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Notice of Privacy Practices

This notice describes how medical / protected health information about you may be used and disclosed by the Saint Raphael Healthcare System and its Medical Staff and how you can get access to this information.

Please review it carefully.

Please direct questions about this notice to the
Hospital of Saint Raphael Privacy Officer at 203-789-4305

The Saint Raphael Healthcare System has always been committed to respecting the privacy of you, other patients, and your protected health information. We are required by law to maintain the privacy of your protected health information, to provide you this detailed Notice of our legal duties and privacy practices relating to your protected health information, and to abide by the terms of the Notice that are currently in effect.

This Notice applies to the Saint Raphael Healthcare System, its entities and departments, including but not limited to the Hospital of Saint Raphael, Sister Anne Virginie Grimes Health Center, the Father Michael J. McGivney Center for Cancer Care, Saint Raphael Foundation, and DePaul Health Services Corporation.  It does not apply to the MRI Center or dialysis centers.

The privacy practices in this Notice, Saint Raphael Healthcare System policies and procedures, and federal and state laws must be followed by all members of the Saint Raphael community including employees, contracted individuals, members of the medical staff, volunteers, students, etc.  Business associates and partners who have access to protected health information because of their association with Saint Raphael’s must also follow these practices, policies and procedures.

Protected health information is information about you that may identify you, is related to your past, present, or future health condition; was obtained when you received services at Saint Raphael’s, or was received from other providers (doctors, hospitals, etc).  Entities of the Saint Raphael Healthcare System often must share your information for treatment, payment, or health care operations as noted below.  This is done in a safe, secure, and responsible manner.

I. USES AND DISCLOSURES FOR TREATMENT, PAYMENT AND HEALTH CARE OPERATIONS
The following are various ways in which we may use or disclose your protected health information for purposes of treatment, payment, and health care operations.

For treatment:  We may use and disclose your protected health information in providing you with treatment and services, in coordinating your care, and we may disclose information to other providers involved in your care. Your protected health information may be used by doctors, nurses, home health aides, physical therapists, pharmacists, suppliers of medical equipment, or other persons involved in your care.

For payment:  We may use and disclose your protected health information for billing and payment purposes.  We may disclose your protected health information to your representative, or to an insurance or managed care company, Medicare, Medicaid, or another third party payer. For example, we may contact Medicare or your health plan to confirm your coverage or to request prior approval for services that will be provided to you.

For health care operations:  We may use and disclose your protected health information as necessary for health care operations, such as management, personnel evaluation, education, training, and to monitor our quality of care.  We may disclose your protected health information to another entity with which you have or had a relationship if that entity requests your information for certain aspects of its health care operations or health care fraud and abuse detection or compliance activities. For example, protected health information of many patients may be combined and analyzed to evaluate and improve quality of care and planning for services.

II. SPECIFIC USES AND DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION
The following are various ways in which we may use or disclose your protected health information without your authorization.

Individuals involved in your care or payment for your care:  Unless you object, we may disclose protected health information about you to a family member, close personal friend, or other person you identify, including clergy, who is involved in your care.

Emergencies:  We may use or disclose your protected health information as necessary in emergency treatment situations.

Legal requirements:  We may use or disclose your protected health information when required by federal, state, or local law.

Business associates:  We may disclose your protected health information to a contractor or business associate who needs the information to perform services for Saint Raphael’s. Our business associates are obligated by law to preserve the confidentiality of this information.

General information/hospital directory:  Unless you object, we may provide general information (good, fair, etc.) about your condition to those who ask for you by name.

Public health activities:  We may disclose your protected health information for public health activities, including reporting to a public health authority for preventing or controlling disease, injury or disability, reporting child abuse or neglect or reporting births and deaths.

Reporting victims of abuse, neglect or domestic violence:  If we believe that you have been a victim of abuse, neglect, or domestic violence, we may use and disclose your protected health information to notify a government authority, if authorized by law or if you agree to the report.

Health oversight activities:  We may disclose your protected health information to a health oversight agency for activities authorized by law, such as audits, investigations, inspections, and licensure actions or for activities involving government oversight of the healthcare system.

To avert a serious threat to health or safety:  When necessary to prevent a serious threat to your health or safety or the health or safety of the public or another person, we may use or disclose protected health information, limiting disclosures to someone able to help lessen or prevent the threatened harm.

Judicial and administrative proceedings:  We may disclose your protected health information in response to a court or administrative order.  We also may disclose information in response to a subpoena, discovery request, or other lawful process under limited circumstances.

Law enforcement:  We may disclose your protected health information for certain law enforcement purposes, including to comply with reporting requirements or to comply with a court order, warrant, or similar legal process, or to answer certain requests for information concerning crimes and victims of crimes.

