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Student Medical & Counseling Clinic

HIPAA

Notice of Privacy Practices

THE STUDENT MEDICAL CLINIC (SMC) HAS ALWAYS COMPLETELY SAFEGUARDED THE PRIVACY OF YOUR PERSONAL HEALTH INFORMATION. EFFECTIVE APRIL 14, 2003, THE HEALTH INFORMATION PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA) REQUIRES THAT WE INFORM YOU WITH THIS WRITTEN NOTICE 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
Jackson Horsley, MD, Medical Director and Privacy Officer at:

Student Medical Clinic
400 E University Way
Ellensburg, WA 98926-7585
(509) 963-1874.
 

This Notice of Privacy Practices describes how we may use and disclose protected health information to carry out treatment, payment, or health care operations, or for the purposes that are permitted or required by law. It also describes your rights to access and control of your protected health information. “Protected health information” (PHI) includes information that we have created or received regarding your health. It includes your medical records and personal information such as your name, social security number, address, and phone number. We are required, under federal law, to protect the privacy of you PHI. All employees of the SMC are required to maintain confidentiality of PHI, receive appropriate privacy training, provide you with this Notice of Privacy Practice, and follow the practices and procedures set forth in the Notice.

I.USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

Uses and Disclosures of PHI based upon your written consent:  You will be asked to sign consent for release of information form to use and disclose your PHI for treatment, payment, and health care operations.

For Treatment: We may use health information about you to provide you with medical treatment or services. We may disclose health information about you to doctors, nurses, therapists, office staff, or personnel who are involved in taking care of you and your health. For example your provider may use your medical history to decide what treatment is best for you. He or she may also tell another practitioner about your condition in order to determine the most appropriate care for you.

For Payment:  Health information may be used and disclosed to bill Medicaid and the Take Charge program. Student medical and counseling charges are not involved in using or disclosing protected information in any way. Do not send your billing form along with your payment to the University cashier when paying your SMC bill on your student account. You may disclose information to your health insurance plan by sending them your billing statement for reimbursement purposes.

For Healthcare Operations:
The SMC may use or disclose your PHI to support quality assurance, accreditation, peer review, and risk management activities. These activities evaluate the performance of our staff to ensure that our patients receive quality care. Another activity would be the preceptoring of a provider in-training (e.g., physician assistant or nurse practitioner who may, with your oral consent, have access to PHI).
We may call you by name in the waiting room when it is time to see you. Our transcriptionist transcribes our records. All employees of the Student Medical & Counseling Clinic sign a binding confidentiality statement that prohibits release of PHI without your authorization.
Appointment Reminders: We may remind you by phone, voicemail, or in writing that you have a healthcare appointment with us, unless you specifically ask us not to do so.

II. SPECIAL SITUATIONS WHEN PROTECTED HEALTH INFORMATION MAY BE DISCLOSED WITH OR WITHOUT YOUR WRITTEN AUTHORIZATION OR CONSENT

Family and Friends: We may disclose PHI about you to your family members or friends if we obtain your verbal agreement to do so, of if we give you an opportunity to object to such a disclosure and you do not raise an objection. We may also disclose health information to your family or friends if we can infer from the circumstances that you would not object. For example, we may assume you agree to disclosure of PHI to your spouse or friend if they accompany you in the exam room during treatment. In a medical or treatment emergency we may determine that disclosing information to a close relative or friend, who brought you to the office, is in your best interests.

Health or Safety Threat: We may use or disclose PHI needed to prevent the spread of a communicable disease. Disclosure to a health department official for public health surveillance, investigation, and intervention is allowed. We may disclose PHI, in order to avert a serious threat, to Student Life/Student Affairs or the Director of the AUAP program (if you are an AUAP student) in a situation where your health or the health of others could be jeopardized.

Military, Veterans, National Security: We may be required by military command or other government authorities, including ROTC, to release to them health information about you. However, in most cases you will be informed of the request and be asked to authorize a release of information.

Lawsuits, Disputes, Law Enforcement: If you are involved in a lawsuit, dispute or suspected criminal activity we will comply with a court or administrative order, subpoena, warrant, or summons, subject to all applicable legal requirements, which may involve disclosing PHI.

