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.
Grand River Hospital District (GRHD) is required by law to maintain the privacy of your health information and to provide you with notice of its legal duties and privacy practices with respect to your health information. If you have questions about any part of this notice or if you want more information about the privacy practices at GRHD please contact:
Compliance & Privacy Department
Peter McNally, Interim Compliance & Privacy Officer
I. How GRHD may Use or Disclose Your Health Information
GRHD collects health information from you and stores it in a chart and on a computer. This is your medical record. The medical record is the property of GRHD, but the information in the medical record belongs to you. The GRHD protects the privacy of your health information. The law permits GRHD to use or disclose your health information for the following purposes:
1. Treatment. We use medical information about you to provide your medical care. We disclose medical information to our employees and others who are involved in providing the care you need. For example, we may share your medical information with other physicians or other health care providers who will provide services that we do not provide. Or we may share this information with a pharmacist who needs it to dispense a prescription to you, or a laboratory that performs a test. We may also disclose medical information to members of your family or others who can help you when you are sick or injured.
2. Payment. We use and disclose medical information about you to obtain payment for the services we provide. For example, we give your health plan the information it requires before it will pay us. We may also disclose information to other health care providers to assist them in obtaining payment for services they have provided to you.
3. Regular Health Care Operations. We may use and disclose medical information about you to operate this hospital, primary care services or care center. For example, we may use and disclose this information to review and improve the quality of care we provide, or the competence and qualifications of our professional staff. Or we may use and disclose this information to get your health plan to authorize services or referrals. We may also use and disclose this information as necessary for medical reviews, legal services and audits, including fraud and abuse detection and compliance programs and business planning and management. We may also share your medical information with our “business associates”, such as a billing service, or a coding and auditing firms that perform administrative services for us. We have a written contract with each of these business associates that contains terms requiring them to protect the confidentiality of your medical information. We may also share your information with other health care providers, health care clearinghouses or health plans that have a relationship with you, when they request this information to help them with their quality assessment and improvement activities, their efforts to improve health or reduce health care costs, their review of competence, qualifications and performance of health care professionals, their training programs, their accreditation, certification or licensing activities, or their health care fraud and abuse detection and compliance efforts. GRHD participates in Quality Health Networks (QHN), a regional health information network. This is a centralized electronic database which contains personal health information from a variety of health care services providers including hospitals, physician offices, health insurances companies and pharmacies. All network members are subject to the HIPAA Privacy Laws. By participating in this network and additional centralized electronic databases GRHD intends to provide timely information to those health care and related service providers who may be involved in your care. You may opt out of this health information network by letting GRHD know during registration or contacting the Privacy Officer noted at the top of this notice.
Information provided to you.
4. Appointment Reminders. We may use and disclose medical information to contact and remind you about appointments. If you are not home, we may leave this information on your answering machine or in a message left with the person answering the phone.
5. Sign in sheet. We may use and disclose medical information about you by having you sign in when you arrive at our hospital, clinic or care center. The sign in sheet will contain only minimal information. We may also call out your name when we are ready to see you.
6. Directory. We may list your name, where you are located in our facilities, your general medical condition and your religious affiliation in our directory. This information may be provided to members of the clergy. This information, except your religious affiliation, may be provided to other people who ask for you by name. If you do not want us to list this information in our directory and provide it to clergy and others, you must tell us that you object.
7. Notification and communication with family. We may disclose your health information to notify or assist in notifying a family member, your personal representative or another person responsible for your care about your location, your general condition or in the event of your death. If you are able and available to agree or object, we will give you the opportunity to object prior to making this notification. If you are unable or unavailable to agree or object, our health professionals will use their best judgment in communication with your family and others. In the event of a disaster, we may disclose information to a relief organization so that they may coordinate these notification efforts.
8. Required by law. As required by law, we may use and disclose your health information, but we will limit our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse, neglect or domestic violence, or respond to judicial or administrative proceedings, or to law enforcement officials, we will further comply with the requirement set forth below concerning those activities.
9. Public health. As required by law, we may disclose your health information to public health authorities for purposes related to: preventing or controlling disease, injury or disability; reporting child abuse, elder or other abuse or neglect; reporting domestic violence; reporting to the Food and Drug Administration problems with products and reactions to medications; and reporting disease or infection exposure.
10. Health oversight activities. We may disclose your health information to health agencies during the course of audits, investigations, inspections, licensure and other proceedings.
11. Proof of Immunization. We will disclose proof of immunization to a school that is required to have it before admitting a student if you have agreed to the disclosure on behalf of yourself or your dependent.
12. Judicial and administrative proceedings. We may, and are sometimes required by law, to disclose your health information in the course of any administrative or judicial proceeding to the extent expressly authorized by a court or administrative order. We may also disclose information about you in response to a subpoena, discovery request or other lawful process if reasonable efforts have been made to notify you of the request and you have not objected, or if your objections have been resolved by a court or administrative order.
13. Law enforcement. We may disclose your health information to a law enforcement official for purposes such as identifying or locating a suspect, fugitive, material witness or missing person, complying with a court order or subpoena and other law enforcement purposes.
14. Deceased person information. We may disclose your health information to coroners, medical examiners and funeral directors.
15. Organ donation. We may disclose your health information to organizations involved in procuring, banking or transplanting organs and tissues.
16. Research. We may disclose your health information to researchers conducting research that has been approved by an Institutional Review Board or GRHD’s privacy committee.
17. Public safety. We may disclose your health information to appropriate persons in order to prevent or lessen a serious and imminent threat to the health or safety of a particular person or the general public.
