incurred.
6. You have the right to receive a notification, in the event that there is a breach of your unsecured PHI, which requires notification under the Privacy Rule.
If you believe that your privacy rights have been violated, you should immediately contact us. We will not take action against you for filing a complaint. You also may file a complaint with the Secretary of the U. S. Department of Health and Human Services.
If you have any questions or would like further information about this notice, please contact us.
This notice is effective as of January 1, 2017.