DISTRICT HEALTH DEPARTMENT NO. 4
NOTICE OF PRIVACY PRACTICES REGARDING HEALTH INFORMATION
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.
Understanding Your Health Record/Information
This Notice of Privacy Practices is to provide you adequate notice of
your rights and, our legal duties and privacy practices with respect to
and disclosures of protected health
information. We will use or disclose protected health information in a
manner that is consistent with this notice.
It also describes your rights to access and control your Protected
Health Information (PHI). PHI is information about you, including
demographic information that may identify you and that relates to your
past, present or future physical or mental health or condition and
related health care services. Each time you visit a hospital, physician,
or other health care provider, a record of your visit is made.
Typically this record contains your symptoms, examination and test
results, diagnoses, treatment, assessments, physician orders,
medication lists, progress notes, and a plan for current and future
care or treatment. This information, often referred to as your health
or medical record, serves as:
- a basis for planning your care and treatment;
- a means of communication among the many health professionals who contribute to your care;
- a legal document describing the care you received;
- a source of data for medical research;
- a source of information for public health officials charged with improving the health of the nation;
- a source of data for facility planning and marketing; and,
tool which we can use to assess and improve the care we render and the
outcomes we achieve (adequacy and appropriateness of care).
Understanding what is in your record and how your health information is used helps you to:
We Have a Legal Duty to Protect Health Information About You
- ensure its accuracy;
- better understand who, what, when, where, and why others may access your health information; and,
- make more informed decisions when authorizing disclosure to others.
As required by law, we must maintain policies and procedures about our
work practices, including how we provide and coordinate care provided
our clients. These policies and procedures
include how we create, maintain and protect medical records; how we
govern access to medical information about our clients; how we maintain
the confidentiality of all PHI related to our clients, including
security of electronic files; and how we
educate staff on privacy of client information. We also must provide
you with notice of all legal duties and privacy practices concerning
Notices are posted in each office
in a prominent location and copies are available upon request at each
service delivery site for you to take with you. We will provide the
notice no later than the date of your first service delivery except in
the event of an emergency treatment situation, then as soon as
reasonably practicable after the emergency treatment situation. We
reserve the right to change our practices and the terms of this notice
and to make the new provisions effective for all PHI we maintain.
Should our information practices change, we will post a copy in each
office and have copies available upon request. We will not use or
disclose your health information without your authorization, except as
described in this notice. When another federal or state law governs the
use or disclosure of protected health information, then we will comply
with the law. Uses and Disclosures of Protected Health Information for Treatment, Payment and Health Operations
You will be asked to sign an acknowledgement, which indicates your
receipt of this Notice of Privacy Practices. Once signed, your PHI may
and disclosed by our staff and others
outside of our agency that are involved in your care and treatment for
the purpose of providing health care services to you. Your PHI may
also be used and disclosed to receive payment for your health care
service and support Agency operations. The following are examples of
uses and disclosures of your PHI that this Agency is permitted to make
with your acknowledgement of receipt of this
Notice. These examples are not meant to be exhaustive: We will use your Protected Health Information for treatment.
PHI will be used to provide, coordinate or manage health care and
related services, consultation between health care providers relating
to you or, referral for health care from one provider to another. For
example: We may fax your PHI to a physician or other health care
provider to whom you have been referred to ensure they have the
necessary information to diagnosis or treat you. We may provide your
physician or a subsequent health care provider (such as any hospital,
nursing home or other health care facility to which you may be
admitted) with copies of various reports, and documents while currently
providing service and/or after discharge from service that should
assist him or her in treating you. We may also disclose PHI to
individuals outside our Agency that may be involved in your medical
care after you are discharged from our service (such as family members,
clergy or others) to provide services that are part of your care. We will use your Protected Health Information for payment.
Your PHI will be used, as needed, to obtain payment for your health
care services. This includes billing and collecting for services
provided, determining plan eligibility and coverage, utilization review,
precertification and medical necessity review. For example:
Occasionally the insurance
requests a copy
of the medical record to be sent to them for review prior to paying the
bill. A bill may be sent to you, your insurance company or
third-party health plan, Medicare, Medicaid or any other person or
entity that may be responsible for paying or processing for payment any
portion of your bill for services. The information on or accompanying
the bill may include information that identifies you, as well as your
diagnosis, procedures, supplies, lab tests and results, medical history,
and/or other related information. We will use your Protected Health Information for regular healthcare operations.
