InXite Health Systems Notice of Privacy Practices

InXite Health Systems Notice of Privacy Practices (“Notice”) Effective Date: November 27, 2018

This Notice describes how med­ical infor­ma­tion about you which is Pro­tect­ed Health Infor­ma­tion (PHI) may be used and dis­closed and how you can get access to your PHI. Review it care­ful­ly. We are required by law to main­tain the pri­va­cy of PHI, to pro­vide indi­vid­u­als with notice of the legal duties and pri­va­cy prac­tices of InX­ite Health Sys­tems, Inc. (“InX­ite”) with respect to PHI and to noti­fy affect­ed indi­vid­u­als fol­low­ing a breach of unse­cured PHI. If you have any ques­tions about this Notice, you may ask a mem­ber of the staff where you receive health care ser­vices. You may also con­tact our Pri­va­cy Office at 614–408-1680. You may obtain our most cur­rent Notice by call­ing or writ­ing to our pri­va­cy offi­cer to request that a copy be sent to you in the mail or by ask­ing for it when you come in for an appoint­ment. The address for our pri­va­cy offi­cer is pro­vid­ed at the end of this Notice.

Uses and disclosures we are permitted or required to make

The fol­low­ing is a descrip­tion of the types of uses and dis­clo­sures of your PHI that we are per­mit­ted or required to make. Not every use or dis­clo­sure pos­si­ble is list­ed, but all of the ways that we are per­mit­ted to use and dis­close your PHI will fall with­in one of these gen­er­al cat­e­gories.

Treatment

We will use and dis­close your PHI to pro­vide you care man­age­ment and coor­di­na­tion prac­tices relat­ed health­care ser­vices. This includes dis­clo­sure of your PHI to doc­tors, spe­cial­ists, phar­ma­cies and oth­er third par­ties who are involved in your care. For exam­ple, we will dis­close your PHI to anoth­er physi­cian to whom you have been referred, to the physi­cian who referred you to us or to a home health agency that will be car­ing for you. We will use your PHI dur­ing con­tin­u­um of care coor­di­na­tion which may include, with­out lim­i­ta­tion, physi­cians, nurs­es, care man­agers, social work­ers, phar­ma­cists, phys­i­cal ther­a­pists, spir­i­tu­al care work­ers, nutri­tion staff, etc. who are involved in your care.

Payment

We will use and dis­close your PHI so that we may bill for health care ser­vices and so that pay­ment may be col­lect­ed for the health care ser­vices you receive. This includes activ­i­ties such as com­mu­ni­cat­ing your PHI to an insur­ance com­pa­ny.

Health care operations

We will use and dis­close your PHI as nec­es­sary for health care oper­a­tions. For instance, we may use your infor­ma­tion to eval­u­ate the per­for­mance of health­care pro­fes­sion­als for clin­i­cal qual­i­ty mea­sure pur­pos­es.

Additional rights under Federal and State laws

Fed­er­al and State laws may fur­ther lim­it our uses and dis­clo­sures in the case of your PHI. This includes HIV-relat­ed records, records of alco­hol or sub­stance abuse treat­ment and men­tal health records. If Fed­er­al and/or State law applies to your PHI, we will use and dis­close your PHI in com­pli­ance with these more restric­tive laws.

Appointment reminders

We may call you on the tele­phone, send you an email, or SMS/text you to remind you of an upcom­ing appoint­ment. We may leave you a voice mes­sage that includes the date, time and gen­er­al infor­ma­tion about an upcom­ing appoint­ment on your tele­phone answer­ing device. We may also send you an appoint­ment reminder in the mail.

Treatment alternatives/other health-related benefits and services

We may use or dis­close your PHI to con­tact you to pro­vide you with infor­ma­tion about treat­ment alter­na­tives or oth­er health-relat­ed ben­e­fits and ser­vices that may be of inter­est to you.

Individuals involved in your care

We may dis­close your PHI to those peo­ple who are involved in your care, such as fam­i­ly mem­bers and friends.

As required by law or legal process

We will dis­close your PHI when we are required to do so by local, state or fed­er­al law or process of law.

To avert a serious threat to health or safety

We may use or dis­close your PHI for rea­sons which include pre­vent­ing a seri­ous threat to your health and safe­ty, or the health and safe­ty of oth­ers.

Cadaveric organ, eye and tissue donation

We may dis­close the PHI of organ donors to orga­ni­za­tions that assist with such dona­tions.

Specialized government functions

We may use or dis­close your PHI for spe­cial­ized gov­ern­ment func­tions such as mil­i­tary, nation­al secu­ri­ty and pres­i­den­tial pro­tec­tive ser­vices.

Workers’ compensation

We may dis­close your PHI for pur­pos­es of han­dling your work­ers’ com­pen­sa­tion claims in com­pli­ance with applic­a­ble laws, rules and reg­u­la­tions.

