SAINT ANTHONY'S HEALTH CENTER

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.

WE HAVE A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION (PHI).

We are legally required to protect the privacy of your health information pursuant to the privacy and security provisions of The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).  We call this information "Protected Health Information," or "PHI".  This is information that we've created or received about your past, present or future health or condition, the provision of health care to you, or the payment for health care services that can be used to identify you.  We must provide you with this Notice about our privacy practices that explains how, when, and why we use and disclose your PHI (“Notice of Privacy Practices” or “Notice”).  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 the terms of this Notice and our privacy practices and policies at any time.  Any changes will apply to the PHI we already have.  When we make an important change to our policies, we will promptly change our Notice and post it at designated locations within the Health Center.  You can also request a copy of this Notice from our Information Privacy Officer at 618/474-4854. A copy of the Notice can be viewed on our Web site atwww.sahc.org.

WHO WILL FOLLOW THIS NOTICE.

This Notice of Privacy Practices applies to the Health Center and its employees, volunteers, students and trainees. This Notice also applies to other health care and service providers that provide care and services for Health Center, or its patients, in that, as a condition to providing services at the Health Center, such providers must agree to comply with all Health Center policies, including policies relating to patient privacy. This Notice, however, only details the privacy policies of the Health Center and does not govern the independent practices or operations of health care and service providers, for services provided independent of the Health Center.

 HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION.

We use and disclose health information for many different reasons some which require your specific authorization and some which do not.  Below, we describe the different categories of our uses and disclosures which do not require your specific authorization and give you some examples of each category.

Uses and Disclosures Relating to Treatment, Payment, or Health Care Operations.  We may use and disclose your PHI for the following reasons:

 For treatment.  We may disclose your PHI to physicians, nurses, and other health care personnel who provide you with health care services or are involved in your care.  For example, if you're being treated for a knee injury, we may disclose your PHI to your attending physician and the Health Center’s physical rehabilitation department in order to coordinate your care. Additionally, if you are in need of emergency treatment, and/or you are unable to communicate with us (for example, if you are unconscious or in severe pain), we may disclose your medical information to someone responsible for or involved with your health care.

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 your health plan to receive payment for the health care services we provided to you.  We may also provide your PHI to our third-party business associates, such as billing companies, claims processing companies and others that process our health care claims.

For health care operations.  We may disclose your PHI in furtherance of the Health Center’s operations.  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 use PHI for the development of clinical guidelines, case management, care coordination, performance evaluation, training, and accreditation activities.   

Other Uses and Disclosures That Do Not Require Your Specific Authorization.  We may use and disclose your PHI without your specific authorization for the following reasons:

When a disclosure is required by federal, state or local law, judicial or administrative proceedings, or law enforcement.  We may use or disclose medical information about you as prescribed in an administrative or legal proceeding. For example, we make disclosures when a law requires that we report information 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.

For public health activities.  We may disclose medical information about you to agencies for the reporting of various events and when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. For example, we report 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.

For health oversight activities.  We may disclose PHI to a health oversight agency for activities authorized by state or federal law. For example, we will provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.

For purposes of organ donation.  By law we may notify organ procurement organizations and disclose PHI for their review.  Organ, eye or tissue donations and transplants are only performed with your consent.

For research purposes.  In certain circumstances, we may use or disclose PHI in order to conduct medical research. Any such disclosure would comply with all applicable state and federal law.

To avoid harm.  In order to avoid a serious threat to the health or safety of a person or the public, we may disclose PHI to law enforcement personnel or persons able to prevent or lessen such harm, as long as such disclosure is consistent with applicable federal and state law.

For specific government functions.  We may use or disclose PHI of military personnel and veterans in certain situations.  We may disclose PHI for national security purposes such as protecting the President of the United States or conducting intelligence operations.

For workers' compensation purposes.  We may use or disclose PHI in order to comply with workers' compensation laws.

Inmates. If you are an inmate of a correctional institution or under custody of a law enforcement official, we may disclose medical information about you to the correctional institution or law enforcement official in furtherance of providing health care services or safety.

Appointment reminders and health-related benefits or services.  We may use or disclose PHI to provide you with appointment reminders or to provide you with information about treatment alternatives or other health care services the Health Center offers.

