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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. If you have any questions about this Notice
please contact our Privacy Officer or any staff member in our office.
Our Privacy Officer is Amy Peabody.
This Notice
of Privacy Practice describes how we may use and disclose your protected
health information to carry out your treatment, collect payment
for your care and manage the operations of this clinic. It also
describes our policies concerning the use and disclosure of this
information for other purposes that are permitted or required by
law. It describes your rights to access and control your protected
health information. “Protected Health Information” (PHI) is information
about you, including demographic information that may identify you,
that relates to your past, present, or future physical or mental
health or condition and related health care services.
Hill Country
Health Centers, Inc., owns and operates Dripping Springs Health
Center and Wimberley Health Center. Hill Country Health Center,
Inc. independently contracts with the following health care providers:
Dennis Bullock, DC, Erin Kethley, MPT, Jeremy Kethley, MPT, and
Bradley C. Sikes, DC, PA. This Notice of Privacy Practices serves
as notice for Hill Country Health Centers, Inc., as well as the
employees and independent contractors of Hill Country Health Centers,
Inc.
We are required
by federal to abide by the terms of this Notice of Privacy Practices.
We may change the terms of our notice at any time. The new notice
will be effective for all protected health information that we maintain
at that time. You may obtain revisions to our Notice of Privacy
Practices by accessing our website www.hchealth.com, calling the
office and requesting a revised copy be sent to you in the mail
or asking for one at the time of your next appointment.
1.Uses
and Disclosures of Protected Health Information
Uses and Disclosures of Protected Health Information Based Upon
Your Implied Consent
By applying to be treated in our office, you are implying consent
to the use and disclosure of your protected health information by
your doctor, therapist, our office staff and others outside of our
office that are involved in your care and treatment for the purpose
of providing health care services to you. Your protected health
information may also be used and disclosed to bill for your health
care and to support the operation of the practice.
Following are
examples of the types of uses and disclosures of your protected
health information we will make, based on this implied consent.
These examples are not meant to be exhaustive but to describe the
types of uses and disclosures that may be made by our office.
Treatment:
We will use and disclose your protected health information
to provide, coordinate, or manage your health care and any related
services. This includes the coordination or management of your health
care with a third party that has already obtained your permission
to have access to your protected health information. For example,
we would disclose your protected health information, as necessary,
to another physician who may be treating you. Your protected health
information may be provided to a physician to whom you have been
referred to ensure that the physician has the necessary information
to diagnose or treat you. In addition, we may disclose your protected
health information to another physician or health care provider
who becomes involved in your care by providing assistance with your
health care diagnosis or treatment.
Payment:
Your protected health information will be used, as needed, to obtain
payment for your health care services. This may include certain
activities that your health insurance plan may undertake before
it approves or pays for the health care services we recommend for
you such as; making a determination of eligibility or coverage for
insurance benefits, reviewing services provided to you for medical
necessity, and undertaking utilization review activities.
Healthcare
Operations: We may use or disclose, as needed, your protected
health information in order to support the business activities of
this office. These activities may include, but are not limited to,
quality assessment activities, employee review activities and training
of students. We may also call you by name in the reception or treatment
areas. We may use or disclose your protected health information,
as necessary, to contact you to remind you of your appointment.
We will share
your protected health information with third party “business associates”
that perform various activities (e.g., billing, transcription services
for the practice). Whenever an arrangement between our office and
a business associate involves the use or disclosure of your protected
health information, we will have a written contract with that business
associate that contains terms that will protect the privacy of your
protected health information.
We may use or
disclose your protected health information, as necessary, to provide
you with information about treatment alternatives or other health-related
benefits and services that may be of interest to you. We may also
use and disclose your protected health information for other internal
marketing activities. For example, your name and address may be
used to send you a newsletter about our practice and the services
we offer. We may also send you information about products or services
that we believe may be beneficial to you. You may contact our Privacy
Officer to request that these materials not be sent to you.
Uses
and Disclosures of Protected Health Information That May Be Made
With Your Written Authorization
Other uses and disclosures of your protected health information
will be made only with your written authorization, unless otherwise
permitted or required by law as described below.
Other
Permitted and Required Uses and Disclosures That May Be Made With
Your Authorization or Opportunity to Object
In the following instance where we may use and disclose your protected
health information, you have the opportunity to agree or object
to the use or disclosure of all or part of your protected health
information. If you are not present or able to agree or object to
the use or disclosure of the protected health information, then
your doctor may, using professional judgment, determine whether
the disclosure is in your best interest. In this case, only the
protected health information that is relevant to your health care
will be disclosed.
Others
Involved in Your Healthcare: Unless you object, we may
disclose to a member of your family, a relative, a close friend
or any other person you identify, your protected health information
that directly relates to that person’s involvement in your health
care. If you are unable to agree or object to such a disclosure,
we may disclose such information as necessary if we determine that
it is in your best interest based on our professional judgment.
We may also use and disclose protected health information to notify
or assist in notifying a family member, personal representative
or any other person that is responsible for your care, your location,
or general condition. Finally, we may use or disclose your protected
health information to an authorized public or private entity to
assist in disaster relief efforts and to coordinate uses and disclosures
to family or other individuals involved in your health care.
Other
Permitted and Required Uses and Disclosures That May Be Made Without
Your Consent, Authorization or Opportunity to Object
We may use or disclose your protected health information in the
following situations without your consent or authorization. These
situations include:
Required
By Law: We may use or disclose your protected health information
to the extent that the use or disclosure is required by law. The
use or disclosure will be made in compliance with the law and will
be limited to the relevant requirements of the law. You will be
notified, as required by law, of any uses or disclosures.
