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.
USE AND DISCLOSURE OF HEALTH INFORMATION
Traditions Health, LLC (“Traditions”) may use your information that constitutes protected health information (“health information”) as defined in the Privacy Rule of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996, for purposes of providing you treatment, obtaining payment for your care, and conducting health care operations. We have established policies to guard against unnecessary disclosure of your health information.
THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH, AND PURPOSES FOR WHICH, YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:
To Provide Treatment. We may use your health information to coordinate care within Traditions’ affiliates and with others involved in your care, such as your attending physician and other health care professionals who have agreed to assist in coordinating your care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. We also may disclose your health information to individuals outside of those directly involved in your care including family members, pharmacists, suppliers of medical equipment or other health care professionals.
To Obtain Payment. We may include your health information in invoices to collect payment from third parties for the care you receive from us. For example, we may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or us. We also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for home care and the services that will be provided to you.
To Conduct Health Care Operations. We may use and disclose health information to conduct health care operations and as necessary to provide quality care to all our patients. Health care operations include such activities as:
For example, we may use your health information to evaluate our staff performance, combine your health information with other patients in evaluating how to more effectively serve all of our patients or disclose your health information to our staff and contracted personnel for training purposes.
For Participation in A Health Information Exchange. We may access and share your health information electronically with other health care providers involved in your care through Traditions’ participation in a health information exchange. The purpose of this exchange of information is to support the delivery of safer and better coordinated patient care. Participation in the information exchange is voluntary. For more information regarding your rights and our participation in a health information exchange please see our website.
For Fundraising Activities. We may use information about you including your name, address, phone number and the dates you received care in order to contact you to raise money for the benefit of Traditions and its operations. We may also release this information to a related foundation. If you do not want us to contact you for fundraising activities, notify our Privacy Officer at compliance@traditionshealth.com and indicate that you do not wish to be contacted.
For Appointment Reminders. We may use and disclose your health information to contact you as a reminder that you have an appointment for a home visit or for discussion of treatment alternatives. We may use and disclose your health information to tell you, via newsletters, mailings, or other means, about or recommend possible treatment options or other health-related benefits and services that may be of interest to you.
To Individuals Involved In Your Care Or Payment For Your Care. We may release your health information to a friend or family member who is involved in your medical care. We may also give information to someone who helps pay for your care. We may also tell your family or friends your location or general condition. In addition, we may disclose your health information to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location. Unless doing so is inconsistent with any prior expressed preference of the patient that is known to Traditions, we may also disclose health information of a deceased patient to family members or friends who may have been involved in the care or payment for health care of the deceased patient. Such health information disclosed would be relevant to the level of involvement of the family member or friend.
THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH, AND PURPOSES FOR WHICH, YOUR HEALTH INFORMATION MAY ALSO BE USED AND DISCLOSED:
When Legally Required. We will disclose your health information when it is required to do so by any federal, state or local law or regulations.
When There Are Risks to Public Health. We may disclose your health information for public activities and purposes in order to:
To Report Abuse, Neglect Or Domestic Violence. We are allowed to notify government authorities if we believe a patient is the victim of abuse, neglect or domestic violence. We will make this disclosure only when specifically required or authorized by law or when the patient agrees to the disclosure.
To Conduct Health Oversight Activities. We may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. We, however, may not disclose your health information if you are the subject of an investigation not directly related to your receipt of health care or public benefits.
In Connection With Judicial And Administrative Proceedings. We may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only if reasonable efforts have been made to either notify you about the request or to obtain an order protecting your health information.
For Law Enforcement Purposes. We may disclose your health information to a law enforcement official for certain law enforcement purposes as follows:
To Coroners And Medical Examiners. We may disclose your health information to coroners and medical examiners for purposes of identifying a deceased person, determining cause of death or for other duties, as authorized by law.
To Funeral Directors. We may disclose your health information to funeral directors as necessary to carry out their duties with respect to your funeral arrangements. We may disclose your health information prior to and in reasonable anticipation of your death to the funeral director, if necessary to carry out their duties.
For Organ, Eye Or Tissue Donation. We may use or disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue for the purpose of facilitating the donation and transplantation.
For Research Purposes. We may, under very select circumstances, use your health information for research. Before we disclose any of your health information for such research purposes, we must obtain a written authorization, or the project will be subject to an extensive approval process. However, under certain conditions we may also disclose your health information for preparatory research, research on protected health information of decedents, and limited data sets.
In the Event of A Serious Threat To Health Or Safety. We may, consistent with applicable law and ethical standards of conduct, disclose your health information if, in good faith, we believe that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.
For Specified Government Functions. In certain circumstances, the Federal regulations authorize us to use or disclose your health information to facilitate specified government functions relating to military and veterans, national security and intelligence activities, protective services for the President and others, medical suitability determinations, inmates under law enforcement custody and determining eligibility for or conducting enrollment in certain government benefit programs.
