Effective Date: April 14, 2003 |
Notice of Privacy Practices
OUR RESPONSIBILITIES
Commonwealth Orthopaedic Centers, P.S.C. takes the privacy of your health information seriously. we are required by law to maintain that privacy and to provide you with this Notice of Privacy Practices. This Notice is provided to tell you about our duties and practices with respect to your information. We are required to abide by the terms of this Notice that is currently in effect.
HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION
The following categories describe different ways that we use and disclose your health information. For each category we explain what we mean and give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories. |
- For Treatment We may use health
information about you to provide you with treatment, health care or other related
services. We may disclose your health information to doctors, nurses, aids, technicians
or other employees who are involved in taking care of you. Additionally, we may use or
disclose your health information to manage or coordinate your treatment, health care or
other related services. We may also disclose your medical information to other health
care providers who are providing treatment to you, whether or not we are involved with
your treatment at that time. We will send information to other medical providers in
the event we transfer care to another provider.
|
- For Payment We may use and
disclose your health information to bill and collect for the treatment and services we
provide you. We may send your health information to an insurance company or other third
party for the payment purposes including to a collection service. We may also disclose
your medical information to another health care provider or payor of health care for the
payment activities of that entity.We may send or give information to your employer
in the case of the Worker's Compensation claim.
|
- For Health Care Operations We may
use and disclose your health information for health care operations. These uses and
disclosures are necessary to run Commonwealth Orthopaedic Centers, P.S.C., to make sure
you receive competent, quality health care, and to maintain and improve the quality of
health care we provide. We may also provide your health information to various
governmental or accreditation entities to maintain our license and accreditation. We
may also disclose your medical information to another health care provider or payor for
certain health care operations activities of that entity also has a relationship with
you. In addition, we may disclose your medical information to any of the entities
included in Commonwealth Orthopaedic Centers P.S.C.'s organized health care arrangement
for purposes of health care operations of the organized health care arrangement. We
will receive information from health care providers such as Operative Notes, test
results, and progress notes. We will send progress notes and office notes to health
care providers and we will send your medical records for storage for purging purposes.
|
- Incidental Uses and Disclosures
We may occasionally inadvertently use or disclose your medical information when such
use or disclosure is incident to another use or disclosure that is permitted or
required by law. For example, while we have safeguards in place to protect against
others overhearing our conversations that take place between doctors, nurses or
other Commonwealth Orthopaedic Centers, P.S.C., personnel, there may be times that
such conversations are in fact overheard. Please be assured, however, that we have
appropriate safeguards in place to avoid such situations, and others, as much as
possible.
|
- Disclosures to You
Upon a request by you, we may use or disclose your medical
information in accordance with your request.
|
- Limited Data Sets
We may use or disclose certain parts of your medical
information, call a "limited data set," for purposes of research, public health
reasons or for our health care operations. We would disclose a limited data set
only to third parties that have provided us with satisfactory assurances that they
will use or disclose your medical information only for limited purposes.
|
- Disclosures to the Secretary of
Health and Human Services We might be required by
law to disclose your medical information to the Secretary of the Department of
Health and Human Services, or his/her designee, in the case of a compliance review
to determine whether we are complying with privacy laws.
|
- De-Identified Information
We may use your medical information, or disclose it to a third
party whom we have hired, to create information that does not identify you in any
way. Once we had de-identified your information, it can be used or disclosed in
anyway according to law.
|
- Disclosures by Members of Our Workforce
Members of our workforce, including employees,
volunteers, trainees or independent contractors, may disclose your medical information
to a health oversight agency, public health authority, health care accreditation
organization or attorney hired by the workforce member, to report the workforce member's
belief that we have engaged in unlawful conduct or that our care or services could
endanger a patient, workers or the public. In addition, if a workforce member is a
crime victim, the member may disclose your medical information to a law enforcement
official.
|
|
- As Required By Law
We may disclose your health information when required to do so by federal, state or local
law.
|
- For Public Health Purposes
We may disclose your health information for public health activities.
While there may be others, public health activities generally include the following:
|
- Preventing or controlling disease, injury or disability;
|
- Reporting births and deaths;
|
- Reporting defective medical devices or problems with medications;
|
- Notifying people of recalls of products they may be using; and
|
- Notifying a person who may have been exposed to a disease or may
be at risk for contracting or spreading a disease or condition.
|
|
- About Victims of Abuse We may
disclose your health information to notify the appropriate government authority if we
believe an individual has been the victim of abuse, neglect or domestic violence. We
will only make this disclosure if you agree or when 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 might include audits, investigations,
inspections, and licensure. These activities are necessary for the government to
monitor the health care system, government benefit programs, and compliance with civil
rights laws.
|
- Judicial Purposes We may disclose
your health information in response to a court or administrative order. We may also
disclose your health information in response to a subpoena, discovery request, or other
lawful process by someone else involved in a dispute, but only if efforts have been
made to tell you about the request, in which you were given an opportunity to object
to the request, or to obtain an order protecting the information requested.
|
- Law Enforcement We may release
health information if asked to do so by a law enforcement official, if such disclosure
is:
|
|
- In response to a court order, subpoena, warrant, summons or
similar process;
|
- To identify or locate a suspect, fugitive, material witness, or missing person;
|
- About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement;
|
- About a death we believe may be the result of criminal conduct;
|
- About criminal conduct at the Covered Entity; or
|
- In emergency circumstances to report a crime; the location of the
crime or victims; or the identity, description or location of the person who
committed the crime.
|
|
- Coroners, Medical Examiners and Funeral
Directors In certain circumstances, we may disclose health information to a
coroner or medical examiner. This may be necessary, for example, to identify a deceased
person or determine the cause of death. We may also release health information about
individuals to funeral directors as necessary to carry out their duties.
|
- Organ and Tissue Donation We may
disclose 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.
|
- Research Under certain
circumstances, we may use and disclose health information about you for research
purposes. For example, a research project may involve comparing the health and
recovery of all individuals who received one medication to those who received another.
All research projects, however, are subject to a special approval process. This process
includes evaluating a proposed research project and its use of health information,
trying to balance the research needs with your need for privacy of your health
information. Before we use or disclose health information for research, the project
will have been approved through this research approval process. Additionally, when it
is necessary for research purposes and so long as the health information does not leave
Commonwealth Orthopaedic Centers, P.S.C., we may disclose your health information to
researchers preparing to conduct a research project, for example, to help the
researchers look for individuals with specific health needs. Lastly, if certain
criteria are met, we may disclose your health information to researchers after your
death when it is necessary for research purposes.
|
- To Avert a Serious Threat to Health or
Safety We may use and disclose your health information when we believe it
is 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 or lessen the threat or to law enforcement authorities
in particular circumstances.
|
- Military and Veterans If you are
a member of the armed forces, we may release your health information as required by
military command authorities. We may also release health information about foreign
military personnel to the appropriate foreign military authority.
We may disclose to the Department of Veterans Affairs your health information
upon your separation or discharge from military services for the purpose of a
determination by the department of Veterans Affairs of your eligibility for or
entitlement to certain benefits.
We may use and disclose to components of the Department of Veterans Affairs
health information about you to determine whether you are eligible for certain
benefits.
|
- National Security and Intelligence
Activities We may release your health information to authorized federal
officials for lawful intelligence, counterintelligence, and other national security
activities authorized by law.
|
- Protective Services for the President and
Others We may disclose your health information to authorized federal
officials so they may provide protection to the President, other authorized persons or
foreign heads of state or for the conduct of special investigations.
|
- Custodial Situations If you are an
inmate in a correctional institution and if the correctional institution or law
enforcement authority makes certain representations to us, we may disclose your health
information to a correctional institution or law enforcement official.
|
- Medical Suitability Determinations
We may use your health information to make medical suitability determinations and we
may disclose whether you are determined to be medically suitable to the officials of
the Department of State who have a need to see such information for certain purposes.
|
- Workers' Compensation We may
disclose your health information as authorized by and to the extent necessary to
comply with workers' compensation laws or laws relating to similar programs.
|
- Suspected Abuse or Neglect If we
believe that a person is a victim of child or adult abuse or neglect, we are required
by law to report certain information to public authorities.
|
|
Communications Regarding Our Services
or Products We may use use and disclose your health information to make a
communication to you to describe a health-related product or service of -medical care. In
addition, we may use or disclose your health information to tell you about products or
services related to your treatment, case management or care coordination, or alternative
treatments, therapies, providers or settings of care for you. We may occasionally tell you
about another company's products or services, but will use or disclose your health
information for such communications only if they occur in person with you. We may also use
and disclose your health information to give you a promotional gift from us that is a minimal
value. |
- Treatment Alternatives, Appointment Reminders
and Health-Related Benefits We may use and disclose your health information to
tell you about or recommend possible treatment alternatives or health-related benefits or
services that may be of interest to you. Additionally, we may use and disclose your
health information to provide appointment reminders. If you do not wish us to contact
you about treatment alternative, health-related benefits or appointment reminders, you
must notify us in writing, and state which of those activities you wish to be excluded
from.
|
- Individuals Involved In Your Care or Payment
for Your Care We may release health information about you to a family member,
other relative, or any other person identified by you who is involved in your health care.
We may also give information to someone who is involved with or helps pay for your care.
