Corporate Compliance & Privacy Practices

Notice of Privacy Practices for Protected Health Information (PHI)

“This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.”

Our agency is required by law to maintain the privacy of protected health information, to provide you adequate notice of your rights and our legal duties and privacy practices with respect to protected health information and to notify affected individuals following a breach of unsecured protected health information. [45 CFR § 164.520] We will use or disclose protected health information in a manner that is consistent with this notice.

The agency maintains a record (paper/ electronic file) of the information we receive and collect about you and of the care we provide to you. This record includes physicians’ orders, assessments, medication lists, clinical progress notes and billing information.

As required by law, the agency maintains policies and procedures about our work practices, including how we coordinate care and services provided to our patients. These policies and procedures include how we create, receive, access, transmit, maintain and protect the confidentiality of all health information in our workforce and with contracted business associates and/ or subcontractors; security of the agency building and electronic files; and how we educate staff on privacy of patient information.

As our patient, information about you must be used and disclosed to other parties for purposes of treatment, payment and health care operations.

Examples of information that must be disclosed:

Treatment: Providing, coordinating or managing health care arid related services, consultation between health care providers relating to a patient or referral of a patient for health care from one provider to another. For example, we meet on ·a regular basis to discuss how to coordinate care for patients and to schedule visits.

Payment: Billing and collecting for services provided, determining plan eligibility and· coverage, utilization review (UR), pre-certification, medical necessity review. For example, occasionally the insurance company requests a copy of the medical record be sent to them for a coverage review prior to paying the bill.

Health Care Operations: General agency administrative and business functions, quality assurance/improvement activities; medical review; auditing functions; developing clinical guidelines; determining the competence or qualifications of health care professionals; evaluating agency performance; conducting training programs with students or new employees; licensing, survey, certification, accreditation and credentialing activities; internal auditing; and certain fundraising activities and with your authorization, marketing activities. For example, our agency periodically holds clinical record review meetings where the consulting professional of our record review committee will audit clinical records for meeting professional standards and utilization review.

The following uses and disclosures do not require your consent, and include, but are not limited to, a release of information contained in financial records and/ or medical records, including information concerning communicable diseases such as Human Immunodeficiency Virus (HIV) and Acquired Immunodeficiency Syndrome (AIDS), drug/ alcohol abuse, psychiatric diagnosis and treatment records and/or laboratory test results, medical history, treatment progress and/ or any other related information as permitted by state law to:

  1. Your insurance company, self-funded or third-party health plan, Medicare, Medicaid or any other person or entity that may be responsible for paying or processing for payment any portion of your bill for services;
  2. Any person or entity affiliated with or representing us for purposes of administration, billing and quality and risk management;
  3. Any hospital, nursing home or other health care facility to which you may be admitted;
  4. Any assisted living or personal care facility of which you are a resident;
  5. Any physician providing you care;
  6. Licensing and accrediting bodies, including the information contained in the OASIS Data Set to the state agency acting as a representative of the Medicare/Medicaid program;
  7. Contact you to raise funds for the Agency; you will be given the right to opt out of receiving such communications;
  8. Any business associate or institutionally related foundation for the purpose of raising funds for the agency (information may include: demographics – name, address, contact information, age, gender, date of birth; dates of health care provided; department of services; treating physician; outcome information; and health insurance status). You will be given the right to opt out;
  9. Refill reminders for drugs, biologicals and/or drug delivery systems that have already been prescribed to you;
  10. Marketing communications promoting health products, services and information if the communication is made face to face with you or the only financial gain consists of a promotional gift of nominal value provided by the agency; and
  11. Other health care providers to initiate treatment.

We are permitted to use or disclose information about you without consent or authorization in the following circumstances:

  1. In emergency treatment situations, if we attempt to obtain consent as soon as practicable after treatment;
  2. Where substantial barriers to communicating with you exist and we determine that the consent is clearly inferred from the circumstances;
  3. Where we are required by law to provide treatment and we are unable to obtain consent;
  4. Where the use or disclosure of medical information about you is required by federal, state or local law;

We are permitted to use or disclose information about you provided you are informed in advance and given the opportunity to individually agree to, prohibit, opt out or restrict the disclosure in the following circumstances:

  1. Use of a directory (includes name, location, condition described in general terms) of individuals served by our Agency;
  2. Provide proof of immunization to a school that is required by state or other law to have such proof with agreement to disclosure by parent, guardian or other person acting in loco parentis if record is of an unemancipated minor; and
  3. Provide a family member, relative, friend or other identified person, prior to, or after your death, the information relevant to such person’s involvement in your care or payment for care; to notify a family member, relative, friend or other identified person of your location, general condition or death.

