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Privacy practices

Use and disclosures of your personal health information (PHI)

Your authorization and consent. Except as outlined below, we will not use or disclose your PHI for any purpose unless you have signed a form authorizing the use or disclosure. You have the right to revoke that authorization in writing unless we have taken any action in reliance on the consent or authorization.

Uses and disclosures for treatment. We will make uses and disclosures of your PHI as necessary for your treatment. For instance, doctors and nurses and other professionals involved in your care will use information in your medical record and information that you provide about your symptoms and reactions to plan a course of treatment for you that may include procedures, medications, tests, etc. We may also release your personal information to another healthcare facility or professional who is not affiliated with our organization but who is or will be providing treatment to you.

Uses and disclosures for payment. We will make uses and disclosures of your PHI as necessary for payment purposes. For instance, we may forward information regarding your medical procedures and treatment to your insurance company to arrange payment for the services provided to you, or we may use your information to prepare a bill to send to you or to the person responsible for your payment.

Uses and disclosures for healthcare operations. We will use and disclose your PHI as necessary, and as permitted by law, for our healthcare operations, which include clinical improvement, professional peer review, business management, accreditation and licensing, etc. For instance, we may use and disclose your PHI for purposes of improving the clinical treatment and care of our patients. We may also disclose your PHI to another healthcare facility, professional, or health plan for such things as quality assurance and case management, but only if they also have or had a patient relationship with you.

Our facility directory. We maintain a facility directory listing the name, room number, general condition and, if you wish, your religious affiliation. Unless you choose to have your information excluded from this directory, the information, excluding your religious affiliation, will be disclosed to anyone who requests it by asking for you by name. This information, including your religious affiliation, may also be provided to members of the clergy. You have the right during registration to have your information excluded from this directory and also to restrict what information is provided and/or to whom.

Family and friends involved in your care. With your approval, we may from time to time disclose your PHI to designated family, friends and others who are involved in your care or in payment of your care in order to facilitate that person’s involvement in caring for you or paying for your care. If you are unavailable, incapacitated or facing an emergency medical situation and we determine that a limited disclosure may be in your best interest, we may share limited PHI with such individuals without your approval. We may also disclose limited PHI to a public or private entity that is authorized to assist in disaster relief efforts in order for that entity to locate a family member or other persons that may be involved in some aspect of caring for you.

Business associates. Certain aspects and components of our services are performed through contracts with outside persons or organizations, such as auditing, accreditation, legal services, etc. At times it may be necessary for us to provide certain aspects of your PHI to one or more of these outside persons or organizations who assist us with our healthcare operations. In all cases, we require these business associates to appropriately safeguard the privacy of your information.

Fundraising. We may contact you to donate to a fundraising effort for or on our behalf. You have the right to opt out of receiving fundraising materials or communications and may do so by sending your name and address to the Privacy Officer, together with a statement that you do not wish to receive fundraising materials or communications from us.

Appointments and services. We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. You have the right to request—and we will accommodate reasonable requests by you—to receive communications regarding your PHI from us by alternative means or at alternative locations. For instance, if you wish appointment reminders to not be left on voicemail or sent to a particular address, we will accommodate reasonable requests. You may request such confidential communication in writing and may send your request to the Privacy Officer.

Research. In limited circumstances, we may use and disclose your PHI for research purposes. For example, a researcher may wish to compare outcomes of all patients that received a particular drug and will need to review a series of medical records. In all cases where your specific authorization is not obtained, your privacy will be protected by strict confidentiality requirements applied by an Institutional Review Board or privacy board, which oversees the research or by representations of the researchers that limit their use and disclosure of patient information.

Other uses and disclosures. We are permitted or required by law to make certain other uses and disclosures of your PHI without your consent or authorization.

  • We may release your PHI for any purpose required by law.
  • We may release your PHI for public health activities, such as required reporting of disease, injury, and birth and death, and for required public health investigations.
  • We may release your PHI as required by law if we suspect child abuse or neglect; we may also release your PHI as required by law if we believe you to be a victim of abuse, neglect or domestic violence.
  • We may release immunization records to a student's school but only if parents or guardians (or the student if not a minor) agree either orally or in writing.
  • We may release your PHI to the Food and Drug Administration if necessary to report adverse events and product defects or to participate in product recalls.
  • We may release your PHI to your employer when we have provided healthcare to you at the request of your employer; in most cases you will receive notice that information is disclosed to your employer.
  • We may release your PHI if required by law to a government oversight agency conducting audits, investigations, or civil or criminal proceedings.
  • We may release your PHI if required to do so by a court- or administrative-ordered subpoena or discovery request; in most cases you will have notice of such release.
  • We may release your PHI to law enforcement officials as required by law to report wounds and injuries and crimes.
  • We may release your PHI to coroners or funeral directors consistent with law.
  • We may release your PHI if necessary to arrange an organ or tissue donation from you or a transplant for you.
  • We may release your PHI if in limited instances if we suspect a serious threat to health or safety.
  • We may release your PHI if you are a member of the military as required by armed forces services; we may also release your personal health information if necessary for national security or intelligence activities.
  • We may release your PHI to workers' compensation agencies if necessary for your workers’ compensation benefit determination.

