Notice of Privacy Practices for Protected Health Information
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND RELEASED AND HOW TO GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Holy Spirit Health System (HSHS) includes the following companies: Holy Spirit Hospital of the Sisters of Christian Charity, Holy Spirit Ventures, Inc., Spirit Physician Services, Inc., and West Shore Advanced Life Support Services, Inc.
Who Will Follow This Notice:
This notice describes Holy Spirit Health System’s practices with respect to the privacy of protected health information maintained by HSHS. This notice applies to those with access to your HSHS record: The Medical Staff of the Hospital and any other health care professionals; all departments and units of Holy Spirit Health System; and all employees, staff, trainees, students, volunteers and contractors. All of Holy Spirit Health System's entities, sites and locations follow the terms of this notice. In addition, these entities, sites and locations may share protected health information with each other for treatment, payment, or health operations purposes described in this notice.
We understand that information about you and your health is personal and are committed to protecting health information about you. We create a record of the care and service you receive at Holy Spirit Health System and this is needed to provide you with quality care and to comply with certain legal requirements. This notice applies to the records of your care generated by any HSHS health care provider regardless of location (“protected health information”). This notice will tell you about the ways in which we may use and release protected health information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of protected health information.
We are required by law to:
- • Maintain the privacy of your protected health information.
- • Provide this Notice of our legal duties and privacy practices with respect to protected health information about you;
- • Follow the terms of the Notice that is currently in effect; and
- • Notify you if there is a breach of your unsecured protected health information
How Holy Spirit Health System May Use or Release Your Health Information:
Each time you receive healthcare services from a hospital, physician, or other healthcare provider, a record of your visit is made. Typically, this record may contain your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. The following categories describe different ways that we use and release health information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and release information will fall within one of the categories.
For Treatment: We may use your protected health information to provide you with medical treatment or services. We may release protected health information about you to doctors, nurses, technicians, medical, and other healthcare students, or other Holy Spirit Health System personnel who are involved in your care. For example, a doctor may need to tell a dietitian if you have diabetes to arrange for appropriate meals. HSHS is also required by law to protect the privacy of your protected health information more strictly if the services provided are related to any of the following: drug and alcohol abuse or dependence, mental health treatment or services, and HIV related information.
For Payment: We may use and release protected health information about you so the treatment and services you receive at Holy Spirit Health System may be billed and payment may be collected from you, an insurance company or another third party. For example, we may need to give your health insurer information about the surgery you received at the hospital so they will pay for the surgery. We may also tell your health insurer about a planned treatment to obtain prior approval or to determine whether your plan will cover the treatment. As a patient, you have the right to request restrictions on disclosure to your health plan of protected health information relating solely to health services or items for which you, or another individual other than the health plan, have paid for out-of-pocket in full.
For Health Care Operations: We may use and share your protected health information so that we, or others that have provided treatment to you, can better operate the office or facility. For example, we may use your protected health information to review the treatment and services we provided and to see how well our staff cared for you. We may share your protected health information with our researchers so they can develop plans to conduct research. We may share information with our students, trainees, and staff for review and learning purposes. We may use and release your protected health information so that Holy Spirit Health System can ensure that our patients receive quality care.
Business Associates: We may release protected health information to “business associates” who provide contracted services such as accounting, legal representation, claims processing, accreditation, information technology services and consulting. If we release health information to a business associate, we will do so subject to a contract that provides that the information will be used in a manner consistent with our privacy practices.
Treatment Alternatives: We may use and release protected health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefit and Services: We may use and release protected health information to tell you about health-related benefits or services that may be of interest to you.
Appointment Reminder: We may use and release protected health information to contact you as a reminder that you have an appointment for treatment or medical care at Holy Spirit.
HSHS Directory: We may include limited information about you in the hospital directory while you are a patient in the hospital. Directory information may include your name, location in the hospital, general condition, and religious affiliation. This information may be provided to members of the clergy and to other people who ask for you by name. You may request for us not to release any part or all of this directory information, and we will follow your instructions.
Communication with Family: Under certain circumstances, health professionals, using their best judgment, may release protected health information to a family member, other relative, close personal friend or any other person you identify, relevant to that person’s involvement in your care or payment related to your care.
Notification: We may use or release information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.
Research: Under certain circumstances, we may release information about you for research purposes. The use and release for research projects are subject to a special authorization process. This process evaluates a proposed research project and its use of health information, determining that your health information will be adequately protected. Before we use or release protected health information for research, the project will have been approved through this research process.
Fundraising Activities: We may use information about you in an effort to raise charitable contributions for Holy Spirit Health System. We may release information to the Office of Resource Development, which may contact you for the purpose of raising awareness about charitable programs and/or asking for donations or other considerations that benefit the Health System or any aspect of its operations. We would release information, such as your name, address, phone number, and the dates you received treatment or services from our providers. Any fundraising materials sent to you will include instructions on how to opt out of receiving further fundraising communications.
Funeral Directors/Coroners: We may release protected health information to funeral directors or coroners consistent with applicable law to carry out their duties. This may be necessary, for example, to indentify a deceased person, or determine the cause of death.
Food and Drug Administration (FDA): We may release to the FDA health information relative to adverse events with respect to food, supplements, product and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.
Workers Compensation:We may release protected health information about you for workers compensation or similar programs. These programs provide benefits for work-related illness or injuries.
Organ and Tissue Donation: If you are an organ donor, we may release health information to organizations that handle organ procurement or organ, eye, or tissue transplantation, or to an organ donation bank.