For Worker’s Compensation. We may release your health information for worker’s compensation or similar programs, as permitted by law.
Business Associates. There are some services provided for Traditions through contracts with business associates. When these services are contracted, we will disclose your health information to the business associate so they can perform the job we have asked them to do. However, business associates are required by federal law to appropriately safeguard your information.
THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH, AND PURPOSES FOR WHICH, YOUR HEALTH INFORMATION WILL NOT BE USED AND DISCLOSED WITHOUT YOUR AUTHORIZATION:
We must obtain your written authorization prior to using or disclosing your health information if (i) the use or disclosure includes psychotherapy notes; (ii) the use or disclosure is for marketing purposes; (iii) the disclosure constitutes a sale of health information; and (iv) for any other uses and disclosures not described in this Notice.
AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION
Other than is stated above, we will not disclose your health information other than with your written authorization. If you or your representative authorizes us to use or disclose your health information, you may revoke that authorization in writing at any time. If you revoke your permission, 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 permission, and that we are required to retain our records of the care that we provided to you.
YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION
You have the following rights regarding your health information that we maintain:
Right To Request Restrictions. You may request restrictions on your health information that we use and disclose for treatment, payment, or health care operations. You have the right to request a limit on our disclosure of your health information to someone who is involved in your care or the payment of your care. We must agree to restrict disclosure of your personal health information upon your request, if:
For other situations, Traditions is not required to agree with your request. If we do agree, our agreement must be in writing, and we will comply with your request unless the information is needed to provide you emergency treatment.
If you wish to make a request for restrictions, please contact the Privacy Officer at compliance@traditionshealth.com. Your request should include: (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.
Right To Receive Confidential Communications. You have the right to request that we communicate with you in a certain way. For example, you may ask that we only conduct communications pertaining to your health information with you privately with no other family members present. If you wish to receive confidential communications, please contact the Privacy Officer at compliance@traditionshealth.com. We will not request reasons for your request and will attempt to honor your reasonable requests for confidential communications.
Right To Inspect And Copy Your Health Information. You have the right to inspect and copy your health information, including billing records. A written request to inspect and copy records containing your health information may be made to the Privacy Officer. If you request a copy of your health information, we may charge a reasonable fee for copying and assembling costs associated with your request. If we maintain your personal health information electronically, we must provide you with electronic access in a form and format requested by you, if the information is readily producible in such format.
We may deny your request to inspect and copy in very limited circumstances such as when Traditions believes access could cause harm to you or another. If you are denied access to health information, you may request that the denial be reviewed, and we will comply with the outcome of the review.
Right To Amend Health Care Information. You or your representative have the right to request that we amend your records if you believe that your health information is incorrect or incomplete. That request may be made as long as the information is maintained by us. A request for an amendment of records must be made in writing to the Privacy Officer. We may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by us, if the records you are requesting are not part of our records, if the health information you wish to amend is not part of the health information you or your representative are permitted to inspect and copy, or if, in our opinion, the records containing your health information are accurate and complete. If your request is denied, we must provide you with a written denial and allow you to submit a statement of disagreement for inclusion in the record.
Right To An Accounting. You or your representative have the right to request an accounting of disclosures of your health information made by us for certain reasons, including reasons related to public purposes authorized by law and certain research. The request for an accounting must be made in writing to the Privacy Officer. The request should specify the time period for the accounting, which may not be longer than six (6) years and may not include dates before April 14, 2003.We will provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.
Right To A Paper Copy Of This Notice. You or your representative have a right to a separate paper copy of this Notice at any time even if you or your representative have received this Notice previously or you previously elected to receive it electronically. You may obtain a copy of this Notice at our website: www.traditionshealth.com.
To obtain a separate paper copy, please contact our Privacy Officer.
OUR DUTIES
We are required by law to maintain the privacy of your health information and to provide to you and your representative this Notice of our duties and privacy practices. We are required to abide by the terms of this Notice of our duties and privacy practices and to notify you following a breach of your unsecured protected health information. Notice of such breach will be made in accordance with state and federal requirements. We are required to abide by the terms of this Notice as may be amended from time to time. We reserve the right to change the terms of our Notice and to make the new Notice provisions effective for all health information that we maintain. If we make a major change to the Notice, the revised Notice will be posted at Traditions’ headquarters and on our website. You or your personal representative have the right to express complaints to us and to the Secretary of the U.S. Department of Health and Human Services if you or your representative believe that your privacy rights have been violated. Any complaints to us should be made in writing to our Privacy Officer at the email address below. You will not be penalized or retaliated against for filing a complaint.
CONTACT PERSON
We have designated the Privacy Officer as its contact person for all issues regarding patient privacy and your rights under the Federal privacy standards, who can be contacted at compliance@traditionshealth.com or 979-704-6547.
This Notice was first published in 2008 and revised in June 2022.