THE HILL AT WHITEMARSH

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.

PLEASE REVIEW IT CAREFULLY.

The Hill at Whitemarsh is committed to safeguarding the privacy and confidentiality of your health information including all records and information created and/or maintained at our organization. This includes any information we receive from other providers or facilities.  The Hill at Whitemarsh is required by law to:

  • Maintain the privacy of your protected health information
  • Provide you with a Notice as to our legal duties with respect to protecting the privacy of your personal health information and our privacy practices related to the use and disclosure of your protected health information.
  • Abide by the terms of this Notice including any future revisions as required or authorized by law.
  • Notify you of changes made to the Notice; we reserve the right to change this Notice and to make the revised or new Notice effective for all protected health information that we already maintain about you as well as information we may receive in the future. We will mail a revised Notice to the address you have provided to us.
  1. Your protected health information may be used and disclosed for treatment, payment and health care operations without needing to obtain your consent or authorization. For example:

For Purposes of Treatment: We may use and disclose your protected health information to personnel who may be involved in the management and coordination of your care such as physicians, nurses, therapists, dieticians, nurse aides, students in various health studies and other personnel throughout each level of care offered at The Hill at Whitemarsh. We may communicate with hospital staff and provide copies of various reports when transferred to and from acute care; or with home health agencies upon discharge, to ensure that such health care providers have the necessary information to diagnose and treat you.

For Purposes of Payment: We may use and disclose your protected health information so that we may bill and receive payment from you, an insurance company or other third party payer for the health care and other items and services you received at The Hill at Whitemarsh. When billing we may need to include protected health information that identifies you, as well as your diagnosis, procedures and supplies used.

For Purposes of Health Care Operations: We may use and disclose your protected health information as necessary for the day-to-day health care operations of the facility, including in connection with pre-admission and evaluation of potential applicants and for enrollment purposes, as well as in connection with resident transfers among the different levels of care offered at The Hill at Whitemarsh.  For example, protected health information from your medical record may be used by members of medical staff, risk or quality improvement team members to assess the care and outcomes of health care that is provided to you. This information is used in an effort to continually improve the quality and effectiveness of health care and services.  Your protected health information may be used and disclose your for treatment, payment and health care operations without needing

  1. The Hill at Whitemarsh may use and disclose your personal health information for other specific purposes, unless you revoke the release of your personal healthcare information in writing. If you revoke your authorization, we will no longer use or disclose your information as you specified, except where we have already acted upon your authorization. Other specific uses can include:

For purposes related to emergencies / disasters: Uses or disclosures in emergency / disaster situations to share information as necessary to identify, locate and notify family members, guardians, or anyone else responsible for the individual’s care of the in individual’s location, general condition or death.

Business Associates: Some services that we provide are contracted with business associates for example billing services companies and other service providers. When these services are contracted we may disclose your health information so that they may be able to deliver care and bill you or your third party payer for services rendered. To protect your information, however, we require the business associate to appropriately safeguard your protected health information.

The Hill at Whitemarsh Directory: We will use your name, photograph, and your location in the facility and your telephone number in our resident directories. The directory information may be given to people who ask for you by name.

Appointment reminders: Certain personal healthcare information may be used or disclosed to remind you of appointments.

Clergy: Certain limited information about you may be given to a member of the clergy such as your religious affiliation.

Fund Raising Activities: You may be contacted for fund raising activities for the facility and its operations. You will be given the opportunity to “opt out” (not participate) if you do not want to receive any further fundraising communications.

As Permitted by Law: Disclosures may be made about you to someone who has the legal right to act for you (personal representative), or to the Secretary of the Department of Health and Human Services, and where required, or permitted, by law for:

  • Oversight by State and Federal Agencies that may include audits and investigations, inspections or licensure and certification surveys.
  • Public Health Activities and Protective Services Agencies such as reporting fraud or suspected abuse or neglect; disease outbreaks, adverse reactions to medications, supplements or food, or problems with health care products.
  • Workers Compensation to the extent authorized by law related to workers compensation or other similar programs established by law.
  • Judicial and Administrative Proceedings as response to court orders, summons, warrants or subpoenas.
  • Law Enforcement Officials requests for the purpose to locate a missing person, a suspect, or material witness, to report criminal conduct on our premises or in an emergency to report the commission of a crime or imminent threat to health or safety of staff or residents.
  • Coroners, Medical Examiners, Funeral Directors or Organ Procurement Organizations for the purpose of identifying a deceased individual, to determine the cause of death, or facilitate organ or tissue donation. Also to provide funeral directors with information in order to carry out their duties.
  • National Security, Military and Veterans for purposes of intelligence, counterintelligence and other national security activities.
  • Decedent: disclosure to family members and others who were involved in the care or payment prior to death, unless it is inconsistent with your prior expressed preference.
  1. Your Authorization is required for all other uses of personal health information.

Except as described in this Notice or required by law, we will use and disclose personal health information only with your written Authorization.  Examples of disclosures that require your written authorization include disclosure of psychotherapy notes, use of your protected health information for marketing and disclosures that constitute a sale of protected health information. You may revoke your Authorization to use or disclose personal health information in writing, at any time. If you revoke your Authorization, we will no longer use or disclose your personal health information for the purposes covered by the Authorization, except where we have already relied on the Authorization.

  1. Your Rights regarding your protected health information:

Right of Notification of Breaches: We must notify you following a breach of your unsecured protected health information.

Right to Request Restrictions: You have the right to request a restriction or limitation on our use and disclosure of your protected health information. For example, you may ask us not to disclose your protected health information for purposes of treatment, payment or healthcare operations.  You may also request that any part of your protected health information not be disclosed to family members or friends who may be involved in your care or for notification purposes as described in this Notice of Privacy Practices.

Right to Receive Confidential Communication: We must accommodate your reasonable requests of communicating your protected health information by alternative means or at alternative locations. To request confidential communications, you must make your request in writing to the Compliance Officer on the form entitled “Resident Request to Restrict Use and Disclosure of Protected Health Information” and tell us how or where you wish to be contacted. You do not need to give us a reason for your request.

Right of Access to Protected Health Information: You have the right to inspect and obtain a copy of your medical information and billing records. This does not include psychotherapy notes.

Right to Request an Amendment: You have the right to request to amend your protected health information if you think it is wrong or incomplete, as long as the information is kept by or for The Hill at Whitemarsh. Your request for an amendment must be made in writing. Complete the form entitled “Resident Request to Amend Protected Health Information” and submit it to the Compliance Officer. We may deny your request if it is not in writing or does not include a reason to support the request.

Right to an Accounting of Disclosures: Subject to implementation of final regulations, you have the right to request a listing (account) of the disclosures of your protected health information that we made except for disclosures:

  • Made prior to April 14, 2013;
  • Made to carry out treatment, payment or health care operations;
  • Made to you or your personal representative;
  • Made pursuant to a valid and effective authorization (one that complies with the requirements of state law as well as with HIPAA) signed by you or your personal representative;
  • Made to persons