Sensitive Care     Confidential Services   Compassionate Staff

Home

Abortion Services

Appointment Information

Directions

24 hour Consent Law

Parental Consent Law

Counseling Services

Decision-Making Process

Links

HERITAGE CLINIC FOR WOMEN

NOTICE OF PRIVACY PRACTICES

PLEASE REVIEW IT CAREFULLY.

A federal regulation, known as the "Health Insurance Portability and Accountability Act" or "HIPAA Privacy Rule," requires that we provide a detailed written notice of our privacy practices. The HIPAA Privacy Rule requires us to address many specific issues in this Notice which makes it lengthy yet relevant to your privacy rights.

As permitted by the HIPAA Privacy Rule, we reserve the right to make changes to this Notice and to make such changes effective for all PHI we may already have about you. If and when this Notice is changed, we will post a copy in our office in a prominent location and on our website at www.heritageclinic.com . We will also provide you with a copy of the revised Notice upon your request to our Privacy Official. You will be asked to sign a form to show that you received this Notice. Even if you do not sign this form, we will still provide you with treatment.

TREATMENT: We will use PHI about you as a staff in order to provide you with appropriate health care and services such as ultrasounds, lab tests, counseling services, exams and procedures within our facility. We may use and disclose PHI about you to other health care providers in order to provide, coordinate or manage your health care and related services. We may use and disclose PHI about you in order to access health related supplies or services for you. For example, we may phone in a prescription to a pharmacy or schedule a mammogram on your behalf. We may use and disclose PHI about you when referring you to another health care provider for treatment. For example, we may send a report to a physician we refer you to for specialized care following an abnormal test result so that the other physician may have accurate information in order to treat you.

PAYMENT: We may use and disclose your PHI so that we can bill and collect payment for the treatment and services provided to you. Before providing treatment or services, we may share details with your health plan concerning the services you are scheduled to receive. For example, we may use and disclose your PHI to find out if your health plan will cover the cost of your scheduled services and whether you will need a referral from your primary physician. After providing treatment or services, we may use and disclose PHI about you for insurance billing, claims management, and collection activities. We may use and disclose PHI about you in order to satisfy your request for financial assistance for services you have scheduled. For example, if we have solicited financial resources for you from one or more funding organizations, we may disclose your PHI to secure your funding and to collect payment from the funding organization once your services have been provided. We may disclose limited PHI about you to consumer reporting agencies relating to collection of payments owed to us. We may also disclose PHI to another health care provider or to a company or health plan required to comply with the HIPAA Privacy Rule for the payment activities of that health care provider, company, or health plan. For example, we may allow a health insurance company to review PHI for the insurance company’s activities to determine the insurance benefits to be paid for your care.

HEALTH CARE OPERATIONS: We may use and disclose your PHI in the course of performing Heritage Clinic for Women business activities which are referred to as "health care operations". Health care operations include doing things that allow us to improve or maintain the quality of the medical care we provide and to address business related financial aspects relating to health care costs and provision of services.

In some situations, you have the opportunity to agree or object to certain uses and disclosures of your PHI without written authorization. If you do not object, then we may make these types of uses and disclosures of PHI.

• We may disclose PHI about you to a family member, close friend, or any other person identified by you if that information is directly relevant to the person’s involvement in your care or payment for your care.
• If you are present and able to consent or object or you have given consent or objection ahead of time, we may only use or disclose PHI about you if you do not object after you have been informed of your opportunity to object.
• If you are not present or you are unable to consent or object, we may exercise professional judgment in determining whether the use or disclosure of PHI about you is in your best interests. For example, if you are given medication during your visit that makes you unable to communicate normally with our medical staff, we may find it is in your best interest to give your prescriptions and other medical supplies or instructions to the friend or relative who brought you in for treatment.
• We may use or disclose PHI about you to notify a family member, close friend, or any other person identified by you of your location or medical condition. We also may coordinate with disaster relief agencies to make this type of notification.
• We also may use professional judgment and our experience with common practice to make reasonable decisions about your best interests in allowing a person identified by you to act on your behalf to pick up filled prescriptions, medical supplies, or other things that contain PHI about you.
• We may disclose PHI about you upon your request to solicit funding for services scheduled in our office.