Your PHI will be used for general Agency administrative and business
functions, quality assurance/improvement activities; medical review;
functions; developing clinical
guidelines; determining the competence or qualifications of health care
professionals; evaluating agency performance; conducting training
programs with students or new employees; licensing, survey,
certification, accreditation and credentialing activities; internal
auditing and certain fundraising and marketing activities. For example:
We may use PHI to review our treatment and services and to evaluate
the performance of our staff in caring for you. We may also combine PHI
about many clients to decide what additional services we should offer,
what services are not needed, and whether certain new treatments are
effective. We may also disclose information to doctors, nurses,
technicians, medical and nursing students, and other personnel for
review and learning purposes to help them practice or improve their
skills. We may also combine PHI we have with PHI from other health care
agencies to compare how we are doing and see where we can make
improvements in the care and services we offer. We may remove
information that identifies you from this set of PHI so others may use
it to study health care and health care delivery without learning who
the specific clients are. We may use and disclose PHI without your authorization or opportunity to object.
We may use and/or disclose PHI about you for a number or circumstances
in which you do not have to consent, give authorization or otherwise
have an opportunity to agree or object. Those circumstances include:
Public Health Activities: We may disclose information to state or
federal public health authorities, as required by law to: prevent or
may disclose information to state or federal public health
authorities, as required by law to: prevent or control disease, injury
or disability; vital events such as births and deaths; public health
surveillance; report child abuse or neglect; report reactions to
medications or problems with products; notify persons of recalls of
products they may be using; notify a person who may have been exposed
to a disease or may be at risk for contracting or spreading a disease
Abuse or Neglect: We may disclose your PHI to a public agency that is
authorized by law to receive reports of child abuse or neglect. In
may disclose your PHI to a public agency that is authorized by law to
receive reports of child abuse or neglect. In addition, if we believe
that you have been the victim of abuse, neglect or domestic violence we
may disclose your PHI to the governmental entity or agency authorized
to receive such information. In this case, the disclosure will only be
made if you agree or when required or authorized by law.
Food and Drug Administration: We may disclose your PHI to a person or
company required by the Food and Drug Administration to report adverse
may disclose your PHI to a person or company required by the Food and
Drug Administration to report adverse events, product defects or
problems, biologic product deviations, track FDA related products, to
enable product recalls, repairs or replacements, or to conduct post
marketing surveillance, as required.
Health Oversight: We may disclose your PHI to a health oversight
agency for activities authorized by law, such as audits, investigations,
may disclose your PHI to a health oversight agency for activities
authorized by law, such as audits, investigations, inspections,
licensure or disciplinary actions, civil, administrative, or criminal
proceedings or actions by a government health oversight agency to
monitor the health care system, government benefit programs, other
government regulatory programs and compliance with civil rights laws.
Judicial and Administrative Proceedings: We may disclose your PHI if
you are involved in a lawsuit or a dispute. This disclosure may be in
may disclose your PHI if you are involved in a lawsuit or a dispute.
This disclosure may be in response to an order of a court or
administrative tribunal, court ordered warrant, summons issued by a
judicial officer, or similar process, but only if efforts have been
made to notify you about the request or an order was obtained
protecting the information requested.
Law Enforcement: We may disclose your PHI, when applicable legal
requirements are met, for law enforcement purposes. These law
may disclose your PHI, when applicable legal requirements are met, for
law enforcement purposes. These law enforcement purposes include;
identification or location of a suspect, fugitive, or missing person,
pertaining to the victim of a crime, if under certain limited
circumstances, we are unable to obtain the persons agreement,
pertaining to a death we believe may be the result of criminal conduct,
in good faith, in the event or evidence of criminal conduct at our
location(s) and in emergency circumstances to report a crime, the
location of the crime or victim(s), or the identity, description or
location of the person who committed the crime.
Coroners, Funeral Directors and Organ Donation: We may disclose PHI to
a coroner or medical examiner for identification purposes, determining
may disclose PHI to a coroner or medical examiner for identification
purposes, determining cause of death or for the coroner or medical
examiner to perform other duties authorized by law. We may also
disclose PHI to a funeral director, as authorized by law, in order to
permit the funeral director to carry out their duties. We may disclose
such information in reasonable anticipation of death.
