Notice of Privacy Practices

Treatment: We will use and disclose your protected health information to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with a third party for treatment purposes. For example, we may disclose your protected health information to a pharmacy to fulfill a prescription, to a laboratory to order a blood test, or to a home health agency that is providing care in your home. We may also disclose protected health information to other physicians who may be treating you or consulting with your physician with respect to your care. In some cases, we may also disclose your protected health information to an outside treatment provider for purposes of the treatment activities of the other provider.

Payment: Your protected health information will be used, as needed, to obtain payment for the services that we provide. This may include certain communications to your health insurer to get approval for the treatment that we recommend. For example, if a hospital admission is recommended, we may need to disclose information to your health insurer to get prior approval for the hospitalization. We may also disclose protected health information to your insurance company to determine whether you are eligible for benefits or whether a particular service is covered under your health plan. In order to get payment for your services, we may also need to disclose your protected health information to your insurance company to demonstrate the medical necessity of the services or, as required by your insurance company, for utilization review. We may also disclose patient information to another provider involved in your care for the other provider’s payment activities.

Operations: We may use or disclose your protected health information, as necessary, for our own healthcare operations in order to facilitate the function of the Practice and to provide quality care to all patients. Healthcare operations include such activities as:

• Quality assessment and improvement activities
• Employee review activities
• Training programs, including those in which students, trainees, or practitioners in health care learn under supervision
• Accreditation, certification, licensing, or credentialing activities
• Review and auditing, including compliance reviews, medical reviews, legal services, and maintaining compliance programs
• Business management and general administrative activities (In certain situations, we may also disclose patient information to another provider or health plan for their healthcare operations.)

Other Uses and Disclosures: As part of treatment, payment and healthcare operations, we may also use or disclose your protected health information for the following purposes: to remind you of an appointment, to inform you of potential treatment alternatives or options, or to inform you of health-related benefits or services that may be of interest to you. Although we currently do not engage in any fundraising activities, in the future we may contact you in order to raise funds for the Practice or an institutional foundation related to the Practice. Should we send you any fundraising communications, you will be provided with an opportunity to opt-out of receiving any future communications. If you do not wish to be contacted regarding fundraising, please contact our Privacy Officer.

When Legally Required: We will disclose your protected health information when we are required to do so by any Federal, State, or local law.

When There Are Risks to Public Health: We may disclose your protected health information for the following public activities and purposes:

• To prevent, control, or report disease, injury or disability as permitted by law
• To report vital events such as birth or death as permitted or required by law
• To conduct public health surveillance, investigations, and interventions as permitted or required by law
• To collect or report adverse events and product defects, track FDA regulated products, enable product recalls, repairs or replacements to the FDA, and to conduct post-marketing surveillance.
• To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease as authorized by law
• To report to an employer information about an individual who is a member of the workforce as legally permitted or required

To Report Abuse, Neglect, or Domestic Violence: We may notify government authorities if we believe that a patient is the victim of abuse, neglect, or domestic violence. We will make this disclosure only when specifically required or authorized by law or when the patient agrees to the disclosure.

To Conduct Health Oversight Activities: We may disclose your protected health information to a health oversight agency for activities including audits; civil, administrative, or criminal investigations, proceedings, or actions; inspections; licensure or disciplinary actions; or other activities necessary for appropriate oversight as authorized by law. We will not disclose your health information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.

In Connection With Judicial and Administrative Proceedings: We may disclose your protected health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a signed authorization. In certain circumstances and, as permitted by state law, we may be compelled to disclose your protected health information in response to a subpoena, but only where we receive satisfactory assurances that reasonable efforts have been made to notify you or to obtain a protective order.

• For Law Enforcement Purposes: We may disclose your protected health information to a law enforcement official for law enforcement purposes as follows:
• As required by law for reporting of certain types of wounds or other physical injuries
• Pursuant to court order, court-ordered warrant, subpoena, summons or similar process
• For the purpose of identifying or locating a suspect, fugitive, material witness or missing person
• Under certain limited circumstances, when you are the victim of a crime
• To a law enforcement official, if the Practice has a suspicion that your death was the result of criminal conduct
• In an emergency in order to report a crime

To Coroners, Funeral Directors, and for Organ Donation: We may disclose protected health information to a coroner or medical examiner for identification purposes, to determine cause of death or for the coroner or medical examiner to perform other duties authorized by law. We may also disclose protected health information to a funeral director, as authorized by law, in order to permit the funeral director to carry out their duties. We may disclose such information in reasonable anticipation of death. Protected health information may be used and disclosed for cadaveric organ, eye, or tissue donation purposes.