Public health activities

We may dis­close your PHI to pub­lic health enti­ties as autho­rized by law. Such dis­clo­sures include (but are not lim­it­ed to) reports of births and deaths, child or elder abuse and neglect, and domes­tic vio­lence.

Health oversight activities

We may dis­close your PHI to agen­cies of the gov­ern­ment for activ­i­ties autho­rized by law. These activ­i­ties include mon­i­tor­ing health care sys­tems and par­tic­i­pa­tion in gov­ern­ment pro­grams.

Lawsuits and disputes

If you are involved in a law­suit or oth­er dis­pute, we may dis­close your PHI in response to doc­u­ments such as a court order or when cer­tain oth­er require­ments are met.

Law enforcement

We may dis­close your PHI if asked to do so by a law enforce­ment offi­cial for rea­sons includ­ing (but not lim­it­ed to) iden­ti­fy­ing or locat­ing a sus­pect, a wit­ness or a miss­ing per­son, or inves­ti­gat­ing crim­i­nal activ­i­ty.

Coroners, medical examiners and funeral directors

We may dis­close cer­tain PHI to a coro­ner or med­ical exam­in­er. We may also dis­close cer­tain PHI about deceased patients to funer­al direc­tors so that they may car­ry out their duties.

Inmates

If you are an inmate of a cor­rec­tion­al insti­tu­tion or under the cus­tody of a law enforce­ment offi­cial, we may dis­close your PHI to the respec­tive cor­rec­tion­al insti­tu­tion or law enforce­ment offi­cial in accord with applic­a­ble laws, rules, reg­u­la­tions and our poli­cies.

Business associates

Some of the ser­vices we pro­vide are per­formed through con­trac­tu­al rela­tion­ships with out­side par­ties or busi­ness asso­ciates. These ser­vices may include (but are not lim­it­ed to) finan­cial, audit­ing and legal. We ask our busi­ness asso­ciates to sign an agree­ment that restricts the abil­i­ty of the busi­ness asso­ciate to use or dis­clo­sure your PHI in an effort to make sure that all PHI is appro­pri­ate­ly safe­guard­ed.

Research

We may use or dis­close your PHI for cer­tain research pur­pos­es when such research is approved by an insti­tu­tion­al research review board, as appro­pri­ate.

Receiving payment for PHI

Unless allowed by law, we may not receive pay­ment direct­ly or indi­rect­ly for your PHI with­out your autho­riza­tion.

You have rights regarding your PHI

Your right to inspect and copy

You have the right to inspect and receive a copy (paper or elec­tron­ic) of your PHI that may be used to make deci­sions about your care. You may also direct us in writ­ing to trans­mit your PHI to anoth­er enti­ty or indi­vid­ual.

To do so, you must com­plete a Patient Access Request Form. You may obtain a copy of the form by con­tact­ing our Pri­va­cy Office direct­ly using the con­tact infor­ma­tion at the end of this Notice. If you need assis­tance com­plet­ing the form, please con­tact the Pri­va­cy Office at 614–408-1680 or via email at info@inxitehealth.com.

Note that you may be charged a rea­son­able cost-based fee. Note also that we may deny your request to inspect and receive a copy of your PHI in very lim­it­ed cir­cum­stances. If you are so denied, in some cas­es, you may request that such denial be reviewed. We will com­ply with the out­come of such review.

Authorizations

You may also wish to grant anoth­er indi­vid­ual or enti­ty the right to access or obtain your PHI. To do so, you must com­plete an autho­riza­tion form that com­plies with the law.

If you pro­vide us with a writ­ten autho­riza­tion to dis­close your PHI, you may revoke (can­cel) it at any time. Your revo­ca­tion (can­cel­la­tion) must be in writ­ing. Con­tact our Pri­va­cy Office at 614–408-1680 for more infor­ma­tion. We are not able to take back any uses or dis­clo­sures that we already made with your autho­riza­tion.

With­out your autho­riza­tion, we will not dis­close your PHI for mar­ket­ing pur­pos­es as set forth under the HIPAA rules. If we have psy­chother­a­py notes (as defined by the HIPAA Rules), we will not dis­close them unless you sign an autho­riza­tion.

You may also want to grant anoth­er indi­vid­ual or enti­ty rights to access your PHI. If you wish to do so, you can con­tact the Pri­va­cy Office at 614–408-1680 or at info@inxitehealth.com and request the appro­pri­ate autho­riza­tion form for grant­i­ng access.