Research:  We may use or disclose your protected health information for research purposes if the privacy aspects of the research have been reviewed and approved, if the researcher is collecting information in preparing a research proposal, if the research occurs after your death, or if you authorize the use or disclosure.

Coroners, medical examiners, funeral directors, organ procurement organizations:  We may release your protected health information to a coroner, medical examiner, funeral director or, if you are an organ donor, to an organization involved in the donation of organs and tissue.

Military, veterans and other specific government functions:  If you are a member of the armed forces, we may use and disclose your protected health information as required by military command authorities.  We may disclose protected health information for national security purposes, to protect the President of the United States or certain other officials or to conduct certain special investigations.

Disaster relief:  Unless you object, we may disclose protected health information about you to a disaster relief organization.

Workers’ compensation:  We may use or disclose your protected health information to comply with laws relating to workers’ compensation or similar programs.

Inmates/law enforcement custody:  If you are under the custody of a law enforcement official or a correctional institution, we may disclose your protected health information to the institution or official for certain purposes including the health and safety of you and others.

Fundraising activities:  We may use certain limited information to contact you in an effort to raise funds for Saint Raphael’s and its operations.  You have the right to opt out of this process by writing to the Saint Raphael Foundation. There will be no fundraising contact made after you opt out.

Appointment reminders:  We may use or disclose protected health information to remind you about appointments.

Treatment alternatives and health-related benefits and services:  Unless you opt-out, we may use or disclose your protected health information to inform you about treatment alternatives and health-related benefits and services that may interest you.

III. USES AND DISCLOSURES WITH YOUR AUTHORIZATION
Except as described in this Notice, we will use and disclose your protected health information only with your written Authorization.  You may revoke an Authorization in writing at any time. If you revoke an Authorization, we will no longer use or disclose your protected health information for the purposes covered by that Authorization, except where we have already relied on the Authorization.

IV. YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION
Listed below are your rights regarding your protected health information. Each of these rights is subject to certain requirements, limitations, and exceptions. Exercising these rights may require you to submit a written request to Saint Raphael’s.  At your request, Saint Raphael’s will supply you with the appropriate form to complete.  You have the right to:

Request restrictions:  You have the right to request restrictions on the use or disclosure of your protected health information for treatment, payment, or health care operations. You also have the right to request restrictions on the protected health information we disclose about you to a family member, friend, or other person who is involved in your care or the payment for your care.

We are not required to agree to your requested restriction except where:

  • You are competent and the restriction is to family members or friends;
  • The disclosure is to a health plan for purposes of carrying out payment or health care operations, unless the disclosure is otherwise required by law; and the information pertains to a health care item or service for which you have paid out of pocket in full.

If we do agree to accept your requested restriction, we will comply with your request except as needed to provide you emergency treatment.

Access to protected health information: You have the right to inspect and obtain a copy of your clinical or billing records or other written information that may be used to make decisions about your care; subject to some exceptions. Your request must be made in writing and access will be provided in a timely manner. In most cases, we may charge a reasonable fee for our costs in copying and mailing your requested information. You have the right to request your information in an electronic format if the record is maintained electronically. The fee for providing an electronic copy may not be greater than the labor costs and the cost of the electronic storage media, if supplied by Saint Raphael Healthcare System, associated with responding to the request.

We may deny your request to inspect or receive copies in certain circumstances. If you are denied access to protected health information, in some cases you have a right to request review of the denial. The review will be performed by a licensed health care professional, designated by Saint Raphael’s, other than the one who made the initial decision to deny access.

Request amendment: You have the right to request amendment of your protected health information maintained by Saint Raphael’s as long as the information is kept by or for Saint Raphael’s. Your request must be made in writing to the Health Information Management Department and must state the reason for the requested amendment.

We may deny your request for amendment if the information:

  • was not created by Saint Raphael’s, unless the originator of the information is no longer available to act on your request
  • is not part of the protected health information maintained by Saint Raphael’s
  • is not part of the information to which you have a right of access
  • is already accurate and complete, as determined by Saint Raphael’s

We must respond to your request in 60 days with a written notification of our acceptance or denial of the amendment. If we agree to the amendment, we will amend the relevant portions of your medical record and make a reasonable effort to inform business associates and other individuals known to us, or identified by you, as having the protected health information requiring amendment.

If we deny your request for amendment, we will give you a written denial including the reasons for the denial and information about your right to submit a written statement disagreeing with the denial. Your statement of disagreement will be attached to your medical record. If a statement of disagreement is inserted, we have the right to insert a rebuttal statement. We will provide you with a copy of the rebuttal statement. If you do not wish to submit a statement of disagreement, you may request a copy of the amendment request and a copy of our denial be included with all future disclosures. Should we deny your request for an amendment, you have the right to process a complaint and/or contact the Secretary of Health and Human Services to lodge your complaint.

