Notice of Privacy Practices
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This notice describes our hospital system, hospital, and health care center’s, here after referred as, Cookeville Regional Health Systems (“CRHS”), Privacy Practices and that of specific doctors and health care professionals who participate in an organized health care arrangement (“arrangement”) with us to provide an integrated health care setting.
It is important for you to know that most doctors who care for you at Cookeville Regional Medical Center, (CRMC) are not employees of the facility, so we must have an arrangement by which doctors and facility employees work together to provide quality patient care. The privacy practices in this notice apply to doctors and other independent health care professionals and only relates to the patient care services provided to you in our Health System. This notice is meant to satisfy a “joint notice” requirement, so that your health care service at CRHS is not disrupted. Doctors and other independent health care professionals may have different policies or notices regarding their use and disclosure of the medical information created or received by their offices or clinics.
People who work within our arrangement will share protected health information with each other, as necessary to carry out treatment, payment, or health care operations relating to our arrangement.
Therefore, this notice applies to:
- CRHS, which includes any health care entity legally owned or operated by CRHS, to include Highland Rim Home Health, Cookeville Regional Medical Group, The Sleep Center at Cookeville Regional, The Cancer Center at Cookeville Regional, The Surgery Center at Cookeville Regional, The Women’s Center at Cookeville Regional, The Diabetes Center at Cookeville Regional, The Imaging Center at Cookeville Regional, The Inpatient Rehabilitation Center at Cookeville Regional, The Heart Center at Cookeville Regional, The Spine Center of Cookeville Regional, Fairfield-Glade Outpatient Clinic, Cumberland River Hospital and Home Care.
- All CRHS employees, volunteers, and students of specific educational programs.
- Business associates and business associate subcontractors of CRHS, such as businesses, health care professionals and/or employees who are contracted to provide CRHS facility-based services. To protect your information, we require the business associate, business associate subcontractors and their employees to appropriately safeguard your information. Examples: pathology, emergency, information system service, and doctors who are employed to direct certain patient care programs. Our hospital system maintains Business Associate Agreements with all affiliates who create, transmit or maintain your Personal Health Information. These Business Associates are held to the highest privacy standards as CRHS.
- Any doctor or health care professional who is part of CRHS’s organized health care arrangement. To be included in this arrangement, a doctor or health care professional must (1) be a “covered entity” under the Federal Privacy Regulation 45 CFR Part 160, (2) have medical staff privileges or been authorized to participate in patient care by the Medical Staff and CRHS Board of Trustees, and (3) have agreed to participate in the arrangement.
We respect the confidentiality of your health information and recognize that information about your health is personal. We are committed to protecting medical information about you and to informing you of your rights regarding such information. . We create a record of the care and services you each time you receive care at CRHS. This protected health information generally includes information that we create or receive that identifies you and your past, present or future health status or care or the provision of or payment for that health care. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care created or retained by CRHS, whether made by CRHS personnel or your personal doctor.
In this Notice, we refer to our uses and disclosures of health information as our “Privacy Practices.”
This notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.
We are required by law to:
• Maintain the privacy of protected health information;
• Prohibit the sale of your protected health information
• Duty to notify you in case of a breach of your protected health information.
• Your Right to “Opt Out” of any of our Fundraising campaigns.
• Inform you of how you have the Right to Restrict disclosure of your health service when you are paying with cash or credit card and paid in full to your insurance company.
• Provide individuals with notice of our legal duties and privacy practices with respect to protected health information; and
• Follow the terms of the notice that is currently in effect.
