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Notice of Privacy Practices

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.

Interfaith Medical Center (IMC) values the privacy of each of its patients.  IMC is required by law to maintain the confidentiality of your protected health information (PHI). This Notice of Privacy Practices tells you how your PHI may be used and how IMC keeps your information private and confidential and applies whether you are a patient at the main hospital or any of the satellite clinic locations. This notice explains the legal duties and practices relating to your PHI.  As part of IMC's legal duties this Notice of Privacy Practices must be given to you.

IMC and its affiliated entities and subsidiaries are separate legal entities, including but not limited to the main hospital campus, the numerous outpatient clinics in the community, Interfaith Emergency Medicine, P.C., Interfaith Professional Physician Services, P.C., Smile Brooklyn Dental, P.C. and Interfaith Psychiatry Services, P.C. However, they are under common ownership and/or control, and thus have organized themselves as a single Affiliated Covered Entity (ACE) for the purposes of HIPAA compliance. This status permits IMC, its affiliated entities, and subsidiaries to maintain a single Notice of Privacy Practices. This Notice describes the health information practices of IMC and its related entities. All such entities, sites and locations will follow the terms of this Notice. In addition, these entities, sites and locations may share medical information with each other for treatment, payment and healthcare operations as described in this notice.

When we use the word “we,” we mean all the persons/entities covered by this Notice and noted above, including facilities (including outpatient clinics), medical professionals and other persons/companies who assist us with your treatment, payment or our business as a health care provider.


Each time you register at or are admitted to IMC for treatment or health care services as an inpatient or outpatient, we will make available copies of the current Notice of Privacy Practices.

IMC is required to abide by the Notice of Privacy Practices currently in effect.  IMC reserve the right to make changes to the Notice of Privacy Practices. Any revisions to our Notice of Privacy Practices will be posted on the IMC website at http://www.interfaithmedical.com and a copy may be obtained at any time upon request.

USES AND DISCLOSURES OF PHI

We may use and disclose your medical information in the ways described below.


Treatment: We may use medical information about you to provide you with medical treatment or services you require. We may disclose medical information about you to doctors, nurses, technicians, medical students, or other IMC personnel who are involved in taking care of you.  For example would be if your physician discloses your health information to another doctor for the purposes of a consultation. Different departments of IMC also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work, and x-rays.  We also may disclose medical information about you to people outside IMC who may be involved in your medical care. Also, we may contact you with appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.

Payment: We may use and disclose your health information for the purpose of allowing us, as well as other entities, to secure payment for the health care services provided to you. We may also tell your health plan about a treatment you are going to receive in order to obtain prior approval or to determine whether your plan will cover the treatment. We may also disclose information about you to other healthcare facilities for purposes of payment as permitted by law.

Health Care Operations: We may use and disclose your information for the purposes of our day-to-day operations and functions. For example, we may compile your health information, along with that of other patients, in order to allow us to review that information and make suggestions concerning how to improve the quality of care. We have agreed, to the extent permitted by law, to share your PHI among ourselves for purposes of treatment, payment or health care operations. This enables us to better address your health care needs.

Fundraising: In accordance with existing law, IMC may contact you as part of our efforts to raise funds for IMC.  You have the right to opt out of fundraising communications.  All such elections should be sent to the Privacy Officer at the address listed at the end of this Notice of Privacy Practices.

Inpatient Directory: We may include certain limited information about you in our directory while you are a patient at IMC, so that your family, friends and clergy can visit you and generally know how you are doing. This information may include your name and location within the facility, your religious designation, and information about your condition in general terms that will not communicate specific medical information about you.  Your religious affiliation may be shared with a clergy member, even if they don't ask for you by name.  Directory information, except for your religion, may be released to anyone who asks for you by name.  This is so your family, friends and clergy can know how you are doing.  If you do not want any information being given out, please let the admitting staff know of your wishes.

Individuals Involved in Your Care: We may release your medical information if you become incapacitated to the person you named in your Durable Power of Attorney for Health Care (if you have one), or otherwise to a friend or family member who is your personal representative (i.e., empowered under state or other law to make health-related decisions for you).  We may give information to someone who helps pay for your care.  In addition, we may disclose your medical information to an entity assisting in disaster relief efforts so that your family can be notified about your condition.  HIPAA also allows us at certain times to speak with those who are/were involved in your care/payment activities while being treated as patient and/or even after your death, if we reasonably infer based on our professional judgment that you would not object.  If you do not wish for us to speak with a particular person about your care, you should notify your nurse or care provider.  

