Patient Services - HIPAA Privacy Policies
Date of Last Revision and Effective Date April 14, 2003
THIS NOTICE OF PRIVACY PRACTICES (HEREINAFTER REFERRED TO
AS NOTICE) DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE
USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS
INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.
Cincinnati Eye Institute (CEI) is required by law to maintain the privacy of your
Protected Health Information (PHI) and to provide you with this Notice. This
Notice is being given to you to comply with the requirements of the privacy
rules issued under the Health Insurance Portability and Accountability Act of
1996 (HIPAA). This Notice applies to all of the records of your care generated
by CEI, whether made by CEI or an associated facility.
OUR COMMITMENT TO YOUR PRIVACY
CEI is committed to safeguarding the privacy of your medical information. As
our patient, CEI creates paper and electronic medical records about your
health, and the services and/or items we provide to you as our patient. We will
comply with all applicable federal and state laws regarding the privacy and
confidentiality of your medical information.
WHO SHOULD READ THIS NOTICE?
All patients of CEI should read this Notice.
WHOM DOES THIS NOTICE COVER?
The terms "we", "our" or "us" used in this Notice refer to CEI.
WHAT IS PROTECTED HEALTH INFORMATION?
Your Protected Health Information (PHI) is information which may identify you
and has to do with your past, present or future physical or mental health or
condition; the provision of health care to you; or the past, present, or future
payment for health care provided to you.
WHAT INFORMATION IS IN THIS NOTICE?
This Notice describes your rights regarding your PHI. It also describes how
we may use and disclose your PHI to carry out treatment, payment, health
care operations, and for other specified purposes that are permitted or
required by law. We are required to comply with the terms of this Notice. We
will not use or disclose your PHI without your written authorization, except as
described in this Notice.
WHAT RIGHTS DO YOU HAVE REGARDING YOUR PHI?
Right to Inspect and Copy your PHI. You have the right to inspect and
obtain a copy of your medical information that may be used to make decisions
about your care. This includes your medical and billing records but does not
include psychotherapy notes. Upon proof of an appropriate legal relationship,
records of others related to you or under your care (guardian or custodial) may
also be disclosed.
To inspect and obtain a copy of your medical record, you must submit your
request in writing to our Privacy Officer. Ask the front desk representative for
the name of the Privacy Officer. If you request a copy of the information, we
may charge a fee for the costs of copying, mailing or other supplies (tapes,
disks, etc.) associated with your request.
We may deny your request to inspect and obtain a copy in certain very limited
circumstances. If you are denied access to your medical information, you may
request that our QI/QA Committee review the denial. Another licensed health
care professional chosen by CEI will review your request and the denial. The
person conducting the review will not be the person who denied your request.
We will comply with the outcome and recommendations from that review.
Right to Amend your PHI. If you feel the medical information in your record
is incorrect or incomplete, then you may ask us to amend the information. You
have the right to request an amendment for as long as CEI maintains your
To request an amendment, you must submit your request in writing to our
Privacy Officer. This request must be signed, dated and should include your
intended amendment and a reason that supports your request to amend.
In certain cases, we may deny your request if you ask us to amend information
- was not created by us, unless the person or entity that created the
information is no longer available to make the amendment;
- is not part of your medical information kept by or for CEI;
- is not part of your medical information which you would be permitted to
inspect and copy; or
- is inaccurate and incomplete.
Right to an Accounting of Disclosures of your PHI. You have the right to
request an accounting of disclosures. This is a list of disclosures of your
medical information given to others for other than treatment, payment, or
health care operations.
To receive an accounting of disclosures of your PHI, you must submit your
request in writing. The date of your request must not be more than six years
prior and may not include dates before April 14, 2003. Your request should
indicate in what form you want the list (i.e., paper or electronically). We will
notify you of the cost involved and you may choose to withdraw or modify your
request at that time before any costs are incurred.
Right to Request Restrictions. You have the right to request a restriction or
limitation on the medical information we use or disclose about you for
treatment, payment or health care operations. You also have the right to
request a limit on the medical information we disclose about you to someone
who is involved in your care or the payment for your care such as a family
member or friend. For example, you may ask that we not use or disclose
information about a particular treatment you received.
