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ST. JOSEPH'S HEALTH SYSTEM'S NOTICE OF PRIVACY PRACTICE

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.

St. Joseph' s Health System is legally required to protect the privacy of your health information. This information is called " protected health information" or " PHI" for short. PHI includes any information, whether verbal or recorded, that can be used to identify you, and that information:
a. is created or received by the Health System; AND
b. it relates to your past, present, or future physical or mental health or condition, the provision of health care to you, or the payment for such health care.

We must provide you with this notice about our privacy practices. This notice explains how, when, and why we use and disclose your PHI. With some exceptions, we may not use or disclose any more of your PHI than is necessary to accomplish the purpose of the use or disclosure. We are legally required to follow the privacy practices that are described in this notice.

We reserve the right to change this notice and our privacy practices at any time. Any changes will apply to the PHI we already have. Before we make an important change to our policies, we will promptly change this notice. Each time you register as an outpatient, an Emergency Department patient, or a Primary Care Office patient, or you are admitted to the Hospital for treatment or health care services, or you receive services from Creative Orthotics and Prosthetics, or receive medications or supplies from the Madison Avenue Pharmacy, a copy of the notice that is in effect at that time will be made available to you. In addition, you may request a copy of this notice by contacting the Hospital' s Privacy Officer at (607) 733-6541, extension 260 or Creative Orthotics and Prosthetics' Privacy Officer (607) 734-7215.

HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION
We use and disclose PHI for many different reasons. For some of these uses or disclosures, we need your prior, specific authorization (see Section C below). Below, we describe the different categories of our uses and disclosures and give you some examples of each category.
Section A. We may use and disclose your PHI for the following reasons:

1. FOR TREATMENT - We may disclose your PHI to physicians, nurses, medical students, and any other health care personnel who provide you with health care services or are involved in your care. For example, if you are being treated for a knee injury, we may disclose your PHI to the Physical Rehabilitation Department in order to coordinate your care. In addition, we may discuss your PHI with people outside of the Health System who may be involved in your medical care after you leave the Health System, such as family members, homecare providers, nursing home operators and others who provide services that are part of your care (see Section B, #2).

2. TO OBTAIN PAYMENT FOR TREATMENT - We may use and disclose your PHI in order to bill and collect payment for the treatment and services provided to you. For example, we may provide portions of your PHI to our Billing Department and to an insurance company or a third party to get paid for the health care services we provided to you. We may also provide your PHI to our business associates, such as billing companies, claims processing companies, and others that process our health care claims.

3. FOR HEALTH CARE OPERATIONS - We may disclose your PHI in order to operate the Health System. For example, we may use your PHI in order to evaluate the quality of health care services that you received or to evaluate the performance of the health care professionals who provided health care services to you. We may also provide your PHI to our accountants, attorneys, consultants, and others in order to make us sure we are complying with the laws that affect us.

4. WHEN A DISCLOSURE IS REQUIRED BY FEDERAL, STATE, OR LOCAL LAW, JUDICIAL OR ADMINISTRATIVE PROCEEDINGS, OR LAW ENFORCEMENT - We make, for example, disclosures when a law requires that we report PHI to government agencies and law enforcement personnel about victims of abuse, neglect, or domestic violence; when dealing with gunshot and other wounds; or when ordered in a judicial or administrative proceeding.

5. FOR PUBLIC HEALTH ACTIVITIES - We report, for example, information about births, deaths, and various diseases, to government officials in charge of collecting that information, and we provide coroners, medical examiners, and funeral directors necessary information relating to an individual's death.

6. FOR HEALTH OVERSIGHT ACTIVITIES - We will, for example, provide PHI to assist the government when it conducts an investigation or inspection of a health care provider or organization.

7. FOR PURPOSES OF ORGAN DONATION - We may notify organ procurement organizations to assist them in organ, eye, or tissue donation and transplants.

