Notice of Privacy Practices

Individually Identifiable Health Information and Your Health Records

When you receive health care services at Community Hospital of Ottawa (CHO), we write down information about the visit in your health care record. The information we write down may include, but is not limited to, the reason why you visited us, your diagnosis, physician examination reports, test results, charges related to services, and your discharge plan. Your name, age, and hospital numbers are attached to these records. This information is called individually identifiable health information (or health information).

We write this health information down for many reasons. These reasons include evaluating your care as well as your response to treatment over time, to enable our agency to comply with accreditation requirements, and to assess the services we provide.

Why We Give You This Notice and Ask You to Read It

This notice is provided to you as a requirement of the Health Insurance Portability and Accountability Act (HIPAA). It tells you about how CHO may use or disclose your individually identifiable health information, describes your rights regarding this information, and our obligations.

CHO is required by law to:

• Inform you of your rights regarding individually identifiable health information we have about you,
• Keep individually identifiable health information about you private,
• Give you this notice of our legal duties and privacy practices, and
• Follow the terms of the current notice.

Who will Follow this Notice

Community Hospital of Ottawa presents this Notice of Privacy Practices, as a joint notice, due to our designation as an organized health care arrangement. Because of this joint notice, your individually identifiable health information may be shared between your physician, hospital staff, trainees, and health science students in order to carry out treatment, payment, and health care operations. Our hospital volunteers may have limited access to your protected health information, so they may perform a service for our agency.

Your physician may have different procedures related to individually identifiable health information that is generated, used, or disclosed in his/her office.

Our Pledge Regarding Individually Identifiable Health Information

We understand health information about you is private and personal. CHO is committed to protecting this information. We educate staff who provide your care about the importance of the privacy and confidentiality of your health information. Procedures are in place to protect the information we maintain about you.

How Community Hospital of Ottawa May Use or Disclose Your Individually Identifiable Health Information

For Treatment, Payment, and Health Care Operations

There are different ways we may use or disclose your individually identifiable health information: for treatment, to receive payment for the services we provide, and to operate our hospital. For each category listed here, we will explain what we mean and give an example. Not every use or disclosure can be listed, but the ways we are permitted to use and disclose information will most likely fall within one of these categories.

For Treatment - We may use or disclose individually identifiable health information about you to provide, coordinate, or manage your health care. Different departments of the hospital may share information about you to coordinate the various services you need, like x-rays and lab work. If you are an inpatient and your physician prescribes Home Health Services for you, nurses who have cared for you during your inpatient stay will speak with Home Health staff so we can serve you better at home. We may also disclose information about you to people outside of CHO who may be involved in your medical care.

For Payment - We may use or disclose individually identifiable health information about you so the treatment you receive may be billed to and payment may be collected from you, an insurance company, or another third party. CHO may use or disclosure your health information for its own payment or for the payment activities of another health care provider, health plan, or health care clearinghouse. For example, we may send a bill to you or your insurance company. The information that accompanies this bill may include, but is not limited to, your name, account number, diagnosis and services provided to you. If applicable, we may disclose your individually identifiable health information to a collection agency.

For Health Care Operations - We may use or disclose your individually identifiable health information to operate this facility. For example, we may use your individually identifiable health information in a review of our treatment and services. Your health information may be disclosed to an accountant for financial purposes. We may call or send you a questionnaire to ask if your expectations were met regarding the service you received.

Uses or Disclosures CHO May Make Without Your Authorization

Hospital Directory and the Clergy (Inpatients).

We will ask you if you want your name and location at the hospital, in our hospital directory. If your name and room number ARE NOT included in this directory, persons who ask for you by name will be informed that, "We have no information." We will ask you if you want your name given to a member of the clergy. If we are not able to ask you these questions, CHO may use or disclose this information, consistent with your prior expressed preference, if known, and the health professional's judgment.

Communication with Family and Emergency Situations

We may provide individually identifiable health information to a family member, friend, or other person you identify who is involved in your health care or is helping you get payment for your healthcare, unless you object to the disclosure.

In an emergency or when you are not able to voice a preference regarding this type of use or disclosure, we may disclose individually identifiable health information if we determine it is in your best interest. We will tell you about this after the emergency has passed, and give you the opportunity to object to future disclosures to family and friends, if this is possible.

Notification Purposes and Disaster Relief

Unless you object, we may use or disclose your individually identifiable health information, for notification purposes. We may disclose this information, in a disaster situation, to an agency that assists in disaster relief so your family may be notified about your condition, status, and location.

Incidental Uses and Disclosures

The Privacy Rule allows us to use or disclose health information in situations that occur because of a permitted use or disclosure. For example, your physician may discuss your condition with you in a semi-private room or we may contact your pharmacy, if your physician prescribes a medication for you.

Information Disclosed to Business Associates

Some services we provide are through a contract with another person or agency.

These persons or agencies are referred to as our business associates. An example is an agency that helps us process payment for health care services. In this type of situation, we have a contract with the agency that does the service for us. To protect your health information, we require the business associate to safeguard this information.