Required By Law: We may use and disclose PHI as required by federal, state, or local law. Any disclosure must comply with the law and is limited to the requirements of the law. Michigan law requires us to provide documentation of every abortion to the Michigan Department of Community Health. This documentation requires us to share specific non-identifying information with the Office of Vital Statistics (i.e. your age, county, procedure type, date of service, etc.)

Public Health Activities: We may use or disclose your PHI to public health authorities or other authorized persons to carry out certain activities related to public health, including the following activities:

• To prevent or control disease, injury, or disability;
• To report disease, injury, birth or death;
• To report child abuse or neglect;
• To report reactions to medication or problems with products or devices regulated by the federal Food and Drug Administration or other activities related to quality, safety, or effectiveness of FDA-regulated products or activities;
• To locate and notify persons of recalls of products they may be using;
• To notify a person who may have been exposed to a communicable disease in order to control who may be at risk of contracting or spreading the disease; or
• To report to your employer, under limited circumstances, information related primarily to workplace injuries or illness, or workplace medical surveillance.

Abuse, Neglect, or Domestic Violence: We may disclose PHI in certain cases to proper government authorities if we reasonably believe that a patient has been a victim of domestic violence, abuse, or neglect.

Health Oversight Activities: We may disclose PHI to health oversight agencies responsible for monitoring the health care system, government health care programs, and compliance with certain laws. These activities may include, but are not limited to, audits, investigations, inspections, licensure and disciplinary activities.

Lawsuits and Other Legal Proceedings: We may use or disclose PHI when required by a court or administrative tribunal order. We may also disclose PHI in response to subpoenas, discovery requests, or other required legal process when efforts have been made to advise you of the request or to obtain an order protecting the information requested.

Law Enforcement: Under certain conditions, we may disclose PHI to law enforcement officials for the following purpose where the disclosure is:

• Related to a verbal, written or physical threat to our staff, our patients, or our facility.
• About a suspected crime victim if, under certain limited circumstances, we are unable to obtain a person’s agreement because of incapacity or emergency;
• To alert law enforcement of a death that we suspect was the result of criminal conduct;
• Required by law;
• In response to a court order, warrant, subpoena, summons, administrative agency request, or other authorized process;
• To identify or locate a suspect, fugitive, material witness, or missing person;
• About a crime or suspected crime committed at our office; or
• In response to a medical emergency not occurring at the office, if necessary to report a crime, including the nature of the crime, the location of the crime or the victims, and the identity of the person who committed the crime.

To Avert a Serious Threat to Health or Safety: We may use or disclose PHI about you in limited circumstances when necessary to prevent a threat to the health or safety of a person or the public. This disclosure can only be made to an individual who is able to help prevent the threat.

Coroners, Medical Examiner, Funeral Directors: We disclose PHI to a coroner or medical examiner to identify a deceased person and determine the cause of death. In addition, we may disclose PHI to funeral directors, as authorized by law so that they may carry out their jobs.

Organ and Tissue Donation: If you are an organ donor, we may use or disclose PHI to organizations that help procure, locate, and transplant organs in order to facilitate an organ, eye, or tissue donation and transplantation.

Research: We may use and disclose PHI about you for research purposed under certain limited circumstances. We must obtain a written authorization to use and disclose PHI about you for research purposes except in situations where a research project meets specific, detailed criteria established by the HIPAA Privacy Rule to ensure the privacy of PHI.

Specialized Government Functions: Under certain circumstances we may disclose PHI:

• For certain military and veteran activities, including determination of eligibility for veterans for veterans benefits and where deemed necessary by military command authorities;
• For national security and intelligence activities;
• To help provide protective services for the president and others;
• For the health or safety of inmates and others at correctional institutions or other law enforcement custodial situations for the general safety and health related to corrections facilities.