Research.  We may use and disclose your medical information for research purposes.  Most research projects, however, are subject to a special approval process.  Most research projects require your permission if a researcher will be involved in your care or will have access to your name, address or other information that identifies you.  However, the law allows some research to be done using your medical information without requiring your written approval.

Required By Law.  We will disclose your medical information when federal, state or local law requires it.  For example, IMC and its personnel must comply with child and elder abuse reporting laws and laws requiring us to report certain diseases or injuries or deaths to state or federal agencies.

Serious Threat to Health or Safety.  We may use and disclose your medical information when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.

Organ and Tissue Donation.  If you are an organ donor, we may release your medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation or blood bank, as necessary to aid in its organ or tissue donation and transplantation process.

Military and Veterans.  If you are a member of the U.S. or foreign armed forces, we may release your medical information as required by military command authorities.

Workers’ Compensation.  We may release medical information about you for workers’ compensation or similar programs.  These programs provide benefits for work-related injuries or illness.

Minors.  If you are a minor (under 18 years old), IMC may release certain types of your medical information to your parent or guardian if such release is required or permitted by law.  

Public Health Risks.  We may disclose your medical information (and certain test results) for public health purposes, such as:

·         To a public health authority to prevent or control communicable diseases (including sexually transmitted diseases), injury or disability,

·         To report births and deaths,

·         To report child, elder or adult abuse, neglect or domestic violence,

·         To report to FDA or other authority reactions to medications or problems with products,

·         To notify people of recalls of products they may be using,

·         To notify a person who may have been exposed to a disease or may be at risk for getting or spreading a disease or condition,

·         To notify employer of work-related illness or injury (in certain cases),  and

·         To a school to disclose whether immunizations have been obtained.

Health Oversight Activities.  We may disclose your medical information to a federal or state agency for health oversight activities such as audits, investigations, inspections, and licensure of IMC and of the providers who treated you at IMC.  These activities are necessary for the government to monitor the health care system, government programs, and compliance with laws.

Lawsuits and Disputes.  We may disclose your medical information to respond to a court or governmental agency request, order or a search warrant.  We also may disclose your medical information in response to a subpoena, discovery request, or other lawful process by someone else involved in a dispute.

Law Enforcement.  Subject to certain conditions, we may disclose your medical information for a law enforcement purpose upon the request of a law enforcement official or to report suspicion of death resulting from criminal conduct or crime on our premises or for emergency or other purposes.

Medical Examiners and Funeral Directors.  We may disclose your medical information to a coroner or medical examiner or funeral director so they may carry out their duties.

National Security.  We may disclose your medical information to authorized federal officials for national security activities authorized by law.

Protective Services.  We may disclose your medical information to authorized federal officials so they may provide protection to the President of the United States and other persons.

Inmates.  If you are an inmate of a correctional institution or under the custody of a law enforcement officer, we may release your medical information to the correctional institution or a law enforcement officer.  This release would be necessary for IMC to provide you with health care, to protect your health and safety or the health and safety of others, or for the safety and security of the law enforcement officer or the correctional institution.

Business Associates.  Your medical or billing information could be disclosed to people or companies outside IMC who provide services to us. For example, we may use a billing agency to collect outstanding payments to IMC.  We make these companies sign special confidentiality agreements with us before giving them access to your information.  They are also subject to fines by the federal government if they use/disclosure your information in a way that is not allowed by law.

Exceptions: The following categories of information receive special protection under state law, and will be used and disclosed only as allowed by New York law:

·         HIV-related information;

·         Records of mental health treatment; and

·         Substance abuse records.

Authorization:  Other uses and disclosures of your PHI not covered by this Notice or the laws that apply to us will require your written authorization. This authorization will have an expiration date that can be revoked by you in writing. These uses and disclosures may be for marketing, fundraising and for research purposes. Certain uses and disclosure of psychotherapist notes will also require your written authorization.

INDIVIDUAL RIGHTS

You have the right to make certain requests of us related to your PHI. You have the right to:

Right to Access and Copy: You have the right to inspect and copy medical information that may be used to make decisions about your care. Usually, this includes medical and billing records. This right does not include information compiled for use in a legal proceeding and generally does not include psychotherapy notes.

