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CATHOLIC
SOCIAL SERVICES
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.
“Medical information”,
as used in the paragraph above, may not completely describe the type
of information Catholic Social Services may use and disclose. Information
about your past, present, or future health or condition, the provision
of health care or other services to you, or payment for services rendered,
if such information does or could be used to identify you, is considered
“Protected Health Information” (“PHI”) under the Federal Health
Insurance Portability and Accountability Act of 1996 (“HIPAA”) and
federal regulations issued thereunder (collectively, the “HIPAA Privacy
Rule”). Included in your PHI, for example, are your treatment or service
records, your name and address, and your insurance or other health benefit
information. This Notice describes potential uses and disclosures of
your PHI, as well as your rights with respect to your PHI.
- Our Duty to Safeguard
Your Protected Health Information.
Under the HIPAA Privacy
Rule, CATHOLIC SOCIAL SERVICES is required to extend certain protections
to your PHI, and to give you this notice about our privacy practices
that explains how, when and why we may use or disclose your PHI.
Except in specified circumstances, we must use or disclose only the
minimum PHI to accomplish the purpose of the use or disclosure.
We are required to
follow the privacy practices described in this notice, though we
reserve the right to change our privacy practices and the terms of this
Notice at any time. If we do so, we will post a new notice
at Catholic Social Services. You may request a copy of any new
notice by contacting the appropriate Privacy Officer at the sites
listed below:
Philadelphia County Senior Centers
– Kathleen Newman – 215-854-7087
Philadelphia County/Cardinal Bevilacqua
Center – Estella Reyes-Bugg –
- How We May Use
and Disclose Your Protected Health Information.
We use and disclose
PHI for a variety of reasons. For some uses and disclosures, we
must have your written authorization, for others, no authorization is
required. However, the law provides that we are permitted to make
some uses/disclosures without your written authorization. The
following offers more description and examples of our potential uses/disclosures
of your PHI.
- Uses and Disclosures
Relating to Service/Treatment, Payment, or Health Care Operations.
- For Services:
We may disclose your PHI to Catholic Social Services staff members,
volunteers, and other service delivery personnel who are involved in
providing your services. We may also disclose your PHI to other affiliated
facilities and service providers in order to ensure the provision of
additional or modified services to you.
- To obtain payment:
We may use/disclose your PHI in order to bill and collect payment for
your services. For example, we may release portions of your PHI
to Medicaid, a private insurance plan, or a state office to get paid
for services that we delivered to you.
- For service operations:
We may use/disclose your PHI in the course of operating Catholic Social
Services. For example, we may use your PHI in evaluating the quality
of services provided, or disclose your PHI to our accountant or attorney
for audit purposes. Since we are an integrated system, we may
disclose your PHI to designated staff in our central office for similar
administrative and operational purposes. Release of your PHI to
the county, state, and/or the Medicaid agency might also be necessary
to determine your eligibility for publicly funded services.
- Uses and Disclosures
Requiring Authorization:
For uses and disclosures beyond service/treatment, payment and operations
purposes we are required to have your written authorization, unless
the use or disclosure falls within one of the exceptions described below.
Should an authorization be required, you or your authorized representative
will be asked to sign the Catholic Social Services’ standard authorization
form. Once signed, authorizations can be revoked in writing at any time
to stop future uses/disclosures, except to the extent that we have already
undertaken an action in reliance upon your authorization.
- Uses and Disclosures
Not Requiring Authorization: The law provides that we may
use/disclose your PHI without a written authorization in the following
circumstances:
- When required
by law: We may disclose PHI when a law requires that we
report information about a suspected abuse, neglect or domestic violence,
or relating to suspected criminal activity, or in response to a court
order. We must also disclose PHI to authorities who monitor compliance
with these privacy requirements.
- For public
health activities: We may disclose PHI when we are required
to collect information about disease or injury, or to report vital statistics
to the public health authority.
- For health
oversight activities: We may disclose PHI to an accrediting
organization or another agency responsible for monitoring the health
care system for such purposes as reporting or investigation of unusual
incidents.
- Related to
decedents: we may disclose PHI relating to an individual’s
death to coroners, medical examiners or funeral directors, and to organ
procurement organizations relating to organ, eye or tissue donations
or transplants.
- To avert threat
to health or safety: In order to avoid a serious threat
to health or safety, we may disclose PHI as necessary to law enforcement
or other persons who can reasonably prevent or lessen the threat of
harm.