Your right to amend

We are required to retain your PHI regard­ing the care and treat­ment that is pro­vid­ed to you in accor­dance with applic­a­ble law. You have the right to have us amend PHI or a record about you in a des­ig­nat­ed record set for so long as your PHI is main­tained in the des­ig­nat­ed record set. How­ev­er, we may deny such a request if we deter­mine that the PHI or record that is the sub­ject of the request: (i) was not cre­at­ed by us, unless you pro­vide us with a rea­son­able basis to believe that the orig­i­na­tor of PHI is no longer avail­able to act on the request­ed amend­ment; (ii) is not part of the des­ig­nat­ed record set; (iii) would not be avail­able for inspec­tion under 45 CFR 164.524; or (iv) is accu­rate and com­plete. Gen­er­al­ly, we must respond in writ­ing to your request with­in six­ty (60) days. How­ev­er, we may extend the time for such action by no more than thir­ty (30) days as pro­vid­ed under HIPAA. If we do not agree to your request, you have the right to sub­mit a state­ment of dis­agree­ment that we must add to your med­ical record. Con­tact our pri­va­cy offi­cer at 614–408-1680 to request an amend­ment.

Your right to an accounting of disclosures

You have the right to an account­ing of dis­clo­sures. This is a list (account­ing) of the times we’ve dis­closed your health infor­ma­tion for six years pri­or to the date you ask, who we’ve shared it with and why. In com­pli­ance with the law, we will include all the dis­clo­sures except for those about treat­ment, pay­ment, and health care oper­a­tions, and cer­tain oth­er dis­clo­sures (such as any you have asked us to make). We will pro­vide you with an account­ing of dis­clo­sures if you request it and in accord with the law. Con­tact our pri­va­cy offi­cer at 614–408-1680 to make such a request.

Your right to notification

We are required by law to main­tain the pri­va­cy and secu­ri­ty of your PHI. We will let you know prompt­ly if a breach occurs that may have com­pro­mised the pri­va­cy or secu­ri­ty of your infor­ma­tion. This will be done by mail or by oth­er means if nec­es­sary.

Your right to request restrictions

You have the right to request restric­tions on the PHI we use or dis­close about you for treat­ment, pay­ment and health care oper­a­tions. We are not required to agree to your request, and gen­er­al­ly, we will not accept requests for such restric­tions. As required by law, if you have paid out of pock­et for a health care ser­vice or item, you have the right to ask us to not tell your insur­ance com­pa­ny about such ser­vice or item for pur­pos­es oth­er than treat­ment. We will not share the PHI regard­ing such care with your insur­er for pur­pos­es of pay­ment or health care oper­a­tions.

Your right to request confidential communications

You have the right to make a rea­son­able request that we com­mu­ni­cate with you regard­ing your PHI in a cer­tain way or at a cer­tain loca­tion (for exam­ple, home or office phone). Such rea­son­able requests may include, when appro­pri­ate, how infor­ma­tion as to pay­ment for ser­vices we pro­vide to you will be han­dled. We may require you to make this request in writ­ing to the man­ag­er of your care site.

Your right to a paper copy of this Notice

Gen­er­al­ly, you have a right to obtain a paper copy of this Notice. You may ask us to give you a copy of this Notice at any time, even if you have agreed to receive this Notice elec­tron­i­cal­ly. You may also obtain a paper copy of this Notice at the reg­is­tra­tion desk at your next appoint­ment.

Changes to this Notice

We may change this Notice at any time. We may make the revised or changed Notice effec­tive for PHI we already have as well as any PHI we receive in the future. We will post a cur­rent copy of this Notice on our com­pa­ny web­site www.inxitehealth.com. You will find the effec­tive date of that Notice at the top of the Notice. If we make a mate­r­i­al change to uses and dis­clo­sures, your rights, our legal duties or oth­er pri­va­cy prac­tices stat­ed in this Notice, we will prompt­ly revise and dis­trib­ute our changed Notice. Except when required by law, a mate­r­i­al change to any term of this Notice may not be imple­ment­ed pri­or to the effec­tive date of the revised Notice.

Complaints

If you believe your pri­va­cy rights have been vio­lat­ed, you may file a com­plaint with our pri­va­cy offi­cer and/or the sec­re­tary of the U.S. Depart­ment of Health and Human Ser­vices. We have pro­vid­ed both address­es on the last page of this Notice. To file a com­plaint with the Pri­va­cy Office, please call 614–408- 1680. InX­ite val­ues your right to pri­va­cy. You will not be retal­i­at­ed against for fil­ing a com­plaint.

Other uses of your PHI

Oth­er uses and dis­clo­sures of your PHI not cov­ered by the cat­e­gories includ­ed in this Notice or applic­a­ble laws, rules or reg­u­la­tions will be made only with your writ­ten per­mis­sion or autho­riza­tion.

We are required to abide by the terms of this Notice.

Addresses

The address for our privacy office is:

InX­ite Health Sys­tems — Pri­va­cy Office
1 East Cam­pus View Blvd, Suite 320
Colum­bus, OH 43235
1–614-408‑1680

The address for the United States Department of Health and Human Services is:

U.S. Depart­ment of Health and Human Ser­vices
200 Inde­pen­dence Ave. SW
Wash­ing­ton, DC 20201
1–877-696‑6775
Web­site: hhs.gov/ocr/privacy/hipaa/complaints

Last Revi­sion Date: Novem­ber 27, 2018