Treatment Alternatives

We may contact you about treatment options, health related information, disease-management programs, or other programs our facility is participating in or offering.

Communication with You

We may contact you for scheduling purposes, appointment reminders, payment reasons, or other aspects of your care. Unless you tell us otherwise, we will leave a message on your answering machine or with someone who answers your phone, if you are not home.

Requirements of Laws or for the Good of the Public

In addition to treatment, payment, and health care operations, and unless a more stringent law applies, we may use or disclose your individually identifiable health information, to comply with Federal or State laws, to report information necessary for public health activities, for legal proceedings, and for law enforcement activities. These situations may include, but are not limited to, disclosures to:

• another acute care hospital, if you are transferred because of an emergency medical condition.
• a public health authority who is permitted by law to collect this information. This disclosure may be necessary for reasons including, but not limited to, the prevention or control of disease, injury, or disability; to report births and deaths; to report child abuse and neglect; to report reactions to medications or problems with products; or to notify people of product recalls.
• an organ or tissue procurement agency, in the event of a person's death, as necessary to facilitate organ or tissue donation and transplantation.
• a worker's compensation program to comply with law.
• a military command authority, for members of the armed forces.
• a law enforcement official, as required by law.
• a health care agent or next-of-kin. In the event a physician determines that a patient is not able to make decisions, we may contact a patient's health care agent. When no health care agent is available, an adult next-of-kin may be contacted to make decisions for the patient.
• a government health care oversight agency, in the event they request this information for the purpose of auditing or investigating our operations.
• comply with a court order or a valid subpoena.
• federal officials for the purpose of intelligence and national security activities, and for protective services for the President and others.
• avert a serious threat to public health and safety.

Situations That Require Your Written Authorization Due to Federal or State Law

Mental Health and Substance Abuse Treatment

If you are receiving treatment for a mental health disorder or a substance abuse disorder from our CHOICES Department, we will not disclose your individually identifiable health information to friends, family, or another health care agency without your written consent. However, in situations where you or other persons may be harmed because of your actions, your individually identifiable health information may be disclosed.

Other Situations

Other situations may require us to obtain your written consent prior to the use or disclosure of your health information.

Your Rights Regarding Individually Identifiable Health Information

You have the following rights regarding individually identifiable health information we maintain.

In certain situations, we may not be able to fulfill your request.

Right to Request Restrictions

You may ask us not to use or disclose any part of your individually identifiable health information for treatment, payment, or health care operations. Your request should include what information you want restricted; how you want to restrict use or disclosure, to whom the restriction applies, and an expiration date.

Right to Inspect and Copy

You generally have the right to inspect and copy individually identifiable health information that may be used to make decisions about your care. Usually this includes medical and billing records, but does not include psychotherapy notes.

Right to Amend

If you feel that individually identifiable health 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 the hospital.

Right to an Accounting of Disclosures

You have the right to request an "accounting of disclosures." This is a listing of certain health information disclosures we made. Your request should include a time period (up to six years) and a beginning date of no earlier than April 14, 2003.

Right to Receive Confidential Communications

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. We will not ask you the reason for your request. We will accommodate reasonable requests. Your request should specify how or where you wish to be contacted.

Other Uses or Disclosures

Other uses or disclosures of individually identifiable health information, not covered by this notice or the laws that apply to us, will only be made with your written permission. If you provide us permission to use or disclose individually identifiable health information about you, you may revoke that permission, in writing at any time. If you revoke your permission, we will no longer use or disclose individually identifiable health information about you for the reasons covered by your written request. Please understand that we are not able to take back disclosures we have already made with your permission.

Outpatients and Patients Who Have Been Discharged: If you wish to exercise these rights, please contact our Medical Records Correspondence Clerk at 815-431-5279 (Monday through Friday, 8 a.m. to 4:30 p.m.) or write to us at:

Inpatients: If you wish to exercise these rights, please notify your caregiver. He/she will assist you.

How to Obtain a Current Notice

We reserve the right to change this notice and make the revised notice effective for individually identifiable health information we already have about you as well as any information we receive in the future. The effective date of the notice is on the first page, in the top right hand corner.

At your first visit (on or after April 14, 2003) and upon subsequent visits (if our notice has been revised) we will offer you a copy of the current notice and ask you to acknowledge receipt of the notice. We will post a copy of the current notice on our hospital website, www.chottawa.org, and in registration areas of the hospital (i.e. Admitting, ER Registration, Rehabilitation Services, and CHOICES Outpatient Areas). A copy of the current notice may be obtained from these areas during business hours, Monday through Friday.

If you initially agree to receive the notice electronically, you may obtain a paper copy at any time. If we provide you with this notice electronically and the transmission fails, we will forward a written copy of the notice to you.

How to File a Complaint or Request More Information

If you believe your privacy rights have been violated, you may contact our Privacy Officer, or you may file a complaint with the Secretary of the Department of Health and Human Services. You will not be penalized or retaliated against for filing a complaint. You may also contact our Privacy Officer for more information regarding this notice, at the following address/phone number: