Privacy Policy

PRIVACY NOTICE: THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THAT INFORMATION.

PLEASE REVIEW THIS NOTICE CAREFULLY.

This Notice describes how your protected health information (“PHI”) may be used and disclosed to third parties and your rights regarding your PHI. This Notice is in effect as of 08/01/2017 and applies to all protected health information contained in your health records maintained by our office. Our Practice:

a. is required by law to maintain the privacy of the protected health information in your records and to provide you with this Notice of our legal duties and privacy practices with respect to that information.

b. is required to abide by the terms of this Notice currently in effect.

c. reserves the right to change the terms of this Notice at any time, making the new provisions effective for all health information and records that we have and continue to maintain. All changes in this Notice will be prominently displayed and available to our office.

CONSENT

Our Practice may use and/or disclose your PHI if it first obtains a valid Consent signed by you. The

Consent will allow the Practice to use and/or disclose your PHI for the purposes of:

a. Treatment – We will use your health information to make decisions about the provision, coordination or management of your health care, including analyzing or diagnosing your condition and determining the appropriate treatment for that condition. It may be necessary to share your health information with another health care provider whom we need to consult with in respect to your care. These are only examples of uses and disclosures of medical information for treatment purposes that may or may not be necessary in your case.

b. Open Adjusting Rooms – We may choose to keep an open environment in the office to create a sense of warmth, family, healing and education. You may be in an open area where others may see you and/or overhear conversation; however, during adjustments, we do not go over private information. If there is a need to discuss something of a personal nature, you should request an appointment in one of our closed, private exam rooms where a doctor or trained staff member will speak to you about your condition or other matters.

c. Payment – We may need to use or disclose information in your health record to obtain reimbursement from you, from your health-insurance carrier, from another insurer, or from a third-party billing company for our services rendered to you. This may include determinations of eligibility or coverage under the appropriate health care plan, pre-certification and pre-authorization of services or review of services for the purpose of reimbursement. This information may be also used for billing, claims management and collection purposes, and related healthcare data processing through our system.

d. Health Care Operations – Your health records may be used in our business planning and development operations, including improvements in our methods of operation, and general administrative functions. We may also use the information in our overall compliance planning, healthcare review activities, and arranging for legal and auditing functions.

e. Appointment Reminders – The practice may, from time to time, contact you to provide appointment reminders of information about treatment alternatives or other health-related benefits and services that may be of interest to you. The following appointment reminders are used by the Practice: a) a postcard mailed to you at the address provided by you, b) telephoning your home and leaving a message on your answering machine or with the individual answering the phone, c) emails sent to the email provided; and d) texting the cell phone number provided to indicate you have an upcoming appointment or missed an appointment.

NO CONSENT REQUIRED

There are certain circumstances under which we may use or disclose your health information without first obtaining your Acknowledgment or Authorization.

a. De-identified Information – Information that does not identify you and, even without your name, cannot be used to identify you.

b. Business Associate – To a business associate if the Practice obtains satisfactory written assurance, in accordance with applicable law, that the business associate will appropriately safeguard your PHI. A business associate is an entity that assists the Practice in undertaking some essential function, such as a billing company that assists the office in submitting claims for payment to insurance companies or other payers.

c. Personal Representative – To a person who, under applicable law, has the authority to represent you in making decisions related to your health care.

d. Emergency Situations – for the purpose of obtaining or rendering emergency treatment to you provided that the Practice attempts to obtain your Consent as soon as possible; or To a public or private entity authorized by law or by its charter to assist in disaster relief efforts, for the purpose of coordinating your care with such entities in an emergency.

e. Communication Barriers – If, due to substantial communication barriers or inability to communicate, the Practice has been unable to obtain your Consent and the Practice determines, in the exercise of its professional judgment, that your Consent to receive treatment is clearly inferred from the circumstances.

f. Public Health Activities – Such activities include, for example, information collected by a public health authority, as authorized by law, to prevent or control disease.

g. Abuse, Neglect or Domestic Violence – To a government authority if the Practice is required by law to make such disclosure. If the Practice is authorized by law to make such a disclosure, it will do so if it believes that this disclosure is necessary to prevent serious harm.

h. Health Oversight Activities – Such activities, which must be required by law, involve government agencies and may include, for example, criminal investigations, disciplinary actions, or general oversight activities relating to the community’s health care system.

i. Judicial and Administrative Proceeding – For example, the Practice may be required to disclose your PHI in response to a court order or a lawfully issued subpoena.