We are not required to agree to your request and we may not be able to
comply with your request. If we do agree, we will comply with your request
except that we shall not comply, even with a written request, if the
information is exempt from the consent requirement or we are otherwise
required to disclose the information by law.
To request restrictions, you must make your request in writing. In your
request, please indicate:
- what information you want to limit;
- whether you want to limit our use, disclosure or both; and
- to whom you want the limits to apply (i.e., disclosures to your children,
parents, spouse, etc.)
Right to Request 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 may ask that we only contact
you at work or by mail and that we not leave voice mail or e-mail, or the like.
To request confidential communications, you must make your request in
writing. We will not ask you the reason for your request. We will
accommodate all reasonable requests. Your request must specify how or
where you wish us to contact you.
Right to a Paper Copy of This Notice. You have the right to a paper copy
of this Notice and may request one at any time.
HOW WE MAY USE OR DISCLOSE YOUR PHI
The following categories describe different ways that we use and disclose
PHI that we have and share with others including information concerning
HIV testing, diagnosis or treatment of AIDS, AIDS related conditions, drug
or alcohol abuse, drug related conditions, and/or psychiatric/psychological
diagnosis/treatment. Each category of uses or disclosures provides a
general explanation and provides some examples of uses. Not every use or
disclosure in a category is either listed or actually in place. The explanation
is provided for your general information only.
Medical Treatment. CEI uses your medical information previously given to
provide you with current or prospective medical treatment or services.
Therefore, CEI may disclose your medical information to doctors, nurses,
technicians, medical students, or any staff who are involved in your care.
For example, a doctor to whom CEI refers you for ongoing or further care
may need your medical record. Different areas of CEI including front desk,
administration, or the like, also may share your medical information
including your medical record, prescriptions, requests of lab work and
x-rays. We may also discuss your medical information with you to
recommend possible treatment options or alternatives. We also may
disclose your medical information to people outside CEI who may be
involved in your medical care after you leave CEI. This may include your
family members or other personal representatives authorized by you or by a
legal mandate (a guardian or other person who has been named to handle
your medical decisions, should you become incompetent).
Payment. CEI may use and disclose your medical information for services
and procedures so they may be billed and collected from you, an insurance
company, or any other third party. For example, we may need to give your
health care information about treatment you received at CEI to obtain payment
or reimbursement for the care. CEI may also tell your health plan and/or
referring physician about a treatment you are going to receive to obtain prior
approval or to determine whether your plan will cover the treatment, to
facilitate payment of a referring physician, or the like.
Health Care Operations. CEI may use and disclose your medical information
so we can run more efficiently and make certain all of our patients receive
quality care. These uses may include reviewing our treatment and services to
evaluate the performance of our staff, deciding what additional services to
offer and where, deciding what services are not needed, and whether certain
new treatments are effective. CEI may also disclose information to doctors,
nurses, technicians, medical students, and other personnel for review and
learning purposes. CEI may also combine the medical information we have
about you with medical information from other practices to compare how we
are doing and to see where we can make improvements in the care and
services we offer. CEI may remove information that identifies you from this set
of medical information so others may use it to study health care and health
CEI may also use or disclose information about you for internal or external
utilization review and/or quality assurance, to business associates for
purposes of helping us to comply with our legal requirements, to auditors to
verify our records, to billing companies to aid us in this process, and the like.
We shall endeavor, at all times when business associates are used, to advise
them of their continued obligation to maintain the privacy of your medical
Appointment and Patient Recall Reminders. CEI may ask that you sign in
at the front desk on the day of your appointment. CEI may use and disclose
your medical information to contact you as a reminder that you have an
appointment. This contact may be by phone, in writing, or via e-mail, and may
involve sending an e-mail or leaving a message on an answering machine
which could be received or intercepted by others.
Emergency Situations. CEI may disclose your medical information to an
organization assisting in a disaster relief effort or in an emergency situation so
your family can be notified about your condition, status and location.
Research. CEI may use and disclose your medical information for research
purposes regarding medications, efficiency of treatment protocols, and the like.
All research projects are subject to an approval process, which evaluates a
proposed research project and its use of medical information. Before we use
or disclose your medical information for research, the project will have been
approved. We will obtain an authorization from you before using or disclosing
your individually identifiable health information unless the authorization
requirement has been waived. If possible, CEI will make your medical
information non-identifiable. If the information has been sufficiently deidentified,
an authorization for the use or disclosure is not required.
