Notice of Privacy Practices
I. 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.
The terms of this Notice of Privacy Practices apply to ProMedica Health System, Inc. (“ProMedica”). ProMedica is a covered entity that includes general acute care hospitals, ambulatory surgery centers, clinics, physician offices, home health care, and other health care facilities. ProMedica, its employees, volunteers, students, independent contractors, Medical Staff, and other professionals will share personal health information of patients with other ProMedica entities as necessary to carry out treatment, payment, and health care operations as permitted by law.
II. We Have a Legal Duty to Protect Your Health Information
We're required by law to protect the privacy of your health information. We're also required to provide you with this notice about our privacy practices. We're required to comply with all of the terms described in the current version of our Notice of Privacy Practices.
You can request a copy of this notice from the contact person listed in Section VI below at any time and can view a copy of this notice on our Web site at www.promedica.org.
III. How We May Use And Disclose Your Health Information
A. Use and Disclosure That Does Not Require Your Authorization
ProMedica collects health information from you and stores it in a paper chart and on a computer. The collected information may be used for the following purposes.
1. For treatment. We may give information about you to physicians, nurses, medical students, and other health care personnel who are involved in your care.
2. To obtain payment for treatment. We may give portions of your information to our billing department and to your health plan to get paid for the services we provided to you. We may give your information to our business associates, such as billing companies, claims processing companies, law firms, collection agencies, and others that process our health care claims. We may also give your information to another health care provider that has treated you for their payment purposes.
3. For regular health care operations. We may disclose information about you to operate this business. For example, we may use information about you to look at the quality of health care services that you received or to look at the performance of the professionals who provided health care services to you. We may provide information about you to our accountants, attorneys, consultants, and others in order to make sure we are complying with the laws that affect us. We may also give your information to other health care providers and health plans for their business operations if they have or had a patient relationship with you.
4. When required by federal, state or local law, judicial or administrative proceedings, or law enforcement. For example, we give out your information when a law requires that we report information to government agencies and law enforcement personnel about victims of abuse, neglect, or domestic violence; when dealing with gunshot and other wounds; either by subpoena or when ordered by the court.
5. For public health activities. For example, we report information about births, deaths, and various diseases, to government officials in charge of collecting that information, and we give coroners, medical examiners, and funeral directors necessary information relating to a death.
6. For health oversight activities. For example, we will provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.
7. For purposes of organ donation. We may notify organ procurement organizations to assist them in organ, eye, or tissue donation and transplants.
8. For research purposes. We may give information about you in order to conduct research that has been approved by the ProMedica Institutional Review Board.
9. To avoid harm. In order to avoid a serious threat to the health or safety of a person or the public, we may give your information to law enforcement personnel or persons able to prevent or lessen such harm.
10. For specific government functions. We may give out information on military personnel and veterans in certain situations. We may also give your information for national security purposes, such as protecting the President of the United States or conducting intelligence operations, or to the U.S. Department of Health and Human
Services to show compliance with HIPAA privacy laws.
11. For workers' compensation purposes. We may release your information to your employer when we have provided health care to you at the request of your employer to determine workplace-related illness or injury.
12. Appointments and services. We may contact you to remind you of an appointment or give you a test result. You have the right to request that messages not be left on voice mail or sent to a particular address. We may also contact you to give you information about treatment alternatives, or other health care services and benefits we offer.
13. Fundraising activities. We may contact you to raise funds for our organization. The money raised through these activities is used to expand and support the health care services and educational programs we provide to the community. If you do not wish to be contacted as part of our fundraising efforts, please call the confidential ProMedica Hotline number listed in Section VI below and your information will be forwarded to the appropriate department.
B. You Have the Opportunity to Object to These Disclosures
1. Patient directories. We may include your name, location in this facility, general condition, and religious affiliation, in our patient directory for use by clergy and visitors who ask for you by name. If you do not want us to provide this information to clergy and others, you must tell us that you object and fill out the appropriate form.
2. Disclosures to family, friends, or others. We may provide your information to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object and fill out the appropriate form.
