INLAND MEDICAL & REHAB’S NOTICE OF PRIVACY PRACTICES


As Required by the Privacy Regulations Promulgated Pursuant to the Health Insurance Portability and Accountability Act of 1996 (HIPAA)

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO YOUR IDENTIFIABLE HEALTH INFORMATION.

PLEASE REVIEW THIS NOTICE CAREFULLY.



OUR COMMITMENT TO YOUR PRIVACY


Our organization is dedicated to maintaining the privacy of your identifiable health information.  In conducting our business, we will create records regarding you and the treatment and services we provide to you.  We are required by law to maintain the confidentiality of health information that identifies you.  We also are required by law to provide you with this notice of our legal duties and privacy practices concerning your identifiable health information.  By law, we must follow the terms of the notice of privacy practices that we have in effect at the time.

To summarize, this notice provides you with the following important information:
How we may use and disclose your identifiable health information
Your privacy rights in your identifiable health information<
Our obligations concerning the use and disclosure of your identifiable health information.

The terms of this notice apply to all records containing your identifiable health information that are created or retained by our practice.  We reserve the right to revise or amend our notice of privacy practices.  Any revision or amendment to this notice will be effective for all of your records our practice has created or maintained in the past, and for any of your records we may create or maintain in the future.  Our organization will post a copy of our current notice in our offices in a prominent location, and you may request a copy of our most current notice during any office visit.


IF YOU HAVE QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT:

Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385.



WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION IN THE FOLLOWING WAYS


The following categories describe the different ways in which we may use and disclose your identifiable health information.

1.  Assessment/Authorization/Treatment/Acquisition and Delivery of Equipment.  Our organization may use your identifiable health information to assess, secure authorization, treat, acquire or to supply equipment for you. Many of the people who work for our organization may use or disclose your identifiable health information in order to assess, receive authorization, treat, acquire or provide equipment for you, and/or to assist others in your care.  Additionally, we may disclose your identifiable health information to others who may assist in this care, such as your physician, therapists, long term care facilities, adult living homes, hospitals, discharge planners, care providers, case managers, spouse, children or parents.

2.  Payment.  Our organization may use and disclose your identifiable health information in order to secure pre-authorization for services, bill and/or collect payment for the services and/or items you may receive from us.  For example, we may contact your health insurer to certify that you are eligible for benefits (and for what range of benefits), and we may provide your insurer with details regarding your treatment, provide them your identifiable health information, and/or other pertinent information, to determine if your insurer will cover, or pay for, your medical equipment.  We also may use and disclose your identifiable health information to obtain payment from third parties that may be responsible for such costs, such as family members.  Also, we may use your identifiable health information to bill you directly for services and items. At the patient’s request, and with a signed waiver, Inland Medical & Rehab will not disclose PHI and the item(s) and/or services provided to a health plan for which the patient has paid out-of-pocket (cash) in full for item(s) and/or services that the patient requests a restriction, unless for treatment purposes or in the rare event the disclosure is required by law.

3.  Health Care Operations.  Our organization may use and disclose your identifiable health information to operate our business.  Examples of the ways in which we may use and disclose your information for our operations include, but are not limited to, our organization may use your health information to evaluate the quality of care you received from us, release your personal file and any other pertinent information to Joint Commission and/or its surveyors and/or other accrediting bodies for the purpose of having your file audited for quality assurance purposes, or to conduct cost-management and business planning activities for our practice. We will not disclose any psychotherapy notes, as we do not perform these types of services, and would not have record of them. If we did receive such records, then we would obtain written authorization prior to release.

4.  Appointment Reminders.  Our organization may use and disclose your identifiable health information to contact you and remind you of visits/deliveries.