j. Law Enforcement Purposes – In certain instances, your PHI may have to be disclosed to a law enforcement official. For example, your PHI may be the subject of a grand jury subpoena. Or, the Practice may disclose your PHI if the Practice believes that your death was the result of criminal conduct.

k. Coroner or Medical Examiner – The Practice may disclose your PHI to a coroner of medical examiner

for the purpose of identifying you or determining your cause of death.

l. Organ, Eye or Tissue Donation – If you are an organ donor, the Practice may disclose your PHI to the

entity to whom you have agreed to donate your organs.

m. Research – If the Practice is involved in research activities, your PHI may be used, but such use is subject to numerous governmental requirements intended to protect the privacy of your PHI.

n. Avert a Threat to Health or Safety – The Practice may disclose your PHI if it believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public and the disclosure is to an individual who is reasonably able to prevent or lessen the threat.

o. Specialized Government Functions – This refers to disclosures of PHI that relate primarily to military and veteran activity.

p. Workers’ Compensation – If you are involved in a Workers’ Compensation claim, the Practice may be required to disclose your PHI to an individual or entity that is part of the Workers’ Compensation system.

q. National Security and Intelligence Activities – The Practice may disclose your PHI to provide authorized governmental officials with necessary intelligence information for national security activities and purposes authorized by law.

r. Military and Veterans – If you are a member of the armed forces, the Practice may disclose your PHI as required by the military command authorities.

FAMILY/FRIENDS

The Practice may disclose to your family member, other relative, a close personal friend, or any other person identified by you, your PHI directly relevant to such person’s involvement with your care or the payment for your care. The Practice may also use or disclose your PHI to notify or assist in the notification (including identifying or locating) a family member, a personal representative, or another person responsible for your care, of your location, general condition or death. However, in both cases, the following conditions apply:

a. If you are present at or prior to the use or disclosure of your PHI, the Practice may use or disclose your PHI if you agree, or if the Practice can reasonably infer from the circumstances, based on the exercise of its professional judgment, that you do not object to the use or disclosure.

b. If you are not present, the Practice will, in the exercise of professional judgment, determine whether the use or disclosure is in your best interests and, if so, disclose only the PHI that is directly relevant to the person’s involvement with your care.

YOUR RIGHTS

You have certain rights regarding your health record information, as follows:

a. You may request that we restrict the uses and disclosures of your health record information for treatment, payment and operations, or restrictions involving your care or payment related to that care. We are not required to agree to the restriction; however, if we agree, we will comply with it, except regarding emergencies, disclosure of the information to you, or if we are otherwise required by law to make a full disclosure without restriction.

b. You have a right to request receipt of confidential communications of your medical information by an alternative means or at an alternative location. If you require such accommodation, you may be charged a fee for the accommodation and will be required to specify the alternative address or method of contact and how payment will be handled.

c. You have a right to inspect, copy and request amendments to your health records. Access to your health records will not include psychotherapy notes contained in them, or information compiled in anticipation of or for use in a civil, criminal or administrative action or proceeding to which your access is restricted by law. We will charge a reasonable fee for providing a copy of your health records, or a summary of those records, at your request, which includes the cost of copying, postage, and preparation or an explanation or summary of the information.

d. All requests for inspection, copying and/or amending information in your health records, and all requests related to your rights under this Notice, must be made in writing and addressed to the Privacy Office at our address. We will respond to your request in a timely fashion.

e. You have a limited right to receive an accounting of all disclosures required for treatment, payment and healthcare operations, disclosures that require an Authorization, disclosure incidental to another permissible use or disclosure, and otherwise as allowed by law. We will not charge you for the first accounting in any twelve-month period; however, we will charge you a reasonable fee for each subsequent request for an accounting within the same twelve-month period.

f. If this notice was initially provided to you electronically, you have the right to obtain a copy of this notice and to take it home with you if you wish. You may file a written complaint to us or to the Secretary of Health and Human Services if you believe that your privacy rights with respect to confidential information in your health records have been violated. All complaints must be in writing and must be addressed to the Privacy Officer (in case of complaints to us) or to the person designated by the U.S. Department of Health and Human Services if we cannot resolve your concerns. You will not be retaliated against for filing such a complaint. More information is available about complaints at the government’s web site, http://www.hhs.gov/ocr/hipaa. All questions concerning this Notice or requests made pursuant to it should be addressed to: PRIVACY OFFICER, at this clinic’s address.