NOTICE OF PRIVACY PRACTICES Effective 9/1/2005

This notice describes how personal health information (PHI) about you may be used and disclosed and how you can get access to this information. Please review it carefully. A Primary Care Clinic for Adults (APCCFA) respects your privacy and understands that your PHI is personal and sensitive. In 1996, the US Congress enacted a law titled the Health Insurance Portability and Accountability Act, aka HIPAA.  HIPAA, and similar state laws which apply to us, are designed to help protect the privacy of individuals health information that we have created or received regarding your healthcare or payment for your healthcare, which includes your medical records and personal information such as name, address, phone number etc. One of the requirements of the law is to provide you with this notice of our legal duties and privacy practices in order to better inform you about your rights and how your PHI may be used.  This notice describes the ways we may use and disclosed medical and other personal information about you and our obligations if we do so. It also describes your rights and obligations regarding the use and disclosure of your PHI. We are required to make sure that medical information that identifies you is kept private, and to follow the terms of the Privacy Notice that is currently in effect. All staff are required to abide by this act.

USE AND DISCLOSURE OF MEDICAL INFORMATION

APCCFA is allowed to use and disclose your PHI in a number of ways pertaining to your treatment, payment for your care and our healthcare operations. The following three categories describe some of the different ways that we use and disclose PHI. Not every possible use or disclosure is listed, but all of the ways we are permitted to use and disclose information will fall within one of these three categories:

1. Treatment. We may use your PHI to provide you with medical treatment or services. We may disclose your PHI to doctors, nurses, technicians, medical students, or other people who are taking care of you. We may also share your PHI to your other healthcare providers to assist them in treating you.
2. Payment. We may use your PHI so that we can collect payment from your insurance company, you, or another third party for the treatment and services you receive here. We may also tell your health plan or health insurer about a treatment you are going to receive to obtain prior approval or determine if your insurance plan will cover it.
3. Healthcare Operations. We may use and disclose your PHI for operation purposes. This might include measuring and improving quality, evaluating the performance of employees, conducting training programs, and getting the accreditation, certificates, licenses and credentials we need to serve you.

ADDITIONAL USES AND DISCLOSURES

• Appointment Reminders: We may contact you by phone or email to remind you that you have an appointment with us.
• Treatment Alternatives: We may tell you about or recommend possible treatment options or alternatives that may be of interest to you.
• Health-related Benefits and Services: We may tell you about health-related benefits, services, or healthcare education classes or health fairs that may be of interest to you.
• Individuals involved in your care or payment for your care: We may release or disclose your PHI to a friend or family member who is involved in your healthcare, to someone who helps pay for your care, or to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location. The information may include, but is not limited to, your condition and that you are in this office.
• As Required by Law: We will disclose your PHI when required to do so by federal, state, or local laws or regulations.
• To avert a serious threat to health or safety: We may use & disclose your PHI when necessary to prevent a serious threat to your health and safety, or the health and safety of others. Any disclosure, however, would only be to someone able to help prevent the threat from materializing, i.e. Law Enforcement.

SPECIAL SITUATIONS

Workers Compensation: We may disclose your PHI when authorized or necessary to comply with laws relating to workers compensation or other similar programs.

Military & Veterans: If you are a member of the armed forces, we may release your PHI as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.

Public Health & Safety: As required by law, we my disclose PHI for public health activities. These generally include, but are not limited to, the following:

• To prevent or control disease, injury or disability;
• To report vital statistics such as births or deaths;
• To report suspected abuse, neglect or domestic violence to the appropriate government authority;
• To report adverse 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.

Health Oversight Activities: We may disclose your PHI to an agency providing health oversite for oversite activities authorized by law, including audits, civil, administrative, or criminal investigtions, proceedings, inspections, licensure or disciplinary actions, or other authorized activities.

Legal Proceedings: We may disclose your PHI in the course of any legal proceeding in response to an order of the court or administrative agency and, in certain cases, in response to a subpoena, discovery request, or other lawful process.

Law Enforcement: We may release your PHI in certian situations if asked to do sy by a law enforcement official:

• 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 persons agreement;
• About a death we believe may be the result of criminal conduct;
• About criminal conduct which may have occurred at APCCFA;
• In emergency circumstances to report a crime, the location of the crime, or the identity, description and/or location of the victim or person who may have committed the crime.

Funeral Director, Coroner, Medical Examiner: To help them carry out their duties, we may share the PHI of a deceased patient with a coroner, medical examiner, funeral director, or an organ procurement organization.

National Security and Intelligence Activities: We may release your PHI to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law or in connection with providing protective services.

YOUR HEALTH INFORMATION RIGHTS

You have the right to request:

• Restrictions by asking, in writing, that we limit the way we use or disclose your PHI for treatment, payment, or healthcare operations. You may also ask, in writing, that we limit the informaton we give to someone who is involved in your care, i.e. family member or friend. We are not required to agree to your request.  If we do agree to your request, we will honor your restrictions unless it is an emergency.
• That we communicate with you by another means to preserve confidentiality (i.e. a different address, phone or email).
• Access to or a copy of your PHI. Your request must be specific and submitted in writing. We may charge a reasonable fee for the cost of reproducing and mailing copies. In certain situations we may deny your request and will tell you why it is denied. In some cases, you may have the right to ask for a review of our denial.
• That we amend your PHI in our records that you believe is incorrect or incomplete. Your request must be in writing and provide the reason for your request. In certain cases, we may deny your request. If so, we will notify you in writing. You may respond by filing a written statement of disagreement with us and ask that the statement by included with your PHI.
• An accounting of certain disclosures by asking us in writing, for a list of disclosures we have made of your PHI, except for disclosures for treatment, payment, healthcare operations, information provided to you and certain government functions. You may recieve one list per year (12 months) at no charge. If you request another list during the same 12 month period, we may charge your a reasonable fee.
• A paper copy of this notice. We will offer you a copy of this notice the first time you receive care at APCCFA. You may request a copy of this notice at any time.

OTHER USES OF PHI

Other uses and disclosures of PHI not covered by this notice or laws that apply to us will be made only with your written permission. If you provide permission, in writing, to use or disclose your PHI, you may revoke that permission, in writing, at any time. If you revoke your permission, we will not longer use or disclose your PHI for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures made with your permision prior to revocation and that in any event we are required to retain our records of the care that we provided to you.

CHANGES TO THIS NOTICE

We reserve the right to change the terms of this notice at any time. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will make a copy of the current policy available. The notice will contain the effective date at the beginning of this notice.

COMPLAINTS

If you have questions about this notice or if you feel that we may have violated your privacy rights, please contact us by phone, or submit your complaint in writing to the office. If we are unable to resolve your concern, you may contact the Department of Health by visiting their website: www.hhs.gov/ocr/privacy/hipaa/complaints/index.html.