Workers’ Compensation: We may disclose PHI as authorized by workers’ compensation laws or other similar programs that provide benefits for work-related injuries or illness.

Disclosures required by HIPAA Privacy Rule: We are required to disclose PHI to the Secretary of the United States Department of Health and Human Services when requested by the Secretary to review our compliance with the HIPAA Privacy Rule. We are also required incertain cases to disclose PHI to you upon your request to access PHI or for an accounting of certain disclosures of PHI about you (those requests are described in Section III of the Notice).

Incidental Disclosures: We may use or disclose PHI incident to a use or disclosure permitted by the HIPAA Privacy Rule so long as we have reasonable safeguarded against such incidental uses and disclosures and have limited them to the minimum necessary information.

Limited Data Set Disclosures: We may use of disclose a limited data set (PHI that has certain identifying information removed) for the purposes of research, public health, or health care operations. This information may only be disclosed for research, public health, and health care operations purposes. The person receiving the information must sign an agreement to protect the information.

Right to Request Restrictions: You have the right to request additional restrictions on the PHI that we may use for treatment, payment and health care operations. You may also request additional restrictions on our disclosure of PHI about you to certain individuals involved in your care that otherwise are permitted by the privacy Rule. We are not required to agree to your request. If we do agree to your request, we are required to comply with our agreement except in certain cases, including where the information is needed to treat you in the case of an emergency. To request restrictions, you must make your request in writing to our Privacy Official. In your request, please include (1) the information that you want to restrict; (2) how you want to restrict the information (for example, provide information about cost of services rendered to a person you identify but not provide specific information about the services rendered) and (3) to whom you want those restrictions to apply.

Right to Receive Confidential Communications: You have the right to request that you receive communications regarding PHI in a certain manner or at a certain location. When initially setting up appointments and obtaining your personal information, we ask questions regarding where and how to contact you. For example, we ask, "If we needed to send you mail, should we send it in a Heritage Clinic for Women envelope or in a plain envelope?" If you have a request beyond these precautions, you must make your request in writing to our Privacy Official. You must specify how you would like to be contacted (for example, by regular mail to your post office box and not your home). We are required to accommodate only reasonable requests.

Right to Inspect and Copy: You have the right to request the opportunity to inspect and receive a copy of PHI about you in certain records that we maintain. This includes your medical and billing records, but does not include psychotherapy notes or information gathered or prepared for a civil, criminal, or administrative proceeding. We may deny your request to inspect and copy PHI only in limited circumstances. To inspect and copy PHI please contact our Privacy Official. If you request a copy of PHI about you, we may charge you a reasonable fee for the copying, postage, labor and supplies used in meeting your request.

Right to Amend: You have the right to request that we amend PHI about you as long as such information is kept by or for our office. To make this type of request you must submit your request in writing to our Privacy Official. You must also give us a reason for your request. We may deny your request in certain cases, including if it is not in writing or if you do not give us a reason for the request.

Right to Receive an Accounting of Disclosures: You have the right to request an "accounting" of certain disclosures that we have made of PHI about you. This is a list of disclosures made by us during a specified period of up to six years other than disclosures made: for treatment, payment, and health care operations; for use in or related to a facility directory; to family members or friends involved in your care; to you directly; pursuant to an authorization of you or your personal representative, or for certain notification purposed (including national security, intelligence, correctional, and law enforcement purposed) and disclosure made before April 14, 2003. If you wish to make such a request, please contact our Privacy Official identified on the last page of this Notice. The first list that you request in a 12-month period will be free, but we may charge you for our reasonable costs of providing additional lists in the same 12-month period. We will tell you about these costs, and you may choose to cancel your request at any time before costs are incurred.

Right to a Paper Copy of this Notice: You have a right to receive a paper copy of this Notice at any time. You are entitled to a paper copy of this Notice even if you have previously agreed to receive this Notice electronically. To obtain a paper copy of this Notice, please contact our Privacy Official at the location noted below.

V. PRIVACY OFFICIAL CONTACT INFORMATION