Privacy Practices

Notice of Privacy Practices

This notice describes how medical information about you may be used and disclosed by Whitemarsh House and how to get access to this information. Please review it carefully.

Our Duty is to Safeguard Your Protected Health Information
Individually identifiable information about your past, present or future health or condition, the provision health care to you or payment for health care is considered “Protected Health Information” (PHI).   We are required to extend certain protections to your PHI, and to provide this notice about our privacy practices that explains how, when and why we may use or disclose your PHI.  Except in specified circumstances, it is our practice to use or disclose only the minimum necessary PHI to accomplish the intended purpose of the use or disclosure.

While we are required to follow the privacy practices described in this notice, we reserve the right to change our privacy practices and the terms of this notice at any time.

How We May Use and Disclose Your Protected Health Information
Whitemarsh House may use and disclose Personal Health Information for a variety of reasons.   We have a limited right to use and/or disclose your PHI for purposes of treatment, payment and for our own health care operations. For uses beyond that, we must have your written authorization unless the law permits or requires us to make the use or disclosure without your authorization.   If we disclose your PHI to an outside entity in order to perform  a function  on our  behalf,  we  must  have  in  place an  agreement  !Tom the outside  entity  that  it will  extend  the same  degree  of  privacy protection  to your information  that we must apply to your PHI.   However,   the law provides that we are permitted to make some uses/disclosures without your consent or authorization.   The following describes and offers examples of our potential uses/disclosures of your PHI.

Generally, we may use or disclose your PHI as follows:

For Treatment: We may disclose your PHI to doctors, nurses, and other health care personnel who are involved in providing your health care. For example,  your  PHI  will be shared  among  members  of your  Whitemarsh  House  treatment  team.   Your  PHI may also  be shared  with outside entities  performing  ancillary  services  relating  to  your  treatment,  such  as  pharmacy  services,  lab  work  and  community  mental  health  providers involved in the provision or coordination  of your care.

To Obtain Payment:  We may use/disclose your PHI in order to bill and collect payment for your health care services.   For example, we may contact a member of your family, your attorney and/or banker, and/or your employer, and/or your case manager, and/or a third-party public or private insurance entity and release portions of your PHI to them to get paid for services that we have delivered to you.  We also may release information to the PA Department of Public Welfare for auditing and inspection purposes.

For Health Care Operations:  We may use/disclose your PHI in the course of operating under our licensure as a Personal Care Boarding home.   For example, we will take your photograph for medication  identification  purposes, use your PHI in evaluating  the quality of the services  we provide  and  disclose  your  PHI  to  our  fiscal  or  legal  staff  for  auditing  or  legal  purposes.    We will  contact  outside, contracted   providers  and use/disclose  your  PHI  to  inform  them  of specific  health  care  instructions  and  routines  you  may  require  including  appointment  reminders  and procedural  preparations.

Uses and Disclosures of Personal Health Information Requiring Authorization
For uses and disclosures beyond treatment, payment and operations purposes as described above, we are required to have your written authorization, unless the use or disclosure falls within one of the exceptions described below.

Your authorization can be revoked at any time to stop future use/disclosures except to the extent that we have already undertaken any previous action upon your authorization.

Uses and Disclosures of Personal Health Information Not Requiring Authorization
The law provides that we may use/disclose your PHI from mental health records without consent or authorization in the following instances and circumstances:

When Required By Law:   We may disclose  PHI when a law requires that we report information  about suspected  abuse, neglect or domestic violence,  or  relating  to suspected  criminal  activity  including  when  a  crime  has  been  committed  on  the  program  premises  or  against  program personnel or in response to a court order.  We may also disclose PHI to authorities that monitor compliance with these privacy practice requirements.

For Public Health & Safety Activities:  We may disclose PHI when we are required to collect information about disease or injury, or to report vital statistics to a public health authority. We also may disclose PHI as necessary to law enforcement personnel or other persons who can prevent or lessen the threat of immediate or future harm as when following county emergency preparedness protocols in response to a local or national disaster.   In order to avoid a serious threat to health or safety, we may disclose PHI to law enforcement when a threat is made to commit a crime on the program premises or against program personnel.

For  Oversight Activities:  We may disclose  PHI to the protection and advocacy agency, or any other agency responsible  for reporting or investigation  of unusual incidents and the monitoring of a Medicaid funded services program.

Uses and Disclosures Requiring You to Have an Opportunity to Object
In the following situations, we may disclose a limited amount of your PHI if we inform you about the disclosure in advance and you do not object, as long as the disclosure is not otherwise prohibited by law.

Resident Directory:  Your name and general disposition may be disclosed to callers or visitors who ask for you by name.  Additionally, your religious affiliation may be shared with clergy familiar to the Whitemarsh House community.

To Families, Friends and Others Involved in your Care: We may share with these people information directly related to their involvement in your care, or the payment of your care. We may also share PHI with these people to notify them about your location.

Your Rights Regarding Your Protected Health Information
You have the following rights relating to your Protected Health Information:

To Request Restrictions on Uses/Disclosures:  You have the right to ask that we limit how we 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/limitations that are required by law.

To Inspect and Request a Copy of Your PHI:   Unless your access to your records is restricted for clear and documented treatment reasons, you have a right to see your protected health information upon your written request.   We will respond to your request within 30 days.   If we deny you access, we will give you 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, depending upon your circumstances.  You have a right to choose which portions of your information you want copied and to have prior knowledge of the cost of copying.

To Request to Amended 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 1) correct and complete 2) not created by us and/or not part of our records or 3) 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 these changes.

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 treatment,  payment, and operations,  to you, your family, or Whitemarsh  House; or pursuant to your own written authorization.  The list also will not include any disclosures made for national security purposes, to law enforcement officials or correctional facilities, or disclosures made before April 2003. We will respond to your written request to receive such a list within 60 days of receiving your request.  There may be a charge for receiving your disclosure list if it occurs more frequently than annually.

How to File a Complaint
If you think  we may have violated  your  privacy  rights, or you disagree  with a decision  we have made about  access to your  PHI, you  may file a complaint  with the Whitemarsh  House  HIPAA Compliance  Officer, Glenn Makela. You may also file a complaint with the U.S. Secretary of Health and Human Services by calling 1-877-696-6775. No action will be taken against you if you make such a complaint.