In order to inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to IMC's Health Information Management Department. 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 copy in certain limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. A licensed healthcare professional will conduct the review. The reviewer will not be the person who denied your original request. We will comply with the outcome of the review.

You have a right to request that we provide you with an electronic copy of your medical record. IMC will try to provide the information in the format you request. However, if the format is not available, we are permitted to offer other electronic formats. If none for the offered formats are acceptable to you, IMC is permitted to provide you with a “hard copy”.

Right to Amend: If you think that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for IMC. To request an amendment, your request must be made in writing and submitted to IMC's Health Information Management Department. You must give 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 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 medical information kept by or for IMC;

·         is not part of the information that you would be permitted to inspect and copy; or

·         is accurate and complete.

We will provide you with written notice of action we take in response to your request for amendment.

Right to an Accounting of Disclosures: You have the right to request an "accounting of disclosures." This is a list of certain disclosures we made of medical information about you. If your PHI is disclosed through an electronic health record (EHR), we are required to provide you with an accounting, when requested, for up to three years prior to the request. Uses and disclosures of PHI through an electronic health record include treatment, payment and healthcare operations.

To request an accounting of disclosures, you must submit your request in writing to Health Information Management Department. Your request must state a time period. We will attempt to honor your request. If you request more than one accounting in any 12-month period, we may charge you for our reasonable retrieval, list preparation and mailing costs for the second and subsequent requests. We will notify you of the costs 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 make a written request to restrict or put a limitation on the medical information we use or disclose about you for treatment, payment or health care operations.  You also have the right to request a limit on your medical information that we disclose to someone involved in your care or the payment for your care, like a family member or friend.  If we agree to your request we will comply with your request unless the information is needed to provide you with emergency treatment.  We are generally not required to agree to your request, except as follows:

Payor Exception:  If otherwise allowed by law, we are required to agree to a requested restriction, if (1) the disclosure is to your health insurance plan for purposes of carrying out payment or health care operations and (2) the medical information to be restricted relates solely to a health care item or service for which all parties have been paid in full out of pocket.    NOTE:   During a single visit you may receive a bill for payment from multiple sources, including the laboratories, individual physicians who cared for you, specialists, radiologists, etc.   Therefore, if you wish to restrict a disclosure to your health insurance company from all these parties, you must contact each independent health care provider separately and you must submit payment in full to each individual provider. IMC expressly disclaims any responsibility or liability for independent medical staff acts or omissions relating to your HIPAA privacy rights.

If we do agree to a request for restriction, we will comply with your request unless the information is needed to provide you with emergency treatment or to make a disclosure that is required under law.  In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your adult children.  

Right to Request Confidential Communications: You have the right to receive confidential communications about your own health information by alternative means or at alternative locations. This means that you may, for example, designate that we contact you only via e-mail, or at work rather than home. To request communications via alternative means or at alternative locations, you must submit a written request to Health Information Management Department. All reasonable requests will be granted.

Breach Notification:  IMC is required by law to notify you of any breach of unsecured protected health information.

Right to a Paper Copy of This Notice: You have the right to a paper copy of this Notice at your first treatment encounter at IMC. You may get an additional copy of this Notice at any time by contacting the Admitting Department. You may also obtain a copy of this notice at our website, http://www.interfaithmedical.com.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with IMC. The complaint must be in writing, describing the acts or omissions that you believe violate your privacy rights. IMC will not retaliate against you for filing a complaint. All complaints must be submitted in writing to:

 

Privacy Officer
Attn: J. Kyri Isaac, Ph.D

Corporate Compliance
Interfaith Medical Center

1545 Atlantic Avenue
Brooklyn, New York 11213

718-613-4284 

 

You also may file a complaint with the Secretary of Health and Human Services in Washington, D.C. We will not retaliate or penalize you for filing a complaint the Secretary.  To file a complaint with the Secretary of Health and Human Services, write to: 200 Independence Ave., S.E., Washington, D.C. 20201.

Access/Amendments/Accounting & Disclosures: If you wish to request access to your records, an amendment of the records or accounting of disclosures please submit your request in writing to:

 

Health Information Management Department 

1545 Atlantic Avenue
Brooklyn, New York 11213

 

Original Effective Date: April 13, 2003
Last Revised Date: August 20, 2015