Military and Veterans: If you are a member of the armed forces, we may release protected health information about you as required by military command authorities. We may also release health information about foreign military personnel to the appropriate foreign military authority.
Public Health: As required by law, we may release protected health information to public health or legal authorities for activities such as: disease, injury, or disability prevention, recording births or deaths, prevention or control of disease, injury, or disability; notifying a person who may have been exposed to a disease or may be at risk for contaminating or spreading a disease or condition; to report child neglect, elderly abuse or domestic violence.
Health Oversight:We may release protected health information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
Correctional Institution: If you are or should become an inmate of a correctional institution, we may release protected health information to the institution, or agents thereof, health information necessary for healthcare, and the health and safety of other individuals. We may release protected health information about you to the correctional institution or law enforcement official.
Law Enforcement: We may release protected health information if asked to do so for a law enforcement official, in response to a court order, subpoena, summons, warrant, or any similar law enforcement process.
Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may release protected health information about you in response to a court, or administrative order. We may also release health information about you in response to a subpoena, a discovery request, or other lawful process by someone else involved in the dispute.
National Security and Intelligence Activities: We may release protected health information about you to authorized federal officials for intelligence, counterintelligence, and other security activities authorized by law.
Change of Ownership: In the event that Holy Spirit Health System is sold or merged with another organization, your protected health information/record will become the property of the new owner.
Your Health Information Rights:
Right to Inspect and Copy: You have the right to inspect and obtain a copy of your protected health information, except psychotherapy notes per Pennsylvania Regulations. You must submit your request in writing to Health Information Services, Holy Spirit Hospital, 503 North 21st Street, Camp Hill, PA 17011. In addition, an electronic copy of your health information held in a designated record set is available upon request. 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. We may deny your request to inspect and obtain a copy in certain limited circumstances. If you are denied access to your health information, you may request that the denial be reviewed. Another licensed healthcare professional chosen by Holy Spirit Health System will review your request and the denial. The person conducting the review will NOT be the person who denied your request.
Right to Amend: If you feel that your protected health information is incorrect or incomplete, you may ask us to amend the information. Your request must be made in writing and submitted to Health Information Services, Holy Spirit Hospital, 503 North 21st Street, Camp Hill, PA 17011. In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to add to or amend information that:
- • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
- • Is not part of the health information kept by or for Holy Spirit Health System;
- • Is not part of the information which you would be permitted to inspect and copy; or
- • Is accurate and complete.
If your request to amend your health information has been denied, you will be provided with an explanation of our denial reason(s) and information about how you can disagree with the denial.
Right to an Accounting of Disclosures: You have the right to request an “accounting of disclosures.” This is a list of disclosures of your protected health information that we made to organizations or persons outside of Holy Spirit Health System. To request an accounting of disclosures, you must submit your request in writing to the Compliance and Privacy Officer, Holy Spirit Health System, 503 North 21st Street, Camp Hill, PA 17011. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a 12-month period will be free. For additional lists, we may charge you a reasonable cost for assembling the list. 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.
Right to Request Restrictions: You have the right to request a restriction or limitation on the protected health information we use or release about you for treatment, payment, or health care operation. You also have the right to request a limit on the protected health information we release about you to someone who is involved in your care or the payment of your care, like a family member or friend. We are not required to agree to your request. Restriction requests must be made in writing to the Compliance and Privacy Officer, Holy Spirit Health System, 503 North 21st Street, Camp Hill, PA 17011. Your request must include: what information you want to limit; whether you want to restrict the use, disclosure or both; and to whom you want the restrictions to apply.
Right to Confidential Communications: You have the right to request that we communicate with you about health matters in certain way or at a certain location. To request confidential communications you must make your request in writing to the Compliance and Privacy Officer, Holy Spirit Health System, 503 North 21st Street, Camp Hill, PA 17011.We will not ask you the reason for your request and will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
Right to Receive a Copy of the Notice of Privacy Practices: You have the right to a paper copy of this Notice and may print a copy of this Notice at our website, www.hsh.org. If you want a paper copy of this Notice mailed to you or to exercise any of your rights outlined above, please send a written request to the Compliance and Privacy Officer, Holy Spirit Health System, 503 North 21st Street, Camp Hill, PA 17011.
Changes to this Notice: Holy Spirit Health System reserves the right to amend this Notice of Privacy Practices at any time in the future. Until such amendment is made, Holy Spirit Health System is required by law to comply with this Notice. Revisions to the Notice of Privacy Practices will be made available on the Internet at www.hsh.org. The Notice will contain the effective date on the first page.
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Complaints about this Notice of Privacy Practices or how Holy Spirit Health System handles your health information should be directed to:
Compliance and Privacy Officer
Holy Spirit Health System
503 North 21st Street
Camp Hill, PA 17011
You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights. There will be no retaliation for filing a complaint.
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Other Uses of Protected Health Information:
There are certain types of uses and disclosures of protected health information that require a patient’s authorization. These include most uses and disclosures of psychotherapy notes, uses and disclosures of protected health information for marketing purposes, and disclosures that constitute a sale of protected health information. Other uses and disclosures not described in this Notice will be made only with an individual’s authorization. If you provide us permission to use or release protected health information about you, you may revoke that permission in writing, at any time. You understand that we are unable to take back any disclosures we have already made with your permissions, and that we are required to retain our records of the care that we provided to you.
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Effective Date: 8/2013