The Privacy law states we only have to provide the Privacy Notice to you once. CRHS enters this event of acknowledgment into our health information system for our staff to check whether or not you’ve already acknowledged the notice and that we have provided this notice to you already. However, when a change, update or revision is made, we must give a new notice to you or show you where you can either obtain a copy or view the notice.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU:
The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories. Any disclosure not described in this notice will be made only with the individual’s written authorization, and you have the right to revoke an authorization at any time, if you feel the person or organization you gave authorization to as provided by 164.508(b)(5) of the Privacy rule. CRHS will always obtain a written authorization to disclose information for psychotherapy notes, if these are ever contained in your medical record and for marketing if it involves financial remuneration. Notwithstanding any provision of [the HIPAA Privacy Rule], other than the transition provisions in 164.532, CRHS must obtain an authorization for any disclosure of protected health information which is a sale of protected health information, as defined in 164.501 of [the HIPAA Privacy Rule]. (ii) This written authorization must include a statement that the disclosure will result in remuneration to CRHS or any of our legally owned or operated service delivery systems.
For Treatment. We may use medical information about you to provide you with medical treatment or services. We may disclose medical information about you to doctors, nurses, technicians, medical and/or nursing students, or other health care center personnel who are involved in taking care of you at CRHS. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals. Different departments of CRHS also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We also may disclose medical information about you to people outside CRHS who may be involved in your medical care after you leave, such as giving instructions to family members who will be driving you home or who will be helping to care for you at home. We may also share your medical information with:
• Another health care facility who needs your medical information to provide ongoing care or who needs information to evaluate a possible transfer to their facility;
• The physician who ordered a test and needs the results of the test to diagnose your condition; or
• A physician who is expected to see you in his/her office or clinic after discharge or release from CRHS.
With the combination of the Health Information Technology for Economic and Clinical Health (HITECH) Act and the Patient Protection and Affordable Care Act (PPACA), CRHS has chosen to give higher priority to requests related to your continuity of care for your primary care provider. The priority facilitates the provision of more timely, higher quality, and safer patient care. This way of providing your PHI from our hospital to your doctor is defined in the Affordable Care Act. Upon admission or receiving a service, if you provide your primary care provider’s information, your PHI may be sent to that provider. Patients have the right to request restriction or limitation on the medical information we use or disclose about your treatment, payment or health care operations.
For Payment. We may use and disclose medical information about you so that the treatment and services you receive at CRHS may be billed, and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about surgery you received at the health care center so your health plan will pay us or reimburse you for the surgery. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment. We may also release certain information to someone who is responsible to pay for your care. However, if you would like to pay for your health care service in full and not have this information go to your insurance company, you can “restrict” us from sharing your protected health information. You must complete a form through our Medical Record department to ensure this restriction is on file. You must also complete a form in our Patient Financial Services department indicating this restriction upon paying for the service in full.
For Health Care Operations. We may use and disclose medical information about you for CRHS operations. These uses and disclosures are necessary to run CRHS and make sure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many CRHS patients to decide what additional services CRHS should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, technicians, medical and/or nursing students, and other CRHS staff for review and learning purposes. We may also combine the medical information we have with medical information from other health care centers to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning the identity of specific patients.
Appointment Reminders. We may use and disclose medical information to contact you by phone or mail to remind you that you have an appointment at the health care center or a physician’s office or clinic. (See section on Right to Request Confidential Communications.)
Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefits and Services. We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you. However, CRHS will never sell your information or receive any payments for offering you goods or services.
Fundraising Activities. We may use information about you in an effort to raise money for a foundation which helps CRHS provide better services to our community and surrounding counties, including a Cancer Care Fund where we can accept donations to benefit cancer patients. We are permitted to use your demographic information, dates of your healthcare services, a particular department that provided services to you, your physician, your health plan status and the outcome of your health care service delivery without your authorization. If you do NOT wish to receive any fundraising communications, you may “opt-out” of receiving the information by calling 1-855-343-2541 or e-mailing firstname.lastname@example.org. If you DO want to begin receiving fundraising communications in the future, you may use the above easy method by calling or e-mailing the telephone number above or e-mailing the email@example.com
Health Care Center Directory. We may include certain limited information about you in the CRHS directory while you are a patient in or receive health care services at CRHS. This information may include your name, location in CRHS, and your general condition (e.g., fair, stable, etc.) The directory information may be released to people who ask for you by name. This is so your family and friends can visit you in CRHS and generally know how you are doing. If you do NOT want to be in the hospital directory, notify the Registrar at the time you check-in to the facility.