8. FOR RESEARCH PURPOSES - Under certain circumstances, we may use and disclose PHI for research purposes. For example, a research project may involve comparing the health and recovery of all individuals who received one medication to those who received another medication. All research projects, however, are subject to a special approval process. Before we use or disclose information for research, the project must be approved through this research approval process. We may, however, disclose PHI to people preparing to conduct a research project, to help them look for individuals with specific medical needs, as long as the PHI they review does not leave the Health System. We will almost always ask for your specific permission if the researcher will have access to your name, address, or other information that reveals who you are, or if the researcher will be involved in your care at the Health System.

9. TO AVOID HARM - In order to avoid a serious threat to the health or safety of a person or to the public, we may provide PHI to law enforcement personnel or persons able to prevent such harm.

10. FOR SPECIFIC GOVERNMENT FUNCTIONS - We may disclose PHI of military personnel and veterans in certain situations. In addition, we may disclose PHI for national security purposes, such as protecting the President of the United States or conducting intelligence operations.

11. FOR WORKER'S COMPENSATION PURPOSES - We may provide PHI in order to comply with Workers' Compensation Laws.

12. FOR APPOINTMENT REMINDERS AND HEALTH RELATED BENEFITS OR SERVICES - We may use PHI to provide appointment reminders or give you information about treatment alternatives, or other health care services or benefits we offer.

13. FOR FUNDRAISING ACTIVITIES - We may use PHI to raise funds for our organization. The money raised through these activities is used to expand and support the health care services and educational programs we provide to the community. If you do not wish to be contacted as part of our fundraising efforts, please contact the President of the Hospital's Foundation at (607) 737-7004 or Creative Orthotics and Prosthetics' Privacy Officer at(607)734-7215 (if you are receiving services from Creative Orthotics and Prosthetics).

14. FOR CARE PROVIDED TO INMATES - We may release PHI to the correctional institution or to law enforcement officials. This release would be necessary (a) for the Health System to provide you with health care; (b) to protect your health and safety or the health and safety of others; or (c) for the safety and security of the correctional institution.

Section B. You have the opportunity to object to uses and disclosures of PHI for the following purposes:

1. FOR HOSPITAL DIRECTORIES - St. Joseph' s Hospital directory reports may include your name, location in the Hospital, general condition, and religious affiliation, for use by visitors who ask for you by name, and for use by clergy, unless you object.

2. FOR DISCLOSURES TO FAMILY, FRIENDS, OR OTHERS - We may provide PHI to a family member, friend, or another person that you indicate is involved in your care or the payment for your health care, unless you object in whole or in part.

Section C. In any other situation not described above, we will ask for your written authorization before using or disclosing any of your PHI. If you choose to sign an authorization to disclose your PHI, you can later revoke that authorization in writing, to stop any future uses and disclosures for the reasons covered by the written authorization. Please, however, understand that we are unable to take back any disclosures we have already made before you revoked that authorization. In addition, if your authorization was obtained as a condition of obtaining insurance coverage, other law provides the insurer with the right to contest a claim under the policy or the policy itself.

WHAT RIGHTS YOU HAVE REGARDING YOUR PHI
You have the following rights with respect to your PHI:

1. THE RIGHT TO REQUEST LIMITS ON USES AND DISCLOSURES OF YOUR PHI - You have the right to ask that we limit how we use and disclose your PHI. To do so, you must make your request in writing to the Unit Director or Department Head of the area maintaining your PHI or to Creative Orthotics and Prosthetics' Privacy Officer (if you are receiving services from Creative Orthotics and Prosthetics). In that request, you must indicate:

a) what information you want to limit;
b) whether you want to limit our use, the disclosure of that PHI, or both; and
c) to whom you want the limits to apply (for example, disclosures to your spouse). We will consider your request, but we are not legally required to accept it. If we accept your request, we will put any limits in writing and abide by them except in emergency situations. You may not, however, limit the uses and disclosures that we are legally required or allowed to make.

2. THE RIGHT TO CHOOSE HOW WE SEND PHI TO YOU - You have the right to ask that we send PHI to you at an address other than your home address (for example, to your work address), or by a method other than regular mail (for example, through e-mail). Before we agree to your request, we must determine if we can easily provide the PHI in the method that you request.

