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1400 Medical Campus Drive, (231) 935-8000 (voice) HOURS OF OPERATION: We answer our phones from
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MUNSON FAMILY PRACTICE CENTER NOTICE OF PRIVACY PRACTICES Effective Date: 4/9/2003 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. Munson Family Practice Center ("MFPC")
is required by law to maintain the privacy of individually identifiable
patient health information (this information is "protected health
information" and is referred to herein as "PHI"). We
are also required to provide patients with a Notice of Privacy Practices
regarding PHI. We are required to post this Notice in a prominent place
within our facility. We will only use or disclose your PHI as permitted
or required by applicable state law. This Notice applies to your PHI
in our possession including the medical records generated by us. MFPC understands that your health information is
highly personal, and we are committed to safeguarding your privacy.
Please read this Notice of Privacy Practices thoroughly. It describes
how we will use and disclose your PHI. This Notice applies to the delivery of health care
by MFPC. This Notice also applies to the utilization review and quality
assessment activities of Munson Healthcare and MFPC as a member of Munson
Healthcare. I. Permitted Use or Disclosure A. Treatment: MFPC will use and disclose
your PHI in the provision and coordination of health care to carry out
treatment functions. Different departments will share medical information
about you in order to coordinate specific services, such as lab work,
x-rays and prescriptions. MFPC also will disclose your medical information to people or entities outside MFPC who will be involved in your medical care after you leave MFPC, such as other care providers who will provide services that are part of your care. We will share certain information such as your name,
address, employment, insurance carrier, emergency contact information
and appointment scheduling information in an effort to coordinate your
treatment with us and with other health care providers. MFPC will use and disclose your PHI to inform you
of, or recommend possible treatment options or alternatives that will
be of interest to you. MFPC will use and disclose PHI to contact you as
a reminder that you have an appointment for medical care at MFPC. If you are an inmate of a correctional institution
or under the custody of a law enforcement officer, MFPC will disclose
your PHI to the correctional institution or law enforcement official. B. Payment: MFPC will disclose PHI about
you for the purposes of determining coverage, eligibility, funding,
billing, claims management, medical data processing, stop loss/reinsurance
and reimbursement. The medical information will be disclosed to an
insurance company, third party payer, third party administrator, health
plan or other health care provider (or their duly authorized representatives)
involved in the payment of your medical bill and will include copies
or excerpts of your medical records which are necessary for payment
of your account. It will also include sharing the necessary information
to obtain pre-approval for payment for treatment from your health plan.
We will disclose PHI to collection agencies and
other subcontractors engaged in obtaining payment for care. C. Health Care Operations: MFPC will use
and disclose your PHI during routine health care operations including
quality review, utilization review, medical review, internal auditing,
accreditation, certification, licensing or credentialing activities
of MFPC, and for educational purposes. For instance, MFPC will need to share your demographic
information, diagnosis, treatment plan and health status for population
based activities relating to improving health or reducing health care
costs, protocol development, case management and care coordination,
and contacting health care providers and patients with information about
treatment alternatives, in order for us to operate our business in an
efficient, safe and legal manner. We may also use and disclose your PHI to support
the sale, transfer, or other corporate restructuring of Munson Healthcare's
assets. D. Other Uses and Disclosures: As part of
treatment, payment and health care operations, we may also use your
PHI for the following purposes: Medical Research: We may disclose your PHI
without your Authorization to medical researchers who request it for
approved medical research projects; however, with very limited exceptions
such disclosures must be cleared through a special approval process
before any PHI is disclosed to the researchers. Researchers will be
required to safeguard the PHI they receive. Information and Health Promotion Activities:
MFPC will use and disclose some of your PHI for certain health promotion
activities. For example, your name and address will be used to send
you newsletters or general communications. We will also send you information
based on your own health concerns. MFPC may send you this information
if it has determined that a product or service may help you. The communication
will explain how the product or service relates to your well-being and
can improve your health. E. More Stringent State and Federal Laws:
The State law of Michigan is more stringent than HIPAA in several areas.