Clergy/Chaplain Services. If you provide your religious affiliation to the Registrar, then your name, location and religious affiliation may be given to a member of the clergy, such as a preacher, minister, priest or rabbi. This provides the opportunity for clergy to visit you in the hospital. If you do NOT wish to be contacted by any clergy member, you must notify your Registrar.
Individuals Involved in Your Care. We may release medical information about you to a friend or family member who you allow being present during your care or who may be involved in your medical care. We may share medical information about unemancipated minors with a parent, legal guardian or other person acting in loco parentis if not otherwise limited by law.
Customer Service. As part of our customer service program, we may use medical information about you to contact you by mail or phone after discharge to discuss your opinion of the services provided during your encounter with our facility.
Follow Up Contact. We may use medical information about you to contact you by mail or phone following treatment if it is determined you may require additional follow-up. We may also contact you or your personal doctor to follow up on how you are doing following treatment at CRHS. For example, follow-up information is very important in the area of cancer in order to find the best treatments and improve the life expectancy of people diagnosed with cancer.
Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with patients’ need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, but we may, however, disclose medical information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the medical information they review does not leave CRHS. We will almost always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at CRHS.
As Required By Law. We will disclose medical information about you when required to do so by federal, state or local law. This may include provision of patient information for State and National registries and databases, that use the data to identify health needs and improve health services.
To Avert a Serious Threat to Health or Safety. We may use and disclose medical information about you when necessary to prevent a serious threat 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 threat.
Organ and Tissue Donation. We may release medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.
Genetic Testing. We will need to obtain a written authorization from you to release this particular testing up and above the standard release of information process. Health Plans will and may receive this data for payment purposes. You must pay special attention to how you wish this information to be disclosed.
Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
Workers’ Compensation. We may release medical information about you for worker’s compensation or similar programs. These programs provide benefits for work-related injuries or illness. Medical information relating to a Worker’s Compensation claim may be released back to the employer and/or insurance carrier who pays for these programs.
Public Health Risks. We may disclose medical information about you for public health activities. These activities generally include the following:
• To prevent or control disease, injury or disability;
• To report births and deaths;
• To report child abuse or neglect;
• To report reactions to medications or problems with products;
• To notify people of recalls of products they may be using;
• To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; or
• To notify 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.
Health Oversight Activities. We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
Emergency/Disaster Situations. In the case of a disaster (such as mass casualties), we may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.
Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request, obtain an order protecting the information requested or authorization has been received by you to release the requested information.
Law Enforcement. We may release medical information if asked to do so by a law enforcement official:
• In response to a court order, subpoena, warrant, summons or similar process;
• To identify or locate a suspect, fugitive, material witness, or missing person;
• About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
• About a death we believe may be the result of criminal conduct;
• About criminal conduct at the health care center; 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 the crime.
Coroners, Medical Examiners and Funeral Directors. We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information about patients of the health care center to funeral directors as necessary to carry out their duties.
National Security and Intelligence Agencies. We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security agencies authorized by law.
Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.
YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU:
You have the following rights regarding medical information we maintain about you. For any of the following rights, forms to help you with the process are available at registration areas, in the Medical Records Department, on our web sitewww.crmchealth.org, or you can request a form from the Privacy Officer. The address and phone number of the Privacy Officer are listed on the last page of this document.
You have a Right To Access your Protected Personal Health Information in a form or format that is readily able to be produced in paper or electronic copy. The CRHS staff will make all efforts to generate this information to you in the format you request, however, if requesting in the Emergency Department, it may not be able to be produced electronically due to crisis or lack of staff availability. You will be referred to the Medical Record Department.
Right to Inspect and Obtain a Copy. You have the right to inspect and obtain a copy of medical information that may be used to make decisions about your care, unless otherwise limited by law. Usually, this includes medical and billing records, but does not include psychotherapy notes.
To inspect and obtain copy medical information that may be used to make decisions about you, you must submit your request in writing to 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 associated with your request.