Ohio law requires that we obtain a consent from you in any instances before disclosing the performance or results of an HIV test or diagnoses of AIDS or an AIDS-related condition; before disclosing information about drug or alcohol treatment you have received in a drug or alcohol treatment program; and before disclosing information about mental health services you may have received.

Rights that you have

Access to your personal health information. You have the right to copy or inspect much of the PHI that we retain on your behalf. All requests for access must be made in writing and signed by you or your representative. We will charge you a nominal fee per page if you request a copy of the information. We will also charge you for postage if you request a mailed copy and will charge for preparing a summary of the requested information if you request such a summary. You may obtain an access request form from the Privacy Officer.

You have the right to obtain an electronic copy of your health information that exists in an electronic format, and you may direct that the copy be transmitted directly to an entity or person designated by you, provided that any such designation is clear, conspicuous, and specific with complete name, mailing address and other identifying information.

Amendments to your personal health information. You have the right to request in writing that PHI that we maintain about you be amended or corrected. We are not obligated to make all requested amendments but will give each request careful consideration. All amendment requests, in order to be considered by us, must be in writing, signed by you or your representative, and must state the reasons for the amendment or correction request. If an amendment or correction you request is made by us, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary. Please contact the Privacy Officer with any requests.

Accounting for disclosures of your personal health information. You have the right to receive an accounting of certain disclosures made by us of your PHI for six years prior to the date of your request. If you request an accounting of disclosures of your electronic health record, the accounting will be for three years prior to the date of the request for the accounting. For electronic records acquired by us as of Jan. 1, 2009, these requirements will apply to disclosures made by the organization from such a record on and after Jan. 1, 2014. All requests must be made in writing and signed by you or your representative. The first accounting in any 12-month period is free; you may be charged a nominal fee for each subsequent accounting you request within the same 12-month period. Please contact the Privacy Officer with any requests.

Restrictions on use and disclosure of your personal health information. You have the right to request restrictions on certain of our uses and disclosures of your personal health information for treatment, payment or healthcare operations on the consent form you sign when you become a patient. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate. Requested restrictions of disclosure of PHI to a health plan may be honored if disclosure is for purpose of payment and pertains solely to an item or service for which you have paid in full. We retain the right to terminate an agreed-to restriction if we believe such termination is appropriate. In the event of a termination by us, we will notify you of such termination. You also have the right to terminate, in writing or orally, any agreed-to restriction. Please contact the Privacy Officer with any requests.

Breach notification. In the unlikely event there is a breach, or unauthorized release of your PHI, you will receive notice and information on steps you may take to protect yourself from harm.

Complaints. If you believe your privacy rights have been violated, you can submit an oral or written complaint to the Berger Health System Patient Advocate or the Corporate Compliance Officer. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services in Washington D.C. in writing within 180 days of a violation of your rights. There will be no retaliation for filing a complaint.

Acknowledgment of receipt of notice. You will be asked to sign an acknowledgment form that you received this Notice of Privacy Practices.

For further information

If you have questions or need further assistance regarding this Notice, you may contact the Privacy Officer.

As a patient, you retain the right to obtain a paper copy of this Notice of Privacy Practices, even if you have requested such copy by email or other electronic means.

Effective date

This Notice of Privacy Practices is effective September 2013.

The terms of this Notice of Privacy Practices apply to Berger Health System operating as a clinically integrated healthcare arrangement composed of Berger Hospital employees, the physicians and other licensed professionals seeing and treating patients, Home Health and Hospice of Pickaway County, Pickaway Health Services, and Pickaway Medical Group, as well as members of this clinically integrated healthcare arrangement work and practice at Berger Hospital and its affiliated clinics. All of the entities and persons listed will share personal health information of patients as necessary to carry out treatment, payment, and healthcare operations as permitted by law.

We are required by law to maintain the privacy of our patients' PHI and to provide patients with notice of our legal duties and privacy practices with respect to your PHI. We are required to abide by the terms of this Notice so long as it remains in effect. We reserve the right to change the terms of this Notice of Privacy Practices as necessary and to make the new Notice effective for all PHImaintained by us. You may receive a copy of any revised notices at Berger Health System Medical Records Department, or a copy may be obtained by mailing a request to the Privacy Officer at the address listed below:

Privacy Officer
Berger Health System
600 N. Pickaway St.
Circleville, OH 43113

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