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HIPAA
Notice of Privacy Practices
THE STUDENT HEALTH CENTER (SHC) 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 Health Center 400 E University Way Ellensburg, WA 98926-7585 (509) 963-1874. This Notice of Privacy Practices describes how we may use and disclose our
protected health information to carry out treatment, payment, or health care
operations, or for other purposes that are permitted or required by law. It
also describes your rights to access and control 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 your
PHI. All employees of the SHC 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 a consent form to use and disclose you 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. Your Student Health and Counseling
fee is 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 SHC bill on your student account. You yourself may disclose
information to your health insurance plan by sending them your billing form for
re-imbursement purposes.
For Healthcare Operations: The SHC 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
student provider, e.g. physician assistant or nurse practitioner student 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 Health
and Counseling Center sign a binding confidentiality statement that prohibits
release of PHI without your authorization.
II. Special Situations When Protected Health Information May Be
Disclosed With or Without Your Written Authorization or Consent
Family and Friends: We may disclose health information about you to your
family members or friends if we obtain your verbal agreement to do so or 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 health information to
your spouse or friend if they accompany you in the exam room during treatment.
In a medical or treatment emergency situation, we may determine that disclosing
health information to a close relative or friend, whoever brought you to the
office, is in your best interest.
Health or Safety Threat: We may use or disclose PHI needed to
prevent spread of a communicable disease. Or we may use or disclose it to avert
a serious threat to your health or safety or the health and safety of the
public or another person. For example, we may share PHI with the Vice
President of Student Affairs and Enrollment Management or the director of
the AUAP program (if you are an AUAP student) in a situation where your
health or the health or others could be jeopardized. This is a part of the
Family Educational Rights and Privacy Act. This act covers communication
between the medical team, athletic directors and coaches regarding varsity
athletes.
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.
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.
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, 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 or 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
identify 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. You have the right to authorize your PHI to be used in the following
ways.
IV. Your Rights
Right To Inspect and Copy: You may inspect and obtain a copy
of protected health information about you that is 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. You may respond
in that case 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 also
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 Coy of This Notice: This is your paper copy of
the Notice. The Notice is also posted on the CWU SHCC website.
V. Complaints
If you think that your privacy rights have been violated you may file a complaint
with our Privacy Officer - Jackson Horsley, MD at the Student Health Center, 400 E. Unviersity
Way, Ellensburg, WA 98926-7585. 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 SHCC 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.
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