3.THE RIGHT TO INSPECT AND RECEIVE COPIES OF YOUR PHI - You have the right to inspect and copy your PHI. Usually, this PHI includes medical and billing records. To inspect or receive copies of your PHI, you must submit your request in writing to the Director of Medical Records (for Hospital maintained PHI), to the director of the Madison Avenue Pharmacy (when you are receiving medications or supplies from that pharmacy) or to Creative Orthotics and Prosthetics' Privacy Officer (when you are receiving services from Creative Orthotics and Prosthetics). We will respond to your request within 10 days. If you request a copy of your PHI, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request. In some cases, rather than providing you with the PHI you requested, we may, instead, provide you with a summary or explanation of the PHI, as long as you agree to that and to any charge in advance. We may deny your request to inspect or copy your PHI in certain limited circumstances. If we do, we will tell you, in writing, our reason for the denial. If you are denied access to PHI, you may request that the denial be reviewed. Another licensed health care professional chosen by the Health System will review your request and the denial. The person conducting the review will not be the person who denied yourrequest. We will comply with the outcome of the review.

4. THE RIGHT TO AMEND OR UPDATE YOUR PHI - You may ask us to amend your PHI, if you feel that that PHI is incorrect or incomplete. You have the right to request an amendment for as long as the PHI is kept by or for the Health System. To request an amendment, you must submit your request in writing to the Director of Medical Records or the Director of Madison Avenue Pharmacy, or Creative Orthotics and Prosthetics' Privacy Officer, as stipulated previously. In addition, you must provide a reason that supports your request. We will respond to your request within 60 days. We may deny your request if you ask us to amend PHI that:

a) was not created by us, unless the person or entity that created the PHI is no longer available to make the amendment;
b) is not part of the PHI kept by or for the Health System;
c) is not part of the PHI which you would be permitted to inspect and copy; or
d) is accurate and complete.
Our written denial will state the reasons for the denial and will explain your right to file a written statement of disagreement regarding the denial.

5.THE RIGHT TO AN ACCOUNTING OF DISCLOSURES OF YOUR PHI - You have the right to request an "accounting of disclosures" . This is a list of the disclosures we made of your PHI. This list will not include disclosures made for treatment or payment or to conduct healthcare operations; disclosures made directly to you, to your family, or in our Hospital directory reports; disclosures made incident to a use or disclosure which is permitted by Federal Regulations; disclosures made pursuant to your authorization; disclosures to persons involved in your care; disclosures as part of a limited data set; disclosures made for national security purposes, or to corrections or law enforcement personnel, and; disclosures made prior to April 14, 2003. To request this "accounting of disclosures" list, you must submit your request in writing to the Director of Medical Records, to the Director of the Madison Avenue Pharmacy, or to Creative Orthotics and Prosthetics' Privacy Officer, as stipulated previously. We will respond to your request within 60 days. Your request must state a time period which may not be longer than six (6) years and may not include dates before April 14, 2003. Your request should indicate in what form you would like the list (for example, on paper, electronically). The list we provide to you will contain the date of the disclosure, to whom the PHI was disclosed (including their address, if known), a description of the information disclosed, and the reason for the disclosure. The first list you request within a 12 month period will be free. For additional lists, we may charge you for the costs of providing such 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.

HOW TO COMPLAIN ABOUT OUR PRIVACY PRACTICES
If you think that we may have violated your privacy rights, or you disagree with a decision we made about access to your PHI, you may file a written complaint and send it to the Hospital's Privacy Officer or to Creative Orthotics and Prosthetics' Privacy Officer (if your complaint is in regard to Creative Orthotics and Prosthetics), or to the Secretary of the Department of Health and Human Services. The Health System will take no retaliatory action against you if you file a complaint about our privacy practices.

WHO TO CONTACT REGARDING QUESTIONS ABOUT THIS NOTICE OR REGARDING HOW TO COMPLAIN ABOUT OUR PRIVACY PRACTICES
If you have any questions about this notice or any complaints about our privacy practices, or would like to know how to file a complaint with the Secretary of the Department of Health and Human Services, please contact the Hospital's Privacy Officer at (607) 733-6541, ext. 260 or Creative Orthotics and Prosthetics Privacy Officer at (607)734-7215 (when applicable).

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