For Research Purposes: We may use or disclose your protected health information for research when the use or disclosure for research has been approved by an institutional review board or privacy board that has reviewed the research proposal and research protocols to address the privacy of your protected health information.

In the Event of a Serious Threat to Health or Safety: We may, consistent with applicable law, and ethical standards of conduct, use or disclose your protected health information if we believe, in good faith, that such use or disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.

For Specified Government Functions: In certain circumstances, the Federal regulations authorize the Practice to use or disclose your protected health information to facilitate specified government functions relating to military and veterans activities, national security and intelligence activities, protective services for the President and others, medical suitability determinations, correctional institutions, and law enforcement custodial situations.

For Worker’s Compensation: The Practice may release your health information to comply with worker’s compensation laws or similar programs.

The right to inspect and copy your protected health information: You may inspect and obtain a copy of your protected health information that is contained in a designated record set for as long as we maintain the protected health information. A “designated record set” contains medical and billing records and any other records that your physician and the Practice use for making decisions about you. If information in a “designated record set” is maintained electronically, you may request an electronic copy in a form and format of your choice that is readily producible or, if the form/format is not readily producible, you will be given a readable electronic copy.

Under Federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding; and protected health information that is subject to a law that prohibits access to protected health information. Depending on the circumstances, you may have the right to have a decision to deny access reviewed.

We may deny your request to inspect or copy your protected health information if, in our professional judgment, we determine that the access requested is likely to endanger your life or safety or that of another person, or that it is likely to cause substantial harm to another person referenced within the information. You have the right to request a review of this decision.

To inspect or copy your medical information, you must submit a written request to the Privacy Officer whose contact information is listed on the last pages of this Notice. If you request a copy of your information, we may charge you a fee for the costs of copying, mailing or other costs incurred by us in complying with your request. Please contact our Privacy Officer if you have questions about access to your medical record.

The right to request a restriction on uses and disclosures of your protected health information: You may ask us not to use or disclose certain parts of your protected health information for the purposes of treatment, payment, or health care operations. You may also request that we not disclose your health information to family members or friends who may be involved in your care or for notification purposes as described in this Notice of Privacy Practices. Your request must state the specific restriction requested and to whom you want the restriction to apply.

The Practice is not required to agree to a restriction that you may request unless your request relates to a disclosure to a health plan for services that were paid in full by you or someone other than the health plan and the disclosure is not required by law. We will notify you if we deny your request to a restriction. If the Practice does agree to the requested restriction, we may not use or disclose your protected health information in violation of that restriction unless it is needed to provide emergency treatment. Under certain circumstances, we may terminate our agreement to a restriction. You may request a restriction by contacting the Privacy Officer.

The right to request to receive confidential communications from us by alternative means or at an alternative location: You have the right to request that we communicate with you in certain ways. We will accommodate reasonable requests. We may condition this accommodation by asking you for information as to how payment will be handled or specification of an alternative address or other method of contact. We will not require you to provide an explanation for your request. Requests must be made in writing to our Privacy Officer.

The right to have your physician amend your protected health information: You may request an amendment of protected health information about you in a designated record set for as long as we maintain this information. In certain cases, we may deny your request for an amendment. If we deny your request for amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal. Requests for amendment must be in writing and must be directed to our Privacy Officer. In this written request, you must also provide a reason to support the requested amendments.

The right to receive an accounting: You have the right to request an accounting of certain disclosures of your protected health information made by the Practice. This right applies to disclosures for purposes other than treatment, payment, or healthcare operations as described in this Notice of Privacy Practices. We are also not required to account for disclosures that you requested, disclosures that you agreed to by signing an authorization form, disclosures for a facility directory, to friends or family members involved in your care, or certain other disclosures we are permitted to make without your authorization. The request for an accounting must be made in writing to our Privacy Officer. The request should specify the time period sought for the accounting. Accounting requests may not be made for periods of time in excess of six years. We will provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.

The right to obtain a paper copy of this Notice: Upon request, we will provide a separate paper copy of this Notice even if you have already received a copy of the Notice or have agreed to accept this Notice electronically.