We may also tell your family, friends, personal representative or other person responsible
for your health care your condition and that you are at the Hospital.
|
- Third Parties We may disclose your
health information to certain third parties with whom we contract to perform services on
our behalf. If we disclose your information to these entities, we will have an agreement
by them to safeguard your information.
|
- Communications Regarding Commonwealth
Orthopaedic Centers P.S.C.'s Programs or Products We may use and disclose
your health information to make a communication to you to describe a health-related
product or service of Commonwealth Orthopaedic Centers, P.S.C. In addition, we may use
or disclose your health information to tell you about products or services related to
your treatment, case management or care coordination, or alternative treatments,
therapies, providers or settings of care for you. We may occasionally tell you about
another company's products or services, but will use or disclose your health information
for such communications only if they occur in person with you. We may also use and
disclose your health information to give you a promotional gift from us that is a minimal
value.
|
- Disclosures of Records Containing Drug or
Alcohol Abuse Information Because of federal law, we will not release your
medical information if it contains information about drug or alcohol abuse without your
written permission except in very limited situations.
|
|
Other Uses of Health
Information Other uses and disclosures of health information not covered by this
Notice or the laws that apply to us will be made only with your written authorization. If you
provide us 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 health information about you for the reasons covered by your written
authorization. You understand that we are unable to take back any disclosures we have
already made under the authorization, and that we are required to retain our records of the
care that we provided to you. |
Your Rights Regarding
Your Health Information You have the following rights regarding health information
we maintain about you: |
- Right to Request Restrictions You
have the right to request a restriction or limitation on the health 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 health information we disclose about you to someone who
is involved in your care or the payment for your care.
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 Privacy Officer
at 560 South Loop Rd Edgewood, KY 41017. We will not ask you the
reason for your request. We will accommodate all reasonable request. Your request
must specify how or where you wish to be contacted.
|
- 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.
To inspect and copy health information that may be used to make decisions about you,
you can submit your request in writing to Privacy Officer at 859.301.2663 or 560 South Loop Rd Edgewood, KY 41017. 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.
|
- Right to Amend You have the right
to ask us to amend your health and /or billing information for as long as the
information is kept by us.
To request an amendment, your request must be made in writing and submitted to
Privacy Officer at 560 South Loop Rd Edgewood, KY 41017. 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 the person or entity that created
the information is no longer available to make the amendment;
|
- Is not part of the health information kept by us;
|
- 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 a list of certain disclosures that we have made of your
health information.
To request this list of disclosures, you must submit your request in writing to
Privacy Officer at 560 South Loop Rd Edgewood, KY 41017. Your request
must state a time period that 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
twelve-month period, 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 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 or print it from this web site. 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
Privacy Officer at 560 South Loop Rd Edgewood, KY 41017.
Who This Notice Applies To
This Notice describes Commonwealth Orthopaedic Centers, P.S.C. practices and those of: |
- Any health care professional authorized to enter information into or consult your medical record.
|
- All departments and units of Commonwealth Orthopaedic Centers, P.S.C.
|
- Any member of a volunteer group we allow to help you.
|
- All employees, staff and other Commonwealth Orthopaedic Centers, P.S.C. personnel.
|
- All the following entities, sites and locations follow the terms of this Notice. In addition, these entities, sites and locations may share health information with each other for treatment, payment or operations purposes described in this Notice:
|
Commonwealth Orthopaedic Centers, P.S.C. 560 South Loop Rd Edgewood, KY 41017
Commonwealth Orthopaedic Centers, P.S.C. 2845 Chancellor Drive Crestview Hills, KY 41017
Commonwealth Orthopaedic Centers, P.S.C. 525 Alexandria Pike, Southgatge, KY 41017
Commonwealth Orthopaedic Centers, P.S.C. 211 W. Shelby Avenue, Falmouth, KY 41040 |
|
Changes To This Notice
We reserve the right to change this Notice. We reserve the right to make the
revised Notice effective for health information we already have about you as well as any
information we receive in the future. We will post a copy of the current Notice in a clear
and prominent location to which you have access. The Notice is also available to you upon
request. The Notice will contain on the first page, in the top right-hand corner, the
effective date. In addition, if we revise the Notice, you may request a copy of the current
Notice in effect.
You will not be penalized for filing a complaint.
If you have any questions about this Notice, please contact:
Privacy Officer
Commonwealth Orthopaedic Centers, P.S.C.
560 South Loop Road
Edgewood, KY 41017 |
If you believe your privacy rights have been violated, you may file a complaint with
Commonwealth Orthopaedic Centers, P.S.C. or with the Secretary of the Department of Health
and Human Services. To file a complaint with us, contact Privacy Officer, 859.301.2663.
All complaints must be submitted in writing.
|
|
