NOTICE OF HEALTH INFORMATION PRACTICES

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    THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION
    PLEASE REVIEW IT CAREFULLY


    [AMENDED EFFECTIVE SEPTEMBER 23, 2013]


    UNDERSTANDING YOUR HEALTH INFORMATION:

    Each time you visit a hospital, physician, or other health care provider, a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. This information, often referred to as your health or medical record, serves as a:

         * basis for planning your care and treatment
         * means of communication among the many health professionals who contribute to your care
         * legal document describing the care you received
         * means by which you or a third-party payer can verify that services billed were actually provided
         * tool in educating health professionals
         * source of data for medical research
         * source of information for public health officials charged with improving the health of the nation
         * source of data for facility planning and marketing
         * tool with which we can assess and continually work to improve the care we render and the outcomes we achieve

    Understanding what is in your record and how your health information is used helps you to:
         * ensure its accuracy
         * better understand who, what, when, where, and why others may access your health information
         * make more informed decisions when authorizing disclosure to others


    WHO WILL FOLLOW THIS NOTICE:

    This Notice describes the privacy practices of Washington County Hospital and Clinics (WCHC), WCHC Women's Healthcare, WCHC McCreedy Home, WCHC Medical Clinic, WCHC Family Mdicine, WCHC Kalona Clinic, and WCHC Bean's Pharmacy, and its employees and its medical staff, and other credentialed health care professionals who are part of our staff, while caring for you at WCHC.

    When we use the terms "we" and "WCHC" in this notice, this includes Washington County Hospital and Clinics, WCHC Women's Healthcare, WCHC McCreedy Home, WCHC Medical Clinic, WCHC Family Medicine, WCHC Kalona Clinic, and WCHC Bean's Pharmacy.

    All of our employees as well as members of our medical staff and other credentialed health care professionals who are part of our staff may have access to information in your chart for treatment, payment, and health care operations, and may use and disclose information as described in this Notice. This Notice also applies to any member of any volunteer group or trainee we allow to help you while seeking services at WCHC.


    YOUR HEALTH INFORMATION RIGHTS:

    Although your health record is the physical property of Washington County Hospital and Clinics (WCHC), the health care practitioner, or facility that compiled it, the information belongs to you. You have the following rights:

    You may request that we not use or disclose your health information for a particular reason or that your health information not be disclosed to a particular family member, other relative, or close personal friend. Such requests must be made in writing on a form provided by WCHC. We are not required to honor such requests, unless the disclosure is to a health plan or other payer for purposes of carrying out payment or health care operations, and you have paid for the services in full and in advance yourself.

    You may obtain a paper copy of the Notice of Health Information Practices upon request.

    You may inspect and obtain a copy of your health record that will be provided to you within time frames established by law. With regard to your electronic medical record, you may request that you be provided with a copy electronically and you may request that an electronic copy of the electronic medical record be sent to another person or entity if you make the request in writing and sign an authorization. We may charge you a reasonable, cost based fee for any copies, including the cost of any supplies, such as a thumb drive or other electronic medium if you request an electronic copy of your information.

    If you believe that any health information in your record is incorrect or if you believe that important information is missing, you may request that we correct the existing information or add the missing information. Such requests for amendment must be made in writing, and must provide a reason to support the amendment. We ask that you use a request form available from WCHC Health Information to make such requests. We are not required to amend your record but will consider all requests.

    You may obtain a written accounting of disclosures of your health information with a general time period not to exceed six years . These disclosures do not include disclosures for treatment, payment, or health care operations purposes, unless the disclosures were made from your electronic medical record, in which case you may receive an accounting for the three years prior to your request. Please provide requests in writing on a form provided by WCHC Health Information.

    You may request communications of your health information by alternative means or at alternative locations. The request must be made in writing using a form provided by WCHC. The request must be submitted to Health Information. We will attempt to accommodate all reasonable requests.

    You may revoke your authorization to use or disclose health information except to the extent that action has already been taken. All requests must be made in writing.

    We are not required to agree to requested restrictions, amendments or disclosures except as provided above. You will be notified in writing of the final decision and the reason for the decision if appropriate. All requests and responses in regard to the above requests become a part of your health record.


    OUR RESPONSIBILITIES:

    Washington County Hospital and Clinics is required to:

         * maintain the privacy of your health information
         * provide you with a notice as to our legal duties and privacy practices with respect to information we collect and maintain about you
         * abide by the terms of this notice
         * notify you if we are unable to agree to a requested restriction
         * accommodate reasonable requests you may have to communicate health information by alternative means or at alternative         locations.
         * inform you of any unauthorized access, use or disclosure of your unencrypted confidential information in the event its security or         privacy is compromised (i.e., in the event that a reportable breach occurs as provided by the HIPAA Omnibus Final Rule.) We will         provide such notice to you without unreasonable delay but in no case later than sixty days after we discover the breach.

    We reserve the right to change our practices and to make the new provisions effective for all protected health information we maintain without being required to provide you individual notice of the changes. Should our information practices change, we will make the revised notice available upon request, we will post the revised notice on our bulletin board, and will post the revised notice on our web site at http://www.wchc.org

    We will not use or disclose your health information without your authorization, except as described in this notice.



    FOR MORE INFORMATION OR TO REPORT A PROBLEM:

    If you have questions and would like additional information, you may contact the Privacy Officer at 319-653-5481 or Compliance Hotline at 319-863-2076. If you believe your privacy rights have been violated, you can file a complaint with the WCHC Privacy Officer or with the Secretary of Health and Human Services at http://www.hhs.gov/ocr/hipaa/. There will be no retaliation for filing a complaint.


    HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU:

    The following categories describe different ways that we may use and disclose medical information about you without your consent or authorization. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. This Notice covers treatment, payment, and what are called health care operations, as discussed below. It also covers other uses and disclosures for which a consent or authorization are not necessary. Where applicable state law is more protective of your medical information, we will follow state law, as explained on the following pages.

    DISCLOSURES FOR WHICH YOUR AUTHORIZATION IS NOT NECESSARY

    1. We will use your health information for treatment.

    For example:
    Information obtained by a nurse, physician, or other member of your health care team will be recorded in your record and used to determine the course of treatment that should work best for you. Your physician will document in your record his or her expectations of the members of your health care team. Members of your health care team will then record the actions they took and their observations. In that way, the physician will know how you are responding to treatment.

    We will also provide your physician or a subsequent health care provider with copies of various reports that should assist him or her in treating you after your discharge from this hospital.

    For example: We may provide PHI and medical information to Mercy Hospital, University of Iowa Health Care, nursing homes, home health agencies, Public Health, hospice, pharmacies, and reference laboratories such as Cross Medical Laboratory. From time to time, we will also provide your PHI to other health care providers or to outside laboratories, or other health care services that provide services to you, but do not have direct patient contact with you. These are called indirect treatment providers. They are also required to comply with the confidentiality provisions of HIPAA.

    2. We will use your health information for payment.

    For example:
    A bill may be sent to you or a third-party payer, including Medicare or Medicaid. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, procedures, and supplies used.

    3. We will use your health information for regular health operations.

    For example:
    Members of the medical staff, the risk or quality improvement manager, or members of the quality improvement team may use information in your health record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the health care and service we provide.

    4. Business associates: WCHC from time to time will hire outside individuals or entities called "business associates", who render services to WCHC. Examples include claims processors, legal counsel, and a service we use when making microfilm copies of your health record. When these services are contracted, we may disclose your health information to our business associate without your consent or authorization so that they can perform the job we have asked them to do. Business associates are required to maintain and comply with the privacy requirements of state and federal law and keep your medical information confidential.

    5. Directory: Unless you notify us that you object, we will use your name, location in the facility, general condition, and religious affiliation for directory purposes. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name.

    6. Notification: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, of your location, and general condition.

    7. Communication with family for treatment or payment purposes: Health professionals, using their best judgement, may disclose to a family member, other relative, close personal friend or any other person you identify, health information relevant to that person's involvement in your care or payment related to your care.

    8. Research: We may disclose information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.

    9. Funeral directors: We may disclose health information to funeral directors consistent with applicable law to carry out their duties.

    10. Organ procurement organizations: Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

    11. Appointment Reminders, Treatment Alternatives and Health Related Benefits and Services: We may contact you to provide appointment reminders, newsletters, surveys, or information about treatment alternatives and other health-related benefits and services that may be of interest to you Privacy Officer (see below)

    12. Fund raising: We may contact you as part of a fund-raising effort, but you have the right to opt out of any such communications in the future by contacting the Privacy Officer.

    13. Food and Drug Administration (FDA): We may disclose to the FDA health information relative to adverse events with respect to food, supplements, product, and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.

    14. Workers' compensation: We may disclose health information to the extent authorized by and to the extent necessary to comply with Iowa's laws relating to workers compensation or other similar programs established by law.

    15. Public health: As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

    16. Correctional institution: Should you be an inmate of a correctional institution, we may disclose to the institution or agents thereof health information necessary for your health and the health and safety of other individuals.

    17. Law enforcement: We may disclose health information for law enforcement purposes as required or permitted by law, including but not limited to disclosures in response to a court order, subpoena, warrant, summons or similar process, and/or to identify or locate a suspect, fugitive, material witness, or missing person

    18. Reports: Federal law makes provisions for your health information to be released to an appropriate health oversight agency, a public health authority or attorney; provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public.


    HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU WITH AUTHORIZATION:

    Some uses and disclosures of your medical information can be made only with your written authorization, unless otherwise permitted or required by law. You may revoke this authorization anytime, in writing, unless WCHC relies on the use or disclosure indicated in the authorization. 

    Examples of those uses and disclosures that may only be made with your written authorization:

         * We will obtain your authorization for categories of uses and disclosures of your health information that are not described in the Notice above.

         * WCHC will disclose AIDS or HIV-related information, or substance abuse treatment information only with written authorization as required by applicable state law and/or federal regulations unless the law expressly permits otherwise.

         * WCHC will provide mental health information only if you have signed an authorization consistent with Iowa law.

         * WCHC will disclose separately maintained psychotherapy notes only with a specific authorization signed by you or your legal representative.

         * WCHC will not use or disclose your protected health information for marketing purposes without your authorization. Moreover, if we will receive any financial remuneration from a third party in connection with marketing, we will tell you that in the authorization form. You have the right to opt out of marketing communications by contacting the Privacy Officer.

         * WCHC will not sell your protected health information to third parties without your authorization. Any such authorization will disclose that we will receive compensation in the transaction.

    If you provide authorization for the disclosure of your health information, you may revoke it at any time by giving notice in writing to the Privacy Officer. Your revocation will not be effective for uses and disclosures made in reliance on your prior authorization.





    Effective Date: September 23, 2013
    References
    Public Health Service, Department of Health and Human Services. "Confidentiality of Alcohol and Drug Abuse Patient Records."
    Title XIII of the American Recovery and Reinvestment act of 2009
    HIPAA Final Omnibus Rule, effective September 23, 2013