Allegiance Health

Notice of Privacy Practices

Allegiance Health

Organized Health Care Arrangement - Privacy Notice

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

Who Will Follow This Notice

This notice describes our Hospital’s practices and the practices of the following independent health care providers who are collaborating in this organized health care arrangement, solely for the purpose of coordinating the protection of your right to privacy: 

• Allegiance Health (“Hospital”) and all of the Hospital’s facilities that are located on and off the Hospital’s main campus. 
• All members of the Hospital medical staff and other health care providers who provide services at the Hospital or use the Hospital to provide treatment to their patients. These physicians include your personal doctor and any physician that your doctor asks to assist with your care while you are receiving treatment or services. 
• Allegiance Hospice.

Hospital staff, physicians and other health care providers who care for you will follow the terms of this notice, and may share your medical information with each other for treatment, payment or health care operation purposes related to this organized health care arrangement. 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 your medical information. * Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your medical information that is created in the doctor’s office or clinic.

Our Responsibilities 

We Are Required By Federal Law To: 

• Keep all of your protected health information private; 
• Give you a copy of this notice that states our legal duties and notifies you of our privacy practices with respect to your protected health information; and 
• Abide by the terms of the notice that is currently in effect.

How We May Use or Disclose Your Personal Health

Uses or disclosures of health information for treatment, payment and health care operations:

Hospital staff, physicians and other health care providers participating in this organized health care arrangement, may use your individually identifiable health information for treatment, payment and health care operations. We will obtain your consent before we use or disclose your medical information for treatment, payment or health care operations, except in an emergency, when you are prohibited from withholding your consent, or in other situations when we are permitted by law to use or disclose it for such purposes without your consent. In some circumstances, we will assume you consent if you do not object. Some examples of treatment, payment and health care operations include: 

• “Treatment” - We may disclose medical information about you to members of our workforce, including doctors, nurses, technicians, students, volunteers, pharmacists, or others who are involved in taking care of you in order to provide for your health care needs. This could include consulting with or referring your case to another health care provider. 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. The doctor may need to tell the dietitian you have diabetes, so that we can arrange for appropriate meals. 
• “Payment” - We may use and disclose medical information about you so that we can obtain payment for the health care services that were provided to you. This could include billing and disclosing your medical information to a third party, like your insurance company, Medicare or Medicaid. For example, we may need to give your health plan information about surgery you received at the Hospital so your health plan will pay us or reimburse you for the surgery. We may also need to 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 disclose some of your medical information to a collection agency if we are unable to obtain reimbursement from your or someone else who is responsible for paying for your care. 
• “Health Care Operations” - We may use and disclose medical information about you for Hospital operations. The Hospital’s health care operations include such things as conducting quality assessment and improvement activities, conducting training programs, conducting or arranging for medical review, legal services, creating and maintaining medical records, auditing and business planning and development. This includes use or disclosure of your medical information to administrators, physicians, nurses and others who are not directly involved in your care. These uses and disclosures are necessary to run the Hospital and make sure that all of our patients receive quality care. Below are several examples of how this information may be used or disclosed: 
• We may contact you by telephone or mail or use medical information from your record to review our treatment and services and evaluate the performance of our staff in caring for you.
• We may contact you by telephone or mail to ask if you would participate in a “focus group,” so that we can obtain information from community members about potential new services, treatments, or how we can improve or make the services we offer better. 
• We may combine medical information about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. 
• We may disclose information to doctors, nurses, technicians, students, volunteers and other Hospital personnel for review and learning purposes. 
• We may conduct audits of the of the billing process we use for you, an insurance company or another third party for health care services we provided to you. 
• We may use or disclose your health information from a previous visit, to make “registration” faster and more efficient for you, when you register for pre-admission and select outpatient procedures. 
• We may use and disclose health information about you to contact you as a reminder that you have an appointment for treatment or other health care. 
• We may use or disclose your health information, to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
• We may use and disclose your health information to tell you about health-related benefits or services that may be of interest to you. 
• We may contact you to ask for a contribution or help in raising funds for the Health System. 
• Business associates. Some of the health care services provided at the Hospital are obtained through contracts with “business associates”. These are companies or people who perform various treatment, payment or other health care operation activities on behalf of the Hospital. For example, the Hospital uses independent companies to provide physician services in the Department of Anesthesia, the Emergency Department, the Department of Radiology, the Department of Pathology (in the laboratory) and for certain other laboratory tests. The Hospital uses an independent company to assist with the Hospital’s contribution and access to the community wide electronic medical record system. We may also use a “copy service” to assist in making copies of requested health records. When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we have asked them to do. We disclose only the necessary information that these companies need to provide these services, and we require that they keep your information confidential and safeguard it while it is in their custody. 
• Providing Health Information to Your Doctor And Your Other Healthcare Providers. We will automatically incorporate your medical information into the community wide electronic medical record system and provide your primary care physician with electronic access to and/or copies of all laboratory, radiology and other test results, even if he or she did not order the test. We will also automatically provide your primary care physician with access to and/or copies of the treatment records from the Hospital, including records about Emergency Department, Urgent Care or Express Care Services you received, in order to assist your doctor with your continued care and treatment. 
• Hospital Directory. Unless you tell us not to, we will use your name, location in the facility, general condition, and religious affiliation for directory purposes. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name. 
• Communication with Family. Unless you tell us not to, health care providers, using their best judgment, may use or disclose information to notify or assist in notifying a family member, personal representative, or any person responsible for your care, about your location, and general condition. Unless you object, health care providers may also, use their best judgment and disclose to a family member, other relative, close personal friend or any other person that you identify, health information important to that person’s involvement in your care or payment related to your care. This includes using their professional judgment to reasonably assume that it is in your best interest to allow a person to act on your behalf to pick up filled prescriptions, medical supplies, X-rays and other similar forms of protected health information.

Other Uses and Disclosures that are Permitted or Required By Law

Federal and state laws either permit or require us to use or disclose medical information about our patients without their consent for several other reasons. We may disclose your medical information for one or more of these purposes.

Public Health Disclosures

We are required to make certain reports to the state or local public health authorities for the purpose of preventing or controlling disease, injury or disability, including the reports of births, deaths and certain types of injuries or diseases.

We report problems with drugs and medical products we use to the Food and Drug Administration or to the manufacturer so they can assess the quality, safety and effectiveness of their products.

We notify certain persons, such as ambulance personnel, other emergency responders and Hospital personnel, who may be exposed to a patient’s infectious agents (such as HIV) of the results of any test we perform to find out the patient’s infectious status. We also notify funeral directors of the infectious status of decedents. 

Suspected Abuse and Neglect

We report patients that we suspect are victims of abuse or neglect to the appropriate government authorities. 

Health Oversight Activities

We disclose patient information to governmental regulatory agencies so that they can determine that the Hospital complies with state and federal licensing standards and other regulatory requirements. 

Legal Mandates

We disclose patient information any time we are required to by state or federal statute or other government functions. For example, we are required to report any person who comes to the Hospital with a wound inflicted by deadly weapon or violent means (such as a knife or gunshot wound), to the police. Other examples include releasing information when we are required to do so for national security purposes, disaster relief, review of our activities by government agencies, to avoid a serious threat to the health or safety of others, or in other kinds of emergencies.

We disclose other patient information to law enforcement officials only when required by law, such as to comply with warrants, subpoenas, or summonses that are issued by a judicial officer or other properly authorized investigative demand.

We disclose patient information in the course of any judicial or administrative proceeding, but only when ordered to do so by the court or administrative tribunal (such as a Workers Compensation Magistrate). 

For Research

We may use or disclose your information for research, if the research has been subjected to a careful review and approval process by a specially trained committee (Internal Review Board or Privacy Board). The review process evaluates the project and its use of medical information and balances the potential benefit of the research against our patient’s need for privacy of their medical information. 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. In that situation, the patients would not be identified, but their medical information may be used as long as the researcher keeps it confidential.

Other Purposes You May Authorize

In other situations, we will ask for your specific authorization before using or disclosing any identifiable medical information about you. If you choose to sign an authorization to disclose or release information, you can later revoke that authorization to stop any further uses and disclosures, except to the extent that we have already taken action in reliance on your authorization.

Your Rights

Federal and state law, protect your right to keep your individually identifiable health information private. 

Your Right To Inspect Or Receive A Copy Of Your Records.

Each facility to which this notice applies maintains separate records. In most cases, you have the right to look at or get a copy of medical information about you that we use at a facility, to make decisions about you. You must make this request in writing. 

Your Right To Receive Confidential Communications.

You have the right to request that we send communications to you from a facility in a confidential manner, such as at a different address than your home address. You must make this request in writing. You do not have to tell us why you are making this request. 

Your Right To Request Restrictions.

You may request other restrictions on how the Hospital or other facility uses and disclosures your protected health information for purposes of treatment, payment, and health care operations, including disclosures to persons involved in your care, except when specifically authorized by you, when required by law or in emergency circumstances. You must make this request in writing. We will consider your request, but are not required by law to agree to your request. 

Your Right To Correct Or Update (Amend) Your Medical Records.

You have the right to ask us to correct existing information or add missing information to your records at a facility, if you think there is a mistake or important information is missing. You must make this request in writing and provide a reason for your request. We will consider your request, but are not required by law to agree to your request if we think the record is correct and complete. 

Your Right To An Accounting.

You have the right to receive a list of the disclosures of your medical information at a facility that we have made without your written authorization for reasons other than for treatment, payment, or healthcare operations. 

The Right to Receive a Paper Copy Of This Notice.

If this Notice of Privacy Practices was sent to you electronically, you also have the right to request a paper copy of this notice. This Notice is also posted on our website at www.AllegianceHealth.org.

Please send your written requests to:

The Department of Health Information Management
Allegiance Health
205 N. East Avenue
Jackson, Michigan 49201

If you would like more information on how to exercise these rights, please contact the Hospital’s Privacy Officer at (517) 841-7850.

How to File a Complaint

If you are concerned that we have violated your privacy rights, or you disagree with a decision we made about access to your records, you may file a complaint with the Hospital and/or the U.S. Department of Health and Human Services. Under no circumstances will you be retaliated against for filing a complaint with the Hospital or the government. To file a complaint with Allegiance Health, please contact:

Privacy Officer
Allegiance Health
205 N. East Avenue
Jackson, Michigan 49201
Phone: (517) 841-7850

Changes to our Notice (Amendments)

We reserve the right to change our medical information and privacy practices at any time. Before we make any significant changes in our practices, we will change our notice and post the new notice at all admitting, registration, and other check-in points at the Hospital or our other facilities. We will also give you a copy of the revised notice upon your request. The new practice will then apply to any of your medical information that we already have and any additional information that we receive in the future. The revised Privacy Notice will also be available on Allegiance Health’s Web site which is located at www.AllegianceHealth.org.

This Notice of Privacy is effective as of June 23, 2008. If you should have any questions about this notice, please contact the Privacy Officer, by calling (517) 841-7850.