Information Exchanges. We may share your
information through secure electronic means both to and from health care
providers who are treating you. Examples
of “electronic means” include, but are not limited to, ProMedica Link and Care
Everywhere. If you do not wish to
participate in ProMedica’s Health Information Exchanges, tell us you object and
fill out the appropriate form, which can be obtained at the time of
C. Disclosures that Require Your Authorization
Disclosures related to psychiatric treatment programs, human immunodeficiency virus (HIV) test results or diagnosis of AIDS or an AIDS-related condition, or information about alcohol or drug treatment you received in a drug or alcohol treatment program, or certain information to the State Long-Term Care Ombudsman, will not be made without your authorization except as required or allowed by law. Before we use, disclose or sell your personal health information for any reason other than those reasons described in Section III.A and III.B, we will need to get your written authorization. If you authorize us to use or disclose your information, you can revoke your authorization by filling out the appropriate form.
D. Patient Safety Room Surveillance
In some patient rooms video surveillance may be used for the purposes of patient safety and treatment. These images are not recorded and signage will be posted where video surveillance is in use.
IV. Your Health Information Rights
A. The Right to Request Limits on How We Use and Disclose Your Health Information.
You have the right to ask that we limit how we use and give out your information. We will carefully consider your request, but we are not required to accept it, except for certain disclosures when you have paid for service out-of-pocket in full.
If we accept your request, we will put it in writing and abide by it except in emergency situations. To request limits, complete the appropriate form at the facility where you are receiving care.
B. The Right to Choose How We Send Your Information to You.
You have the right to ask that we send information to you to an alternate address. For example, you may ask us to send information to your work address rather than your home address. You can also ask that it be sent by alternate means. For example, you can ask that we send information by fax instead of regular mail. We will agree to your request if we can easily provide it in the format you request.
C. The Right to See and Get Copies of Your Health Information.
Most of the time, you have the right to look at
or get copies / summary of your health
information that we have. Your request
must be on the appropriate form and signed by you or your legally authorized
representative. If we keep your health information in an Electronic Health
Record, it will be given to you (or your designee) electronically upon your request.
We will provide a copy / summary usually within 30 days.
We will charge a reasonable cost-based fee. In
certain situations, we may deny your request. If we do, we will tell you, in
writing, our reasons why and explain how you can have the denial reviewed.
D. The Right to Get a List of Who We Have Given Your Information To.
You have the right to get a list of certain instances in which we have given out your health information after April 14, 2003. To get this list, you must complete the appropriate form and submit it to the facility where you received your care.
E. The Right to Correct or Update Your Health Information.
If you believe that there is a mistake in your information or that a piece of important information is missing, you have the right to request that we correct the existing information or add the missing information. Your request and your reason for the request must be submitted on the appropriate form.
Each request will be carefully considered. If we approve your request, we will make the change to your information, tell you that we have done it, and tell others that need to know about the change.
F. The Right to Get This Notice.
You have the right to request a paper copy of this notice. You also have a right to get a copy of this notice by e mail.
G. The Right to Privacy Notification.
You have the right to be notified after a breach of your protected health information.
V. Changes to the Policy
VI. Complaints and Contact Information
If you think that we may have violated your privacy rights, or you disagree with a decision we made about your health information,you may file a complaint with the U.S.
Department of Health and Human Services Office for Civil Rights by sending a
letter to 200 Independence Avenue, S.W., Washington, D.C. 20201; calling
1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints. We will not retaliate against you for filing a
If you have any questions about this notice or any complaints about our privacy practices, please call the confidential ProMedica Hotline at 419-824-1815 or 800-807-2693. Your information will be directed to the appropriate Privacy Officer or Patient Representative.
VII. Effective Date of This Notice
Effective Date: April 14, 2003
Revised Date: February 17, 2010
Revised Date: May 16, 2011
Revised Date: December 1, 2011
Revised Date: August 13, 2013
Revised Date: April 19, 2016
Revised Date: May 11, 2016