Request an accounting of disclosures: You have the right to request an “accounting” of certain disclosures of your protected health information made after April 14, 2003. This is a listing of disclosures made by Saint Raphael’s or by others on our behalf, but may not include disclosures for treatment, payment, and health care operations, disclosure made pursuant to your Authorization, and certain other exceptions allowed by law. To request an accounting of disclosures, you must submit a request in writing to the Health Information Management Department, stating a time period beginning after April 13, 2003 that is within six years from the date of your request.

Request a paper copy of this Notice: You have the right to obtain a paper copy of this Notice, even if you have agreed to receive this Notice electronically. You may request a copy of this Notice at any time by contacting our Privacy Officer at (203) 789-4305. A copy of this notice is also available at the Saint Raphael’s website: www.srhs.org.

Request confidential communications: You have the right to request that we communicate with you concerning your health matters in a certain manner or location. You must tell us how and where you want to be contacted. We will accommodate your reasonable requests, but may deny the request if you are unable to provide us with appropriate ways of contacting you.

Requests should be sent to:

The Health Information Management Department
The Saint Raphael Healthcare System
1450 Chapel Street
New Haven, CT 06511

V. SPECIAL RULES REGARDING DISCLOSURE OF PSYCHIATRIC, SUBSTANCE ABUSE AND HIV-RELATED INFORMATION
For uses and disclosures concerning protected health information relating to care for psychiatric conditions, substance abuse, or HIV-related testing and treatment, special restrictions may apply.
Except as provided below and as specifically permitted or required under state or federal law, protected health information relating to care for psychiatric conditions, substance abuse, or HIV-related testing and treatment may not be disclosed without your special authorization.

  • Psychiatric information: If needed for your diagnosis or treatment in a mental health program, psychiatric information may be disclosed as needed between your treatment team members. Certain limited information may be disclosed for payment purposes.
  • Psychotherapy notes: A special authorization is required for the disclosure of psychotherapy notes and special rules may apply which limit the information which is disclosed.
  • HIV-related information: HIV-related information may be disclosed for purposes of treatment or payment.
  • Substance abuse treatment: If you are treated in a specialized substance abuse program, your special authorization will be needed for most disclosures, not including emergencies.

VI. USES AND DISCLOSURES FOR MARKETING PURPOSES
Your written authorization must be obtained to use or disclose information for marketing purposes and we will disclose if the organization is receiving payment for making a marketing communication based on protected health information.

VII. INCIDENTAL DISCLOSURES
In the process of using or disclosing your protected health information for an authorized use, we may make incidental disclosures. We will take reasonable steps to limit incidental disclosures.

VIII. BREACH
We will follow all requirements related to any breach of unsecured protected health information. This includes, but is not limited to: determining whether unauthorized acquisition, access, use, or disclosure of protected health information has occurred; analyzing whether it compromises the security or privacy of the protected health information by posing a significant risk of financial, reputational, or other harm; determining whether any exceptions apply; and notifying affected individuals, media, and the Department of Health and Human Services, as required.

IX. FOR FURTHER INFORMATION OR TO FILE A COMPLAINT
If you have any questions about this Notice or would like further information concerning your privacy rights, please contact our Privacy Officer at (203) 789-4305 or visit our website, www.srhs.org.

If you believe that your privacy rights have been violated, you may file a complaint in writing with Saint Raphael’s or with the Office of Civil Rights in the U.S. Department of Health and Human Services. There will be no penalty or retaliation against you or any individual for filing a complaint.

If you believe your privacy rights have been violated, you may file a complaint in writing to:

Patient Relations Department
The Saint Raphael Healthcare System
1450 Chapel Street
New Haven, CT 06511

If you wish to file a complaint with the Secretary of the Department of Health and Human Services, Office of Civil Rights, you may send a letter to:

Office for Civil Rights
U.S. Department of Health and Human Services
Government Center
J.F. Kennedy Federal Building – Room 1875
Boston, MA 02203

X. CHANGES TO THIS NOTICE
We reserve the right to change this Notice and to make the revised or new Notice provisions effective for all protected health information already received and maintained by Saint Raphael as well as for all protected health information we receive in the future. We will provide a copy of the revised Notice upon request or you may obtain a copy of the Notice at our website: www.srhs.org.

Reference: HIPAA Privacy Regulation 164.520

Download an ENGLISH copy of this Notice of Privacy Practices

Download a SPANISH copy of this Notice of Privacy Practices

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