Cadaveric Organ, Eye or Tissue Donation: We may disclose your PHI to
communicate with organizations in procuring, banking or transplanting
may disclose your PHI to communicate with organizations in procuring,
banking or transplanting organs, eyes or tissue for the purposes of
facilitating donation and transplantation (if you are an organ donor).
Research: We may disclose your PHI under very select circumstances for
research. Before we disclose any of your PHI for such research
may disclose your PHI under very select circumstances for research.
Before we disclose any of your PHI for such research purposes, the
project will be subject to an extensive approval process including
protocols to ensure the privacy of your PHI.
To Avert a Serious Threat to Health and Safety: We may disclose your
PHI to prevent or lessen a serious and imminent threat to the health or
may disclose your PHI to prevent or lessen a serious and imminent
threat to the health or safety of a person or the general public, such
as when a person admits to participation in a violent crime or serious
harm to a victim or is an escaped convict. Any disclosure, however,
would only be to someone able to help prevent or lessen the threat.
For Specialized Government Functions: We may disclose your PHI when
appropriate conditions apply, for individuals involved in military and
may disclose your PHI when appropriate conditions apply, for
individuals involved in military and veterans' activities, national
security and intelligence activities, protective services for the
President and others and medical suitability determinations.
Workers' Compensation: We may disclose your PHI to the extent
authorized by and to the extent necessary to comply with laws relating
may disclose your PHI to the extent authorized by and to the extent
necessary to comply with laws relating to workers compensation or other
similar programs established by law.
Correctional Institutions and In Other Law Enforcement Custodial
Situations: Should you be an inmate of a correctional institution, we
you be an inmate of a correctional institution, we may disclose to
the institution or agents thereof PHI necessary for your health and the
safety of other individuals. You May Object to Certain Uses and Disclosures
We are permitted to use or disclose PHI about you without consent or
authorization provided you are informed in advance and given the
opportunity to agree to or prohibit or restrict the disclosure in the
may use and/or disclose your name, and your condition described in
general terms that does not communicate specific medical information in
our client listing or directory, to members of the clergy and with
people who ask for you by name. We also may share your
religious affiliation with clergy.
may use and/or disclose with a family member, relative, friend or other
person identified by you, PHI directly related to that person's
involvement in your care or payment for your care. We may share with a family member, personal representative or other person
responsible for your care, PHI necessary to notify such individuals of your location, general condition or death.
may use and/or disclose PHI with a public or private agency (for
example, American Red Cross) for disaster relief purposes. Even if
you object, we may still share the PHI about you, if necessary for the
emergency circumstances. If you are not present or able to agree or
object to the use or disclosure of your PHI, then your provider may,
using professional judgement, determine whether the disclosure is in
your best interest. In this case only the PHI that is relevant to your health care will be disclosed.
may use and/or disclose PHI to registries such as the Michigan
Childhood Immunization Registry (MCIR) when established protocols
ensure the privacy of your health information.
may use and/or disclose PHI to contact you to provide a reminder to you
about an appointment you have for treatment or medical care.
may use and/or disclose PHI to manage or coordinate your healthcare.
This may include telling you about treatments, services,
products and/or other healthcare providers. We may also use and/or
disclose PHI to give you gifts of a small value. For example: If you
are diagnosed with diabetes, we may tell you about nutritional and other counseling services that may be of interest to you.
may use and/or disclose PHI about you, including disclosure to a
foundation, to contact you to raise funds for the Agency and its
operations. We would only release contact information and the date you received treatment or services.
If you would like to object to our use or disclosure of PHI about you
in the above circumstances, please contact our Privacy Officer.
Your Health Information Rights
Although your health record is the physical property of the Agency
that compiled it, the information belongs to you. Following is a
statement of your
rights with respect to your PHI and a brief description of how you may exercise these rights.