Correctional Facilities: If you are an inmate in a correctional facility we may disclose your PHI to the correctional facility for certain purposes, such as providing health care to you, protecting your health and safety, or that of others.

Abuse or Neglect: We may provide protected health information to government entities authorized to receive reports regarding abuse, neglect, or domestic violence (i.e., posing a significant risk to safety).

Oversight Agencies: Under the law, we may make disclosures about you to health oversight agencies for certain activities such as audits, examinations, investigations, inspections, and licensures.

Communication Barriers: We will assume that you agree to PHI disclosure to an interpreter or other person who assists with a communication barrier and accompanies you into the examining room.

Coroners, Medical Examiners, Funeral Directors: We may release PHI to a coroner or medical examiner. This may be necessary, for example, to indentify a deceased person or determine the cause of death.

Workers’ Compensation: For services provided and according to state or federal law.

III. Other Uses and Disclosures of Health Information Made With Your Authorization
We will not disclose your health information for any purpose other than those identified in the previous sections without your specific, written authorization. An authorization differs from consent. Your consent gives us permission for treatment, billing, and healthcare operations as described above. An authorization is more detailed and specific, and gives permission for purposes other than treatment, billing and healthcare operations, and has an expiration date. If you give us authorization to use or disclose health information about you, you may revoke that authorization in writing at any time. If you do revoke it, we will not disclose further information but cannot take back any uses already made with your original permission.

IV. Your Rights: You have the right to authorize your PHI to be used in the following ways.

RIGHT TO INSPECT AND COPY:  You may inspect and obtain a copy of your PHI contained in your records.  We maintain medical records for up to 10 years.  In rare instances, your request could be denied (e.g., in certain civil, criminal proceedings or if subject to law).  A decision to deny access may be reviewable.

RIGHT TO AMEND:  If you believe health information we have about you is incorrect or incomplete, you may ask us to amend the information.  Your request should be in writing with the reason to support the request.  A request could be denied if it were judged to not be truthful.  In that case you may respond with a written statement of disagreement and ask that the statement be included with your PHI.

RIGHT TO REQUEST RESTRICTION OF DISCLOSURE:  We cannot release HIV, substance abuse, STD, or mental health information about you without a specific authorization.  You have the right to request a restriction or limitation on any PHI we use or disclose for treatment, payment or healthcare operations.  You have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for it (e.g., a relative or friend).  Your request must state the specific restriction requested and to whom you want the restriction to apply.

RIGHT TO REQUEST ALTERNATIVE COMMUNICATION REGARDING PROTECTED HEALTH INFORMATION: You may request that we communicate with you other than by phone, including a message to call back, or by letter.  You may choose an alternative method or a certain location.  The request must be written.  We will accommodate all reasonable requests.

RIGHT TO A LISTING OF DISCLOSURES:  You may request, in writing, any disclosures of PHI about you made after April 13, 2003 other than for treatment, billing, or healthcare operation purposes.

RIGHT TO A PAPER COPY OF THIS NOTICE:  This is your paper copy of the Notice.  The Notice is also posted on the CWU Student Medical Clinic website.

V.  COMPLAINTS
If you have any questions about this notice, or if you believe your privacy rights have been violated you may contact/file a complaint with the Clinic’s Privacy Officer - please contact Jackson Horsley, MD, Medical Director and Privacy Officer at the Student Medical Clinic, 400 E. University Way, Ellensburg, WA 98926 (509) 963-1874.  You have the right to file a complaint with the Secretary of Health and Human Services as well.   You will not be penalized for filing a complaint.

VI. CHANGES TO THIS NOTICE
We may change the terms of this Notice if clarifications or updates of the law are required.  The revised Notice would apply to all PHI that we maintain.  We would post the revised Notice at our clinic and on the CWU Student Medical Clinic website.  You may request a copy of any revised notice in effect at the time.

WHAT AM I BEING ASKED TO SIGN? Part of our legal responsibility under HIPAA is to ask for confirmation that you have received the Notice.  We must request confirmation by signature before or on the day you receive care from us.