Other uses and disclosures not covered in this notice will be made only with your authorization. Authorization may be revoked, in writing, at any time, except in limited situations for the following disclosures:

  1. Marketing of products or services or treatment alternatives that may be of benefit to you when we receive direct payment from a third party for making such communications;
  2. Psychotherapy notes under most circumstances, if applicable; and
  3. Any sale of protected health information resulting in financial gain by the agency unless an exception is met.

YOUR RIGHTS – You have the right, subject to certain conditions, to:

  • Request restrictions on uses and disclosures of your protected health information for treatment, payment or health care operations. However, we are not required to agree to any requested restriction. Restrictions to which we agree will be documented. Agreements for further restrictions may, however be terminated under applicable circumstances (e.g., emergency treatment).  We must agree to your request to restrict disclosure of protected health information about you to a health plan if: 1) the disclosure is for the purpose of carrying out payment or health care operations and is not otherwise required by law; and 2) the protected health information pertains solely to a health care item or service for which you or someone on your behalf paid the covered entity in full. (164.522 Rights to request privacy protection for protected health information).
  • Confidential communication of protected health information. We will arrange for you to receive protected health information by reasonable alternative means or at alternative locations. Your request must be in writing. We do not require an explanation for the request as a condition of providing communications on a confidential basis and will attempt to honor reasonable requests for confidential communications.  If you request your protected health information to be transmitted directly to another person designated by you, your written request must be signed and clearly identify the designated person and where the copy of protected health information is to be sent.
  • Receive notification of any breach in the acquisition, access, use or disclosure of unsecured protected health information by the agency, its business associates and/ or subcontractors.
  • Obtain a paper copy of this notice, even if you had agreed to receive this notice electronically, from us upon request.

COMPLAINTS – If you believe that your privacy rights have been violated, you may complain to the Agency or to the Secretary of the U.S. Department of Health and Human Services. There will be no retaliation against you for filing a complaint. The complaint should be filed in writing, and should state the specific incident(s) in terms of subject, date and other relevant matters. A complaint to the Secretary must be filed in writing within 180 days of when the act or omission complained of occurred, and must describe the acts or omissions believed to be in violation of applicable requirements. [45 CFR § 160.306] For further information regarding filing a complaint, contact:

Amanda McFaddin, VP, Regulatory Affairs, Compliance Officer

545 Mainstream Drive, Suite 412

Nashville, TN 37228

Phone:

(615) 733-3600

Toll Free:

1-844-405-0005

Fax:

(215) 689-3885

(must include company name with report)

Email:

reports@lighthouse-services.com

(must include company name with report)

EFFECTIVE DATE – This notice is effective November 5, 2015. We are required to abide by the terms of the notice currently in effect, but we reserve the right to change these terms as necessary for all protected health information that we maintain. If we change the terms of this notice (while you are receiving service), we will promptly revise and distribute a revised notice to you as soon as practicable by mail, email (if you have agreed to electronic notice), hand delivery or by posting on our website.

If you require further information about matters covered by this notice, please contact:

Amanda McFaddin, VP, Regulatory Affairs, Compliance Officer

545 Mainstream Drive, Suite 412

Nashville, TN 37228

Phone:

(615) 733-3600

Toll Free:

1-844-405-0005

Fax:

(215) 689-3885

(must include company name with report)

Email:

reports@lighthouse-services.com

(must include company name with report)

Adoration Home Health does not discriminate against any person on the basis of race, color national origin, disability, age, sexual orientation, gender identity, religion, or creed in admission, treatment, or participation in its programs, services and activities. For further information about this policy, contact:

Contact Person/Section 504 Coordinator:

Amanda McFaddin, Compliance Officer

Telephone number:

(615) 733-3600

TDD or State Relay number:

(800) 848-0298 (TTY)

(800) 848-0299 (Voice)

If you have questions or concerns regarding the following activities (list is not all inclusive), you are obligated to report it to the Corporate Compliance Officer, Amanda McFaddin at 615-733-3600 or you may report anonymously to the Compliance Hotline at 844-405-0005.

  • Ethical violations
  • Unsafe Working Conditions
  • Quality of Service
  • Sexual Harassment
  • Discrimination
  • Alcohol and Substance Abuse
  • Fraud
  • Conflict of Interest
  • Theft and Embezzlement
  • Violation of the Law
  • Falsification of Contract, Reports or Records
  • Wrongful Discharge
  • Internal Controls
  • Vandalism and Sabotage
  • Theft
  • Conduct Violations
  • Threats
  • Bribery and Kickbacks
  • Improper Conduct
  • Violation of Company Policy
  • Misuse of Company Property