You have the right to:
- Request restrictions on uses and disclosure of your protected health information.
may ask us not to use or disclose any part of your PHI for the purpose
of treatment, payment or health care operations. You may also request
that any part of your PHI not be disclosed to family members or friends
who may be involved in your care, the payment for your care or for
notification purposes as described in this notice. We are not required
to agree to any requested restriction you may request. If we believe it
is in your best interest to permit use and disclosure of your PHI, it
will not be restricted. If we do agree we will comply with your request
unless the information needed is to provide you emergency treatment.To
request restrictions, you must make your request in writing, utilizing
the DHD#4 form "Request to Restrict the Use and Disclosure of Protected
Health Information". These forms are available at any Health Department
office or through request of your provider. Your request must include:
what information you want to limit; whether you want to limit our use
or disclosure or both; and to whom you want the limits to apply. Either
you or we may terminate the restriction upon notification to the other.
- Receive confidential communications of protected health information and
request communications of your PHI by alternative means or at
alternative locations. We will attempt to honor reasonable requests for
confidential communication and will arrange for you to receive
protected health information by alternative means or at alternative
locations. Your request must be in writing utilizing DHD#4 form "Request
for Redirection of Confidential Communication". These forms are
available at any Health Department office or through request of your
provider. We do not require an explanation for the request as a
condition of providing communications on a confidential basis.
- Request to access your health record, you
may inspect and/or obtain a copy of PHI about you, that is contained
in a designated record set for as long as we maintain the PHI. A
"designated record set" contains medical and billing records and any
other records that we may use 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 PHI that is subject to law that prohibits access to
PHI. Depending on the circumstances, a decision to deny access may be
reviewable. In some circumstances, you may have a right to have this
decision reviewed.To inspect and copy medical information that may be
used to make decisions about you, you must submit your request in
writing utilizing DHD#4 form "Request to Inspect and/or Copy Protected
Health Information". These forms are available at any Health Department
office or through your provider. If you request a copy of the
information, we may charge a fee for the costs of copying, mailing or
other supplies associated with your request.If we deny access to your
PHI, you will receive a timely, written denial that explains the basis
for the denial, your review rights and an explanation of how to exercise
those rights. If we do not maintain the medical record, we will tell
you where to request the protected health information if known.
- Request to amend protected health information, for
as long as the PHI is maintained in the designated record set. A
request to amend your record must be in writing to our Privacy Officer,
utilizing DHD#4 form "Request to Amend Protected Health Information".
These forms are
at any Health Department office or through your provider. You must also
provide a reason that supports your request. In certain cases, we
may deny your request. If we deny your request, you have the right to
submit a written statement disagreeing with the denial with our Privacy
Officer and we may prepare a rebuttal to your statement and provide you
with a copy.
- Receive an accounting of disclosure of your protected health information. You
have the right to receive an accounting of certain disclosures we have
made, if any, of your PHI. This right applies to disclosures for
purposes other than treatment, payment or healthcare operation as
described in this notice. It excludes disclosures we may have made to
you, to family members or friends involved in your care, 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 limitations.To request this list of
accounting disclosures, you must submit your request in writing
utilizing DHD#4 form "Request Protected Health Information - Accounting
of Disclosure". These forms are available at any Health Department
office or through your provider. Your request must state a time period,
which may not be longer than six years and may not include dates before
April 14, 2003. If you request a list of disclosures more than once in
12 months, we may charge you a reasonable fee. We will notify you of
the cost involved and you may choose to withdraw or modify your request
at that time before any costs are incurred.
For More Information or to Report a Problem
- Revoke your authorization to use or disclose PHI except to the extent that action has already been taken.
- You have the right to obtain a paper copy of the notice upon
request. You may ask us to give you a paper copy of this notice
anytime even if you have agreed to receive this notice electronically.
If you have questions and would like additional information, you may
contact the Privacy Officer at 989-356-4507 or 1-800-221-0294.
If you believe your privacy rights have been violated, you may file a
complaint with the Privacy Officer or with the Secretary of Health and
Services. All complaints must be in
writing. Health and Human Services can be contacted toll free at
1-877-696-6775 or by e-mail athttp://www.hhs.gov/contacts/. There will be no retaliation for filing a complaint.
There will be no retaliation for filing a complaint.
This notice is effective April 14, 2003. We are required to abide by
the terms of this notice currently in effect, but we reserve the right
are required to abide by the terms of this notice currently in effect,
but we reserve the right to change these terms as necessary for all
PHI that we maintain.