5.    Health-Related Benefits and Services.  Our organization may use and disclose your identifiable health information to inform you of health-related benefits or services that may be of interest to you. Marketing Communications and Sale of your PHI is limited, and in some cases prohibited without your expressed written permission. Inland Medical & Rehab will abide by the rules therein, and would not market to you, or sell your information, except for reasons that are permissible within the law, unless we have your written permission. Inland Medical & Rehab does not do any type of fundraising, therefore, we would not contact you in regards to these events.

6.     Release of Information to Family/Friends.  Our organization may release your identifiable health information to a friend or family member that is helping you pay for your health care, or who assists in taking care of you. This includes making relevant disclosures to the deceased’s patient family and friends who, prior to the patient’s death, were involved in the care or payment for care provided to the person, unless doing so is inconsistent with any prior expressed preference of the decedent that is known to Inland Medical & Rehab.

7.  Disclosures Required By Law.  Our organization will use and disclose your identifiable health information when we are required to do so by federal, state or local law.



USE AND DISCLOSURE OF YOUR IDENTIFIABLE HEALTH INFORMATION IN CERTAIN SPECIAL CIRCUMSTANCES

The following categories describe unique scenarios in which we may use or disclose your identifiable health information:

1.  Public Health Risks.  Our organization may disclose your identifiable health information to public health authorities that are authorized by law to collect information for the purpose of:

Maintaining vital records, such as births and deaths
Reporting child abuse or neglect
Preventing or controlling disease, injury or disability
Notifying a person regarding potential exposure to a communicable disease
Notifying a person regarding a potential risk for spreading or contracting a disease or condition
Reporting problems with products or devices
Notifying individuals if a product or device they may be using has been recalled
Notifying appropriate government agency(ies) and authority(ies) regarding the potential abuse or neglect of an adult patient (including domestic violence); however, we will only disclose this information if the patient agrees or we are required or authorized by law to disclose this information
Notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance.

2. Health Oversight Activities.  Our organization may disclose your identifiable health information to a health oversight agency for activities authorized by law.  Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.

3.  Lawsuits and Similar Proceedings.  Our organization may use and disclose your identifiable health information in response to a court or administrative order, if you are involved in a lawsuit or similar proceeding.  We also may disclose your identifiable health information in response to a discovery request, subpoena, or other lawful process by another party involved in the dispute, but only if we have made an effort to inform you of the request or to obtain an order protecting the information the party has requested.  

4.  Law Enforcement.  We may release identifiable health information if asked to do so by a law enforcement official:
Regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement
Concerning a death we believe might have resulted from criminal conduct
Regarding criminal conduct at our offices
In response to a warrant, summons, court order, subpoena or similar legal process
To identify/locate a suspect, material witness, fugitive or missing person
In an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity or location of the perpetrator)

5. Serious Threats to Health or Safety.  Our organization may use and disclose your identifiable health information when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public.  Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.  

6. Military.  Our organization may disclose your identifiable health information if you are a member of U.S. or foreign military forces (including veterans) and if required by the appropriate military command authorities.

7. National Security.  Our organization may disclose your identifiable health information to federal officials for intelligence and national security activities authorized by law.  We also may disclose your identifiable health information to federal officials in order to protect the President, other officials or foreign heads of state, or to conduct investigations.  

8.  Inmates.  Our organization may disclose your identifiable health information to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official.  Disclosure for these purposes would be necessary: (a) for the institution to provide health care services to you, (b) for the safety and security of the institution, and/or (c) to protect your health and safety or the health and safety of other individuals.

9.  Workers’ Compensation.  Our organization may release your identifiable health information for workers’ compensation and similar programs.



YOUR RIGHTS REGARDING YOUR IDENTIFIABLE HEALTH INFORMATION



You have the following rights regarding the identifiable health information that we maintain about you:

1. Confidential Communications.  You have the right to request that our organization communicate with you about your health and related issues in a particular manner or at a certain location.  For instance, you may ask that we contact you at home, rather than work.  In order to request a type of confidential communication, you must make a written request after contacting Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385, specifying the requested method of contact, or the location where you wish to be contacted.  Our organization will accommodate reasonable requests.  You do not need to give a reason for your request.

2.  Requesting Restrictions.  You have the right to request a restriction in our use or disclosure of your identifiable health information for treatment, payment or health care operations.  Additionally, you have the right to request that we limit our disclosure of your identifiable health information to individuals involved in your care or the payment for your care, such as family members and friends.  We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat to you.  In order to request a restriction in our use or disclosure of your identifiable health information, you must make your request in writing, after contacting Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385.  Your request must describe in a clear and concise fashion: (a) the information you wish restricted; (b) whether you are requesting to limit our practice’s use, disclosure or both; and (c) to whom you want the limits to apply.

3.  Inspection and Copies.  You have the right to inspect and obtain a copy of the identifiable health information that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes.  You must submit your request in writing, after contacting Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385, in order to inspect and/or obtain a copy of your identifiable health information.  Our organization may charge a fee for the costs of copying, mailing, labor and supplies associated with your request.  We may deny your request to inspect and/or copy in certain limited circumstances; however, you may request a review of our denial.  Reviews will be conducted by a different person who gave the initial denial, chosen by our organization. Inland Medical & Rehab must provide access to your records in the electronic form and format requested by you, if the records are "readily reproducible" in that format. Otherwise, we must provide the records in another mutually agreeable electronic format.

4.  Amendment.  You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our organization.  To request an amendment, you must submit your request in writing, after contacting Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385.  You must provide us with a reason that supports your request for amendment.   Our organization will deny your request if you fail to submit your request (and the reason supporting your request) in writing.  Also, we may deny your request if you ask us to amend information that is: (a) accurate and complete; (b) not part of the identifiable health information kept by or for the organization; (c) not part of the identifiable health information which you would be permitted to inspect and copy; or (d) not created by our organization, unless the individual or entity that created the information is not available to amend the information.

5.  Accounting of Disclosures.  All of our patients have the right to request an “accounting of disclosures.”  An “accounting of disclosures” is a list of certain disclosures our organization has made of your identifiable health information.  In order to obtain an accounting of disclosures, you must submit your request in writing, after contacting Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385.  All requests for an “accounting of disclosures” must state a time period, which may not be longer than six years and may not include dates before April 14, 2003.  The first list you request within a 12-month period is free of charge, but our organization may charge you for additional lists within the same 12-month period.  Our organization will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.

6.  Right to a Paper Copy of This Notice.  You are entitled to receive a paper copy of our notice of privacy practices.  You may ask us to give you a copy of this notice at any time.  To obtain a paper copy of this notice, contact Don Whitney our Chief Compliance, Privacy & Security Officer at (509) 455-9385.

7.  Right to File a Complaint.  If you believe your privacy rights have been violated, you may file a complaint with our organization or with the Secretary of the Department of Health and Human Services.  To file a complaint with our organization contact Don Whitney our Chief Compliance, Privacy & Security Officer, at (509) 455-9385.  All complaints must be submitted in writing. You will not be penalized for filing a complaint.

8.  Right to Provide an Authorization for Other Uses and Disclosures.  Our organization will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law.  Any authorization you provide to us regarding the use and disclosure of your identifiable health information may be revoked at any time in writing. After you revoke your authorization, we will no longer use or disclose your identifiable health information for the reasons described in the authorization.

9. Breach Notification Requirements. We are required by law to notify you following a breach of unsecured PHI, unless, after completing a risk analysis applying specific factors, it is determined, that there is a "low probability of PHI compromise."

Please note: we are required to retain records of your care.

ALL WRITTEN CORRESPONDENCE SHOULD BE ADDRESSED AND SENT TO:

INLAND MEDICAL & REHAB
ATTN: DON WHITNEY, PRIVACY OFFICER
200 E. 2ND AVE, SUITE B
SPOKANE, WA 99202

Customers may direct questions regarding this policy to don@inlandmedicalrehab.com

Original January 2003
Updated September 13, 2013\r\n