- For specific
government functions: We may disclose PHI of military
personnel and veterans in certain situations, to correctional facilities
in certain situations, to government programs relating to eligibility
and enrollment, and for national security reasons, such as protection
of the President.
- Uses and Disclosures
Requiring That You Have an Opportunity to Object:
In the following situations, we may disclose your PHI if we inform you
about the disclosure in advance and you do not object. However,
if there is an emergency situation and you cannot be given your opportunity
to object, disclosure may be made if it is consistent with any prior
expressed wishes and disclosure is determined to be in your best interests.
You must be informed and given an opportunity to object to further disclosure
as soon as you are able to do so.
- To families, friends,
or others involved in your care: We may share with these people
information directly related to your family’s, friend’s or other
person’s involvement in your care, or payment for your care.
We may also share PHI with these people to notify them about your location,
general condition, or death.
- To request restrictions
on uses/disclosures: You have the right to ask that we limit
how we use or disclose your PHI. We will consider your request,
but are not legally bound to agree to the restriction. To the
extent that we do agree to any restrictions on our use/disclosure of
your PHI, we will put the agreement in writing and abide by it except
in emergency situations. We cannot agree to limit uses/disclosures
that are required by law. To request a restriction, please contact the
appropriate Site Privacy Officer (see list above in Section II).
- To choose how
we contact you: You have the right to ask that we send you
information at an alternative address or by an alternative means.
We must agree to your request as long as it is reasonably easy for us
to do so. To request such a change, please contact the appropriate Site
Privacy Officer (see list above in Section II):
- To inspect and
copy your PHI: Unless your access is restricted for clear
and documented service/treatment reasons, or under applicable laws and
regulations, you have a right to see your protected health information
if you put your request in writing. We will respond to your request
within 30 days. If we deny your access, we will give written reasons
for the denial and explain any right to have the denial reviewed.
If you want copies of your PHI, a charge for copying may be imposed,
but may be waived, depending on your circumstances. You have a
right to choose what portions of your information you want copied and
to have prior information on the cost of copying. In order to request
access to your PHI, please contact the appropriate Site Privacy Officer
(see list above in Section II).
- To request amendment
of your PHI: If you believe that there is a mistake or missing
information in our record of your PHI, you may request, in writing,
that we correct or add to the record. We will respond within 60
days of receiving your request. We may deny the request if we
determine that the PHI is: (i) correct and complete; (ii) not created
by us and/or not part of our records, or; (iii) not permitted to be
disclosed. Any denial will state the reasons for denial and explain
your rights to have the request and denial, along with any statement
in response that you provide, appended to your PHI. If we approve
the request for amendment, we will change the PHI and so inform you,
and tell others that need to know about the change in the PHI. To request
an amendment, please contact the appropriate Site Privacy Officer (see
list above in Section II) for an amendment request form, and return
a competed form to that department.
- To find out what
disclosures have been made: You have a right to get a list
of when, to whom, for what purpose, and what content of your PHI has
been released other than instances of disclosure for which you gave
consent (i.e. for service/treatment, payment, operations, to you, your
family, or the Catholic Social Services directory). The list also
will not include any disclosures made for national security purposes,
to law enforcement officials or correctional facilities, or before April,
2003. We will respond to your written request for such a list
within 60 days of receiving it. Your request can relate to disclosures
going as far back as six years. There will be no charge for up
to one such list each year. There may be a charge for more frequent
requests. To request a listing of disclosures, please contact the appropriate
Site Privacy Officer (see list above in Section II) for a disclosure
request form, and return the completed form to that department.
- To receive this
notice: You have a right to receive a paper copy of this Notice
and/or an electronic copy by e-mail upon request. If you request
an electronic copy via e-mail, you must sign a consent form to allow
us to communicate with you in that manner.
- How to Make a
Complaint About a Violation of our Privacy Practices:
If you think we may
have violated your privacy rights, or you disagree with a decision we
made about access to your PHI, you may file a complaint with the person
listed in Section VI below. You also may file a written complaint
with the Office for Civil Rights of the Federal Department of Health
and Human Services. We will take no retaliatory action against
you if you make such complaints.
- Contact Person
for Information, or to Submit a Complaint:
If you have questions
about this Notice or any complaints about our privacy practices, please
contact the appropriate Site Privacy Officer (see list above in Section
II). You also may contact the Family Services Division Chief Privacy
Officer, James C. McMaster at 610-626-6550.
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