18. Specialized government functions. We may disclose your health information for military, and national security purposes or to correctional institutions or law enforcement officers that have you have in their lawful custody.
19. Worker’s compensation. We may disclose your health information as necessary to comply with worker’s compensation laws
20. Breach Notification. In the case of a breach of unsecured protected health information, we will notify you as required by law. If you have provided us with a current email address, we may use email to communicate information related to the breach. In some circumstances our business associate may provide the notification. We may also provide notification by other methods as appropriate.
21. Marketing. Provided we do not receive any payment for making these communications, we may contact you to give you information about products or services related to your treatment, case management or care coordination, or to direct or recommend other treatments, therapies, health care providers or settings of care that may be of interest to you. We may similarly describe products or services provided by this practice and tell you which health plans this practice participates in. We may also encourage you to maintain a healthy lifestyle and get recommended tests, recommend that you participate in a disease management program, provide you with small gifts, tell you about government sponsored health programs or encourage you to purchase a product or service when we see you, for which we may be paid. Finally, we may receive compensation which covers our cost of reminding you to take and refill your medication, or otherwise communicate about a drug or biologic that is currently prescribed for you. We will not otherwise use or disclose your medical information for marketing purposes or accept any payment for other marketing communications without your prior written authorization. The authorization will disclose whether we receive any compensation for any marketing activity you authorize, and we will stop any future marketing activity to the extent you revoke that authorization.
22. Fundraising. We may contact you to participate in fund-raising activities for the GRHD. We may use or disclose your demographic information, the dates that you received treatment, the department of service, your treating physician, outcome information and health insurance status in order to contact you for our fundraising activities. You have the right to opt out of fundraising activities. If you do not want to receive these materials, notify the Privacy Officer listed at the top of this Notice of Privacy Practices and we will stop any further fundraising communications. Similarly, you should notify the Privacy Officer if you decide you want to start receiving these solicitations again.
23. Health plan. We may disclose your health information to the sponsor of your health plan.
24. Change of Ownership. In the event that the GRHD is sold or merged with another organization, your health information/record will become the property of the new owner.
25. Monitoring. For patient safety reasons patients may be monitored by camera equipment. There will be no recordings made.
II. When GRHD May Not Use or Disclose Your Health Information
Except as described in this Notice of Privacy Practices, the GRHD will not use or disclose your health information without your written authorization. If you do authorize the GRHD to use or disclose your health information for another purpose, you may revoke your authorization in writing at any time.
III. Your Health Information Rights
1. You have the right to request restrictions on certain uses and disclosures of your health information, by written request specifying what information you want to limit and what limitations on our use or disclosure of that information you wish to have imposed. If you tell us not to disclose information to your commercial health plan concerning your health care items or services for which you paid for in full out-of-pocket, we will abide by your request, unless we must disclose the information for treatment or legal reasons. We reserve the right to accept or reject any other request, and will notify you of our decision. The GRHD is not required to agree to the restriction that you requested.
2. You have the right to request that you receive your health information in a specific way or at a specific location. We will comply with all reasonable requests that are submitted in writing which specify how or where you wish to receive these communications.
3. You have the right to inspect and copy your health information with limited exceptions. We may charge a reasonable fee as established by state or federal law for copies. To access your medical information, you must submit a written request detailing what information you want to access, whether you want to inspect it or get a copy of it as well as your preferred format. We will provide copies in your requested preferred format if it is readily producible, or we will provide you with an alternative format you find acceptable. We may deny your request under limited circumstances and you have a right to appeal our decision. If your written request clearly, conspicuously and specifically asks us to send you or some other person or entity a copy of your medical record, and we do not deny the request, we will send a copy your health record as you requested, and will charge you no more than what it costs us to respond to your request. We may deny your request under limited circumstances where it is believed by allowing access would be reasonably likely to cause harm. You do have a right to appeal our decision. Examples where harm might be determined to occur are a minor’s records, records of an incapacitated adult or psychotherapy notes.
4. You have a right to request that the GRHD amend your health information that is incorrect or incomplete. The GRHD is not required to change your health information and will provide you with information about the GRHD’s denial and how you can disagree with the denial.
5. You have a right to receive an accounting of disclosures of your health information made by the GRHD, except that the GRHD does not have to account for the disclosures described in parts 1 (treatment), 2 (payment), 3 (health care operations), 4 (information provided to you), 6 (directory listings) and 17 (certain government functions) of section I of this Notice of Privacy Practices.
6. You have a right to a paper or electronic copy of this Notice of Privacy Practices. If you would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, contact the Privacy Office at 970-440-4133.
IV. Changes to this Notice of Privacy Practices
GRHD reserves the right to amend this Notice of Privacy Practices at any time in the future, and to make the new provisions effective for all information that it maintains, including information that was created or received prior to the date of such amendment. Until such amendment is made, the GRHD is required by law to comply with this Notice. Revised Notices will replace all existing Notices that are posted in the facilities, on our website, or available for electronic communication.
Complaints about this Notice of Privacy Practices or how the GRHD handles your health information should be directed to the Privacy Office at 970-440-4133.
If you are not satisfied with the manner in which this office handles a complaint, you may submit a formal complaint to:
Department of Health and Human Services
Office of Civil Rights
Hubert H. Humphrey Bldg.
200 Independence Avenue, S.W.
Room 509F HHH Building
Washington, DC 20201
You may also address your compliant to one of the regional Offices for Civil Rights. A list of these offices can be found online at :
https://www.hhs.gov/about/contact-us/index.html or you may also submit your complaint electronically by visiting http://www.hhs.gov/ocr/privacy/index.html
You will not be penalized for filing a complaint.