Required By Law. CEI will disclose your medical information when required
to do so by federal, state or local law.
To Avert a Serious Threat to Health or Safety. CEI may use and disclose
your medical information when necessary to prevent a serious threat either to
your health and safety or the health and safety of the public or another person.
Any disclosure, however, would only be to someone able to help prevent the
Organ and Tissue Donation. If you are an organ donor, CEI may release
your medical information to organizations that handle organ procurement,
organ, eye or tissue transplantation, or an organ donation bank to facilitate
organ or tissue donation and transplantation.
Workers' Compensation. CEI may release your medical information for
workers' compensation or similar programs. These programs provide benefits
for work-related injuries or illness.
Public Health Risks. Law or public policy may require us to disclose your
medical information for public health activities such as:
- preventing or controlling disease, injury or disability;
- reporting births and deaths;
- reporting child abuse or neglect;
- reporting reactions to medications or problems with products;
- notifying people of recalls of products they may be using;
- notifying a person who may have been exposed to a disease or may be at
risk for contracting or spreading a disease or condition; and
- notifying the appropriate government authority if we believe a patient has
been the victim of abuse, neglect or domestic violence. We will only make
this disclosure if you agree or when required or authorized by law.
Investigation and Government Activities. CEI may disclose your medical
information to a local, state or federal agency for activities authorized by law.
These activities include audits, investigations, inspections, licensure, and the
like. These activities are necessary for the payor, the government and other
regulatory agencies to monitor the health care system, government programs,
and compliance with civil rights laws.
Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, CEI
may disclose your medical information in response to a court or administrative
order. CEI may also disclose your medical information in response to a
subpoena, discovery request, or other lawful process by someone else
involved in the dispute. CEI shall attempt in these cases to inform you about
the request so you may obtain an order to protect your medical information if
you so desire. We may also use such information to defend ourselves or staff
members of CEI in any actual or threatened action.
Law Enforcement. CEI may release your medical information if requested by
a law enforcement official:
- in response to a court order, subpoena, warrant, summons or similar
- to identify or locate a suspect, fugitive, material witness, or missing person;
- concerning the victim of a crime if, under certain limited circumstances, we
are unable to obtain the person's agreement;
- concerning a death we believe may be the result of criminal conduct;
- concerning criminal conduct at CEI; and
- in emergency circumstances to report a crime; the location of the crime or
victims; or the identity, description or location of the person who committed
Coroners, Medical Examiners and Funeral Directors. CEI may release
your medical information to a coroner or medical examiner. This may be
necessary to identify a deceased person or determine the cause of death.
CEI may also release your medical information to funeral directors as
necessary to carry out their duties.
Inmates. If you are an inmate of a correctional institution or under the
custody of a law enforcement official, CEI may release your medical
information to the correctional institution or law enforcement official. This
release would be necessary for the institution to provide you with health
care, to protect your health and safety or the health and safety of others or
for the safety and security of the correctional institution.
CHANGES TO THIS NOTICE
CEI reserves the right to change this Notice at any time. CEI also reserves
the right to make the revised Notice effective for medical information we
already have about you as well as any information we may receive from you
in the future. CEI will make available a copy of the current Notice. The
Notice will contain the date of the last revision and effective date on the first
page. In addition, each time you visit CEI for treatment or health care
services, you may request a copy of the current Notice in effect.
If you believe your privacy rights have been violated, you may file a
complaint with CEI. To file a complaint, please contact our Compliance
Officer, who will assist you. All complaints must be submitted in writing and
shall be investigated. You will not be penalized for filing a complaint.
OTHER USES OF MEDICAL INFORMATION
Other uses and disclosures of your medical information not covered by this
Notice or the laws that apply to CEI will be made only with your written
permission, unless those uses can be reasonably inferred from the intended
uses above. If you have provided us with permission to use or disclose your
medical information, you may revoke permission, in writing, at any time. If
you revoke your permission, CEI will no longer use or disclose your medical
information for the reasons covered by your written permission. You
understand that CEI is unable to take back any disclosures that have
already been made with your permission, and that CEI is required to retain
records of the care that we have provided to you.
Cincinnati Eye Institute
1945 CEI Drive
Cincinnati, Ohio 45242
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