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Joint Privacy Notice THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. OUR PLEDGE REGARDING MEDICAL INFORMATION We understand that medical information about you and your health is personal. We are committed to protecting your medical information. We create a record of the care and services you receive at Rockford Health System. We need this record to provide you with quality care and to comply with certain legal requirements. This notice describes how we, the Rockford Health System Organized Health Care Arrangement (OHCA), may use and disclose your protected health information to carry out treatment, payment, or health care operations and for other purposes that are permitted or required by law. The Rockford Health System OHCA consists of Rockford Memorial Hospital, all of Rockford Clinic, the Visiting Nurses Association of Greater Rockford, Rockford Radiology Associates, Rockford Radiation Oncology, Ltd., certain members of the Unified Medical Staff of Rockford Health System and all physicians employed by Rockford Health System This notice covers all information in the written or electronic records which concerns you, your health care, and payment for your health care. It also covers information we share within the OCHA and with other organizations to help US provide your care, get paid for providing care and manage our administrative operations. This notice also describes your rights to access and control your protected health information. We are required by law to:
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU The following categories describe different ways that we are permitted to use and disclose your medical information. Each category will be defined and an example provided. Treatment: We may use your medical information to provide medical treatment or services. We may disclose your medical information to doctors, nurses, technicians, students or other personnel who are involved in taking care of you. 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 dietician if you have diabetes so that we may arrange for appropriate meals. Different parts within the Rockford Health System OHCA also may share your medical information in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We also may disclose your medical information to people outside the RHS OHCA who may be involved in your care outside the hospital or clinic, such as family members, home health agencies, reference labs or others who provide services that are part of your care. These are only examples and we may use or disclose information about you to provide you proper treatment in many other ways We will comply with the requirements of those Illinois laws that limit the use and disclosure of certain medical information. For example, we will not use or disclose any information regarding your HIV or AIDS status, mental health or developmental disabilities information, or genetic testing results without your express authorization, except as otherwise permitted by those laws regulating the use and disclosure of such information. Payment: We may use and disclose your medical information so that the treatment and services you receive through the Rockford Health System OHCA may be billed and payment may be collected from you, and insurance company or a third party. For example, we may need to give your health plan information about the surgery you received at the hospital, so your health plan will pay us or reimburse you for the surgery. We also may tell your health plan about treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment. Health Care Operations: We may use and disclose your medical information for Rockford Health System OHCA operation purposes necessary to run our businesses and to make sure that all of our patients receive quality care. The operations purposes for which we may disclose your medical information include, but are not limited to, various quality assessment and improvement activities, credentialing, training activities, and health care fraud and abuse detection or compliance activities. For example, Rockford Health System OHCA personnel may use or disclose your medical information to review the quality of our treatment and to evaluate the performance of personnel in caring for you. We also may combine your medical information with those of many Rockford Health System patients to determine whether additional services should be offered, what services are no longer needed and whether certain new treatments are effective. We also may use and disclose your responses to our patient satisfaction surveys after removing all identifying information from the materials, to Rockford Health System OHCA personnel, in order to improve our medical care and service to future patients. The Rockford Health System OHCA may use or disclose your medical information for limited operations purposes of certain other health care providers, clearinghouses or health plans. The persons and entities to which our system personnel may disclose your medical information must have or have had a treatment relationship with you, and the medical information discloses must pertain to that relationship. Rockford Health System may release medical information to appropriate bodies to facilitate statistical follow-up based on effectiveness of treatment. For example, we may disclose medical information to cancer or other disease-state registries. Appointment Reminders: We may use and disclose your medical information to contact you by phone or by mail to remind you that you have an appointment for treatment or medical care. Treatment Alternatives: We may use and disclose your 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 certain medical information about you, including your name, address, phone number, diagnosis and treatment (with corresponding dates) to send you information about health services that may be of benefit or interest to you. Hospital Directory: When you are hospitalized at Rockford Memorial Hospital, we may include your name, location within Rockford Memorial Hospital, general condition (e.g., "critical," "serious," "fair," or "good."), and religious affiliation within the Hospital directory. This directory information, except for your religious affiliation, may be provided to people who ask for you by name. This is so your family, friends and clergy may visit you during your stay and generally know how you are doing. We also may release this information to the news media in case of disasters, auto accidents and other police or fire cases that are a matter of public record. This information would be released only if the news media contacts the Hospital for a report on your medical condition and asks for you by name. Your religious affiliations may be given to a member of the clergy, such as a priest or rabbi, even if they do not ask for you by name. You will be asked upon admission if you wish for your information to be included in the Hospital's directory. If you are unable to consent or object, we may use and disclose this information consistent with your prior expressed preference, if known, and in your health professional's judgment. Individuals Involved in Your Care or Payment for Your Care: We may disclose medical information about you to a family member, other relative, close personal friend or any other person you identify who is involved in your medical care. We also may disclose information to someone who helps pay for your care. The medical information disclosed will be limited to that information relevant to the person's involvement in your care or payment related to your care. We also may disclose your medical information to an entity assisting in disaster relief effort, such that your family may be notified about your condition, status and location. If you do not want information disclosed to certain persons, regardless of their involvement in your care, please notify the Privacy Officer, in writing. If you are unable to object, we may exercise our professional judgment to determine if a disclosure is in your best interest. Research: Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involved 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 uses of medical information, trying to balance the research needs with patents' 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. 