Food and Drug Administration reporting. We may disclose your PHI to a person or organization required by the Food and Drug Administration to report adverse events, product defects or any other activity followed by the Food and Drug Administration.

Fundraising activities.   We may use certain 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 Saint Anthony's Foundation at (618) 474-6108.

We are Required to Give You the Opportunity to Object to the Following Uses and Disclosures:

Patient Directories.  We may include your name, location in this facility, general condition, and religious affiliation, in our patient directory for use by clergy and visitors who ask for you by name, unless you object in whole or in part.  The opportunity to consent may be obtained retroactively in emergency situations.

Disclosures to family, friends, or others.  We may provide your PHI to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object in whole or in part.  The opportunity to consent may be obtained retroactively in emergency situations.

INSTANCES WHEN A SPECIFIC AUTHORIZATION TO USE OR DISCLOSE PHI IS NECESSARY.

 All Other Uses and Disclosures Require Your Prior Written Authorization.  In any other situation not described in sections How We May Use and Disclose Your PHI above, we will ask for your written authorization.  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 (to the extent that we haven't taken any action relying on the authorization).

 WHAT RIGHTS YOU HAVE REGARDING YOUR PHI.

You have the following rights with respect to your PHI:

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.  We will consider your request but 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 limit the uses and disclosures that we are legally required or allowed to make.

The Right to Choose How We Send PHI to You.  You have the right to ask that we send information to you at an alternate address.  We must agree to your request so long as we can reasonably provide it in the format you requested.

The Right to See and Obtain Copies of Your PHI.   In most cases, you have the right to look at or obtain copies of your PHI for your personal use, however, you must make the request in writing.  If we don't have your PHI but we know who does, we will tell you how to obtain it.  In certain situations, we may deny your request.  If we do, we will tell you, in writing, our reasons for the denial and explain your right to have the denial reviewed.

If you request copies of your PHI, we will charge you according to the applicable Health Center policy, which will comply with federal and state law.  Instead of providing the PHI you requested, we may provide you with a summary or explanation of the PHI as long as you agree to that and to the cost in advance.

The Right to Obtain a List of the Disclosures We Have Made.  You have the right to get a list of instances in which we have disclosed your PHI.  The list will not include uses or disclosures that you have already consented to, such as those made for treatment, payment, or health care operations, directly to you, to your family, or in our facility directory.  The list also won't include uses and disclosures made for national security purposes, to corrections or law enforcement personnel, or any disclosures prior to April 14, 2003 or any other exception provided under HIPAA.

The list we will give you will include disclosures, designated by you on the request form.  Requests for disclosures made in the last six years only will be honored.  The list will include the date of the disclosure to whom PHI was disclosed (including their address, if known), and description of the information disclosed, and the reason for the disclosure.  We will provide the initial list to you at no charge, but if you make more than one request in the same year, we will charge you a fee for each additional request.

The Right to Correct or Update Your PHI.  If you believe there is a mistake in your PHI or a piece of important information is missing, you have the right to request that we correct the existing information or add the missing information.  You must provide the request and your reason for the request in writing.  We may deny your request in writing if the PHI is; (i) correct and complete, (ii) not created by us, (iii) not allowed to be disclosed, or (iv) not part of our records.  Our written denial will state the reasons for the denial and explain your right to file a written statement of disagreement with the denial.  If you don't file one, you have the right to request that your request and our denial be attached to all future disclosures of your PHI.  If we approve your request, we will change or amend your PHI, tell you that we have done it, and tell others that need to know about the change to your PHI.

The Right to Obtain a Copy of This Notice.  You have the right to obtain a paper copy of this Notice.  You also may obtain a copy of this at our web sitewww.sahc.org.

PERSON TO CONTACT FOR INFORMATION ABOUT THIS NOTICE.

If you have any questions about this Notice or our privacy practices, please contact:  Sister M. Nika Lee, FSGM, Information Privacy Officer, Phone Number:  618/474-4854.

COMPLAINTS.

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 complaint with Sister M. Nika as listed above.  You also may send a written complaint to the Secretary of the Department of Health and Human Services.  We will take no retaliatory action against you if you file a complaint about our privacy practices.   All complaints to the Health Center must be submitted in writing.

EFFECTIVE DATE OF THIS NOTICE.

This Notice went into effect on April 14, 2003.