Public
Health: We may disclose your protected health information
for public health activities to a public health authority that is
permitted by law to collect or receive the information. The disclosure
will be made for the purpose of controlling disease, injury or disability.
We may also disclose your protected health information, if directed
by the public health authority, to a foreign government agency that
is collaborating with the public health authority.
Communicable
Diseases: We may also disclose your protected health information,
if authorized by law, to a person who may have been exposed to a
communicable disease or may otherwise be at risk of contracting
or spreading the disease or condition.
Health
Oversight: We may disclose protected health information
to a health oversight agency for activities authorized by law, such
as audits, investigations, and inspections. Oversight agencies seeking
this information includes government agencies that oversee the health
care system, government benefit programs, other government regulatory
programs and civil rights laws.
Abuse
or Neglect: We may disclose your protected health information
to a public health authority that is authorized by law to receive
reports of child abuse or neglect. In addition, we may disclose
your protected health information if we believe that you have been
a victim of abuse, neglect, or domestic violence to the government
entity or agency authorized to receive such information. In this
case, the disclosure will be made consistent with the requirements
of applicable federal and state laws.
Legal
Proceedings: We may disclose protected health information
in the course of any judicial or administrative proceeding, in response
to an order of a court or administrative tribunal (to the extent
such disclosure is expressly authorized), in certain conditions
in response to a subpoena, discovery request or other lawful process.
Law
Enforcement: We may also disclose protected health information,
so long as applicable legal requirements are met, for law enforcement
purposes. These law enforcements purposes include (1) legal process
and otherwise required by law, (2) limited information requests
for identification and location purposes, (3) pertaining to victims
of crime, (4) suspicion that death has occurred as a result of criminal
activity, (5) in the event that a crime occurs on the premises of
the practice, and (6) medical emergency (not on the Practice’s premises)
and it is likely that a crime has occurred.
Workers’
Compensation: We may disclose your protected health information,
as authorized, to comply with workers’ compensation laws and other
similar legally-established programs.
Required
Uses and Disclosures: Under the law, we must make disclosures
to you and when required by the Secretary of the Department of Health
and Human Services to investigate or determine our compliance with
the requirements of Section 164.500 et. seq.
2. Your
Rights
Following is a statement of your rights with respect to your protected
health information and a brief description of how you may exercise
these rights.
You have the
right to inspect and copy your protected health information. This
means you may inspect and obtain a copy of protected health information
about you that is contained in a designated record set for as long
as we maintain the protected health information. A “designated record
set” contains medical and billing records and any other records
that your doctor and the practice uses for making decisions about
you.
Under federal
law, however, you may not inspect or copy the following records;
psychotherapy notes, information compiled in reasonable anticipation
of, or use in, a civil, criminal, or administrative action or proceeding,
and protected health information that is subject to law that prohibits
access to protected health information.
You have the
right to request a restriction of your protected health information.
This means you may ask us not to use or disclose any part of your
protected health information for the purposes of treatment, payment
or healthcare operations. You may also request that any part of
your protected health information not be disclosed to family members
or friends who may be involved in your care or for notification
purposes as described in this Notice of Privacy Practices. Your
request must be in writing and state the specific restriction requested
and to whom you want the restriction to apply.
Your provider
is not required to agree to a restriction that you may request.
If the provider believes it is in your best interests to permit
use and disclosure of your protected health information, your protected
health information will not be restricted. If your provider does
agree to the request restriction, we may not use or disclose your
protected health information in violation of that restriction unless
it is needed to provide emergency treatment. With this in mind,
please discuss any restriction you wish to request with your provider.
You may request
a restriction by presenting your request, in writing to the staff
member identified as “Privacy Officer” at the top of this form.
The Privacy Officer will provide you with “Restriction of Consent
to use and Disclosure of Protected Health Information” form. Complete
the form, sign it, and ask the staff to provide you with a photocopy
of your request initialed by them. This will serve as your receipt.
You have the
right to request confidential communications from us by alternative
means or at an alternative location. We will accommodate reasonable
requests. We may also condition this accommodation by asking for
you for information as to how payment will be handled or specification
of an alternative address or other method of contact. Please make
this request in writing using “Request for Confidential Communications
of Protected Health Information” available from the Privacy Officer.
You have the
right to have your doctor amend your protected health information.
This means you may request an amendment of protected health information
about you in a designated record set for as long as we maintain
this information. In certain cases, we may deny your request for
an amendment. If we deny your request for amendment, you have the
right to file a statement of disagreement with us and we may prepare
a rebuttal to your statement and will provide you with a copy of
such rebuttal. Please contact our Privacy Officer to determine if
you have questions about amending your medical records.
You have the
right to receive an accounting of certain disclosures we have made,
if any, of your protected health information. This right applies
to disclosures for purposes other than treatment, payment, or healthcare
operations as described in this Notice of Privacy Practices. It
excludes disclosures we may have made to you, for a facility directory,
to family members or friends involved in your care, pursuant to
a duly executed authorization or for notification purposes. You
have the right to receive specific information regarding these disclosures
that occurred after April 14, 2003. The right to receive this information
is subject to certain exceptions, restrictions, and limits. You
have the right to obtain a paper copy of this notice from us, upon
request, even if you have agreed to accept this notice electronically.
3.Complaints
You may complain to us, or the Secretary of Health and Human Services,
if you believe your privacy rights have been violated by us. You
may file a complaint with us by notifying our Privacy Officer of
your complaint. We will not retaliate against you for filing a complaint.
Our Privacy Officer is Amy Peabody. You may contact our Privacy
Officer, or any staff member, including your physician at 512-858-5677,
512-847-0668, or our website, which is www.hchealth.com for further
information about the complaint process.
This
notice was published and becomes effective on April 14, 2003.
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