State law is more stringent when the individual is entitled to greater
access to records than under HIPAA and when under state law the records
are more protected from disclosure than under HIPAA. Certain federal
laws also are more stringent than HIPAA. MFPC will continue to abide
by these more stringent state and federal laws. The federal laws include
applicable internet privacy laws, such as the Children's Online Privacy
Protection Act and the federal laws and regulations governing the confidentiality
of health information regarding substance abuse treatment. In Michigan patients have more rights of access
to behavioral health information under Michigan law than under HIPAA
and the state law defines a minimum necessary standard for release of
mental health information. Disclosure is permitted with consent and
for treatment without consent but only in an emergency. Minors in Michigan
have more rights to confidentiality and protection of certain information
(reproductive health, behavioral health and substance abuse) than under
HIPAA. State law requires facilities to adopt policies regarding release
of information outside the facility. If the facility policy requires
consent for release, then consent will be required. State law genetic
and HIV testing and disclosure consents remain in place. II. Permitted Use or Disclosure with an Opportunity
for You to Agree or Object A. Family/Friends: With your permission,
MFPC will disclose PHI about you to a friend or family member who is
involved in your medical care. We will also give information to someone
who helps you pay for your care. In addition, we will disclose PHI about
you to an agency assisting in a disaster relief effort so that your
family can be notified about your condition, status and location. You
have a right to request that your PHI not be shared with some or all
of your family or friends. B. Promotional Communications: MFPC does
not share or sell your PHI to companies that market health care products
or services directly to consumers for use by those companies to contact
you, such as drug companies. MFPC does maintain a database of individuals
for promotional communications, disease management, and health promotion
purposes. We send information to the individuals in this database about
the programs and services of MFPC. If you wish to be deleted from this
database, you may notify the Privacy Official of Munson Healthcare. III. Use or Disclosure Requiring Your Authorization A. Marketing: We are not permitted to provide
your PHI to any other person or company for marketing to you of any
products or services other than MFPC's products or services without
a signed authorization from you. B. Research: MFPC will use or disclose your
PHI as part of research that includes providing you with treatment.
For example, if you are part of a research study that includes treatment,
MFPC may require that you sign an authorization to allow the researchers
to use or disclose your PHI for this research. C. Other Uses: Any uses or disclosures that
are not for treatment, payment or operations and that are not permitted
or required for public policy purposes or by law will be made only with
your written authorization. Written authorizations will let you know
why we are using your PHI. You have the right to revoke an authorization
at any time, except to the extent that we have taken action in reliance
on the authorization. IV. Use or Disclosure Permitted by Public Policy
or Law without your Authorization A. Law Enforcement Purposes: MFPC will disclose
your PHI for law enforcement purposes as required by law, such as responding
to a court order or subpoena, identifying a criminal suspect or a missing
person, or providing information about a crime victim or possible criminal
conduct as part of a criminal investigation. Required by Law: MFPC will disclose PHI about
you when required by federal, state or local law to make reports or
other disclosures. MFPC also will make disclosures for judicial and
administrative proceedings such as lawsuits or other disputes in response
to a court order or subpoena. We will disclose your medical information
to government agencies concerning victims of abuse, neglect or domestic
violence. MFPC will report drug diversion and information related to
fraudulent prescription activity to law enforcement and regulatory agencies.
Specialized government functions will warrant the use and disclosure
of PHI. These government functions will include military and veteran's
activities, national security and intelligence activities, and protective
services for the President and others. MFPC will make certain disclosures
that are required in order to comply with workers' compensation or similar
programs. B. Health or Safety: Following the requirements
of the Michigan Department of Commerce, MFPC will use and disclose PHI
to avert a serious threat to health and safety of a person or the public.
We will use and disclose PHI to Public Health Agencies for immunizations,
communicable diseases, etc. MFPC will use and disclose PHI for activities
related to the quality, safety or effectiveness of FDA-regulated products
or activities, including collecting and reporting adverse events, tracking
and facilitating product recalls, etc. and post marketing surveillance.
Any patient receiving a medical device subject to FDA tracking requirements
may refuse to disclose, or refuse permission to disclose, their name,
address, telephone number and social security number, or other identifying
information for the purpose of tracking. V. Your Health Information Rights Although we must maintain all records concerning
your treatment by MFPC, you have the following rights concerning your
PHI: A. Right to Inspect and Copy: You have the
right to access your PHI and to inspect and have a copy made of your
PHI as long as we maintain it except for: psychotherapy notes, information
that may be used in anticipation of, or that will be used in a civil,
criminal or administrative action or proceeding, and where prohibited
or protected by law. We will deny your request for access to your PHI
without giving you an opportunity to review that decision if:
You agree to pay a reasonable copying charge. You
must make your requests to access and copy your PHI in writing to MFPC.