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 the Rockford Health System OHCA. We will 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 the Health System when required to do so by law. As Required by Law: We will disclose your medical information when required to do so by any federal, Sate or local law (e.g. reporting of coroner's cases or child/elder abuse with reasonable cause). To Avert a Serious Threat to Health or Safety: We may disclose medical information about you when necessary to prevent a serious threat to your health or safety or the health and safety of the public or another person. Any disclosure, however, would be to someone able to help prevent or avert the threat. Fundraising Activities Rockford Health System personnel may use basic contact information about you, such as your name, address, phone number, and dates of service, to send you information about charitable contribution opportunities on behalf of the Rockford Memorial Development Foundation. If you do not want Rockford Health System to send you such information, please contact the Foundation office in writing. Contract Services: As part of our health care operations, we may disclose medical information about you to vendors with which we contract to provide a service to the Rockford Health System OHCA. Examples of such vendors may include the copy service we use when making copies of your health record, attorneys, auditors, certain health care providers and other agencies. We may disclose medical information to an external transcription company or coding service for purposes of retransmitting that data back to Rockford Health System's clinical repository for inclusion in patients' health records. We may disclose medical information to a utilization review or case management group to review utilization/length-of-stay/or case management information, or to otherwise interact with third party payers for the purpose of obtaining authorization for continued hospitalization or appealing medical denials. When these services are contracted, we may disclose your medical information to our vendors such that they can perform the job we have asked them to do. To protect your medical information, we require the vendors to appropriately safeguard your information by requiring that they enter into an appropriate agreement with Rockford Health System. Incidental Uses and Disclosures: Rockford Health System OHCA personnel may use and disclose your medical information incident to another use or disclosure of your medical information that is permitted or required under law. Limited Data Sets: Rockford Health System OHCA personnel may use or disclose a limited data set of your medical information (i.e., a subset of your medical information in which all identifying information has been removed) for purposes of research, public health, or health care operations. Prior to our release, any recipient of that limited data must agree to appropriately safeguard your information. Special Situations
YOUR RIGHTS REGARDING YOUR MEDICAL INFORMATION You have the following rights regarding the medical information about you that we maintain: Right to Request Confidential Communications: You have the right to request and to receive (if the request is reasonable) confidential communications of protected health information by alternative means or at alternative locations (for example, receive information at your office instead of at home). Any such request must be submitted in writing to the Privacy Officer. Right to Request Restrictions: You have the right to request a restriction or limitation of the medical information we use or disclose 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, such as a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had. We are not required to agree to your request. If we do not agree, we will comply with your request unless the information is needed to provide emergency treatment. To request restrictions, you must make your request in writing to the Privacy Officer and state 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. Right to Inspect and Copy: You have the right to inspect and copy your medical information except in limited circumstances. Generally, this includes medical and billing records, but does not include psychotherapy notes. In order to inspect such records, you must submit your request in writing to the appropriate treating facility. If you request a copy of your records, 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. If you are denied access to your medical information, you may request that the denial be reviewed. We will comply with the outcome of the review. Right to Amend: If you believe the medical information we have about you is incomplete or incorrect, you have the right to request an amendment to the medical information contained within your medical record. Your request for an amendment must be made in writing and submitted to the Privacy Officer. In addition, 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, your request may be denied if you ask us to amend information that:
Right to an Accounting of Disclosures: You have the right to request and receive an accounting of disclosures of your medical information maintained by the Rockford Health System OHCA in the six (6) years prior to the request date, or during the period between the request date and April 14, 2003 whichever is more recent. Such an accounting will not include disclosures:
Any accounting will not include disclosures that you expressly authorize. The first accounting that you request within any 12-month period will be free. For additional accountings, we may charge you for the costs of providing the list. If you would like more information on how to exercise these rights, please contact the Privacy Officer. Right to a Paper Copy of This Notice: You have the right to a paper copy of this notice upon request. You may obtain a copy of this notice at our website, http://www.rhsnet.org, or obtain a copy from Patient Registration or Administration at Rockford Memorial Hospital, any Rockford Clinic location or the Visiting Nurses Association of Greater Rockford. FURTHER INQUIRIES OR GRIEVANCES If you need further information concerning this notice or its statements, you may contact the Privacy Officer as listed below. If you feel that your privacy rights have been violated, you may submit your complaint in writing to the applicable Privacy Officer or the U.S. Department of Health and Human Services. Patients will not be retaliated against for filing a complaint. Contacts This notice is effective April 14, 2003 |