We may deny your request to inspect and copy in certain very limited circumstances, as permitted by law. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by CRHS 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 of the review.
Right to Amend. If you feel that medical 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 CRHS.
To request an amendment, your request must be made in writing and submitted to the Privacy Officer. You must provide a reason that supports your request.
We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
• 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 the medical information kept by or for the health care center;
• Is not part of the information which you would be permitted to inspect and copy; or
• Is accurate and complete.
Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures.” This is a list of the disclosures we made of medical information about you, other than disclosures made for treatment, payment, operations of other reasons where an accounting of disclosures is not required.
To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer.
Your request must state a time period that may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12 month period will be free. For additional lists, we may charge you for the costs of providing the list. 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, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had. As indicated above, you may restrict disclosure to your insurance company if you pay for your health service in full and out of pocket. CRHS must comply with this special circumstance under the HITECH §13405(a).
We are not required to agree to your request. If we do agree, we will comply with your request, unless the information is needed to provide you emergency treatment.
To request restrictions, you must make your request in writing to the Privacy Officer. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.
Right to Request Confidential Communications. You have the right to request that we communicate with you about health care 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.
To request confidential communications, you must make your request in writing to the Privacy Officer. We will not require a reason for the request. Your request must specify how or where you wish to be contacted, and how payment will be handled, when appropriate. CRHS will make all reasonable efforts to accommodate your alternative requests for confidential communications. CRHS reserves the right to contact you at any known location or in any way legally permitted if payment is overdue, and you do not respond to initial notification.
Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.
You may obtain a copy of this notice at our website, www.crmchealth.org,
Personal Representative. Your “personal representative” may exercise the rights listed above on your behalf, if under applicable law, that person has legal authority to act on your behalf in making decisions related to health care. If you live in Tennessee and do not have a “personal representative,” you may wish to create a legal document called a Durable Power of Attorney for Health Care. This may be extremely beneficial in the unfortunate situation where you are unable to make a decision for yourself and wish for someone to be able to act on your behalf. You may request more information about this from our Registrar or the Social Services Department.
CHANGES TO THIS NOTICE:
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice within CRHS and on our web site. The notice will contain the effective date. If we make a substantial change to the notice, a revised notice will be available to you at the next time you register at CRHS for treatment or health care services as an inpatient or outpatient.
You have a right to be contacted when CRHS encounters a “Breach” of your Protected Personal Health Information. A breach is acquisition, access, use or disclosure of your Personal Health Information in violation of the Privacy Rule. The exceptions are:
• If a staff person “unintentionally", and in good faith, with no further use of your PHI accesses your medical information, no breach
• If a staff person inadvertently “sees” your PHI and is within the scope of their job, no breach
• Or if your PHI cannot be retained, because it was not used or disclosed for any length of time, i.e., 1 minute, no breach
• And lastly, if there is a low probability of the access, use or disclosure compromising you in any manner, no breach
If any Breach occurs in any of our CRHS facilities, the Privacy Office will conduct a thorough and comprehensive risk assessment. Any valid breaches are reported to the Office of Civil Rights and you!
If you believe your privacy rights have been compromised, you may file a complaint with the CRHS Privacy Officer or with the Secretary of the Department of Health and Human Services.
All complaints must be submitted in writing. You will not be penalized for filing a complaint.
OTHER USES OF MEDICAL INFORMATION:
Other uses and disclosures of medical information not covered by the categories or specified purposes listed in this notice will be made only with your written authorization.
If you provide us authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time.
To revoke an authorization. As soon as we receive and process your request to revoke your original authorization, we will then cease to use or disclose medical information about you as was originally permitted. You understand that we are unable to take back any disclosures we have already made prior to revoking your permission.
CONTACT INFORMATION FOR THE PRIVACY OFFICER:
Cookeville Regional Medical Center
1 Medical Center Boulevard
Cookeville, TN 38501
Call the Privacy Officer at (931) 783-2710 or email, firstname.lastname@example.org.
Effective Date: September 23, 2013
Revision Date: February 27, 2015