We will respond to your request within 30 days of its receipt. If we
cannot, we will notify you in writing to explain the delay and the date
by which we will act on your request. In any event, we will act on your
request within 60 days of its receipt. B. Right to Amend: You have the right to
amend your PHI for as long as we maintain it. However, we will deny
your request for amendment if:
If MFPC denies your request for changes in your
PHI, we will notify you in writing with the reason for the denial. We
will also inform you of your right to submit a written statement disagreeing
with the denial. You may ask that we include your request for amendment
and the denial any time that MFPC discloses the information that you
wanted changed. We may prepare a rebuttal to your statement of disagreement
and will provide you with a copy of that rebuttal. You must make your request for amendment of your
PHI in writing to MFPC, including your reason to support the requested
amendment. MFPC will respond to your request within 60 days of its receipt.
If we cannot, we will notify you in writing to explain the delay and
the date by which we will act on your request. In any event, we will
act on your request within 90 days of its receipt. C. Right to an Accounting: You have a right
to receive an accounting of the disclosures of your PHI that MFPC made,
except for the following disclosures:
For each disclosure, you will receive: the date
of the disclosure, the name of the receiving organization and address
if known, a brief description of the PHI disclosed and a brief statement
of the purpose of the disclosure or a copy of the written request for
the information, if there was one. You must make your request for an accounting of
disclosures of your PHI in writing to MFPC. You must include the time
period of the accounting, which may not be longer than 6 years. We will
respond to your request within 60 days from its receipt. If we cannot,
we will notify you in writing to explain the delay and the date by which
we will act on your request. In any event we will act on your request
within 90 days of its receipt. In any given 12-month period, we will provide you
with an accounting of the disclosures of your PHI at no charge. Any
additional requests for an accounting within that time period will be
subject to a reasonable fee for preparing the accounting. D. Right to Request Restrictions: You have
the right to request restrictions on certain uses and disclosures of
your PHI:
For example, you may ask that your name not be used
in the waiting room or that information about your condition not be
shared with your family. MFPC will consider your request but is not
required to agree to the requested restrictions. E. Right to Confidential Communications:
You have the right to receive confidential communications of your PHI
by alternative means or at alternative locations. For example, you may
request that we only contact you at work or by mail. We will make every
attempt to honor your request, but we reserve the right to deny unreasonable
requests. F. Right to Receive a Copy of this Notice:
You have the right to receive a paper copy of this Notice of Privacy
Practices, upon request. VI. Complaints If you believe your privacy rights have been violated,
you may file a complaint with Munson Healthcare or with the Secretary
of the Department of Health and Human Services. To file a complaint
with Munson Healthcare, please contact Munson Healthcare's Patient Liaison
at: 1105 6th Street All complaints must be submitted in writing directly
to Munson Healthcare's Patient Liaison. Munson Healthcare assures you
that there will be no retaliation for filing a complaint. VII. Sharing and joint use of your Health Information
In the course of providing care to you and in furtherance
of the Munson Healthcare's mission to improve the health of the community,
MFPC will share your PHI with other organizations as described below
who have agreed to abide by the terms described below: A. Business Associates: MFPC will use and
disclose your PHI to business associates contracted to perform business
functions on its behalf including Munson Healthcare, its parent who
performs certain business functions for MFPC. Whenever an arrangement
between MFPC and another company involves the use or disclosure of your
PHI, that business associate will be required to keep your information
confidential. B. Membership in Munson Healthcare: MFPC,
other members of Munson Healthcare and Munson Healthcare participate
together in an organized health care arrangement for utilization review
and quality assessment activities. We have agreed to abide by the terms
of this Notice with respect to PHI created or received as part of utilization
review and quality assessment activities of Munson Healthcare and its
members. Members of Munson Healthcare will abide by the terms of their
own Notice of Privacy Practices in using your PHI for treatment, payment
or healthcare operations. As a part of Munson Healthcare, MFPC and the
various hospitals, nursing homes, and health care providers in Munson
Healthcare share your PHI for utilization review and quality assessment
activities of Munson Healthcare, the parent company, and its members.
Members of Munson Healthcare also use your PHI for your treatment, payment
to MFPC and/or for the health care operations permitted by HIPAA with
respect to our mutual patients. VIII. Additional Information For further information regarding the subjects covered
in this Notice of Privacy Practices, please contact Munson Healthcare's
Privacy Official at IX. Changes to this Notice MFPC will abide by the terms of the Notice currently in effect. MFPC reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all PHI that it maintains. MFPC will provide you with the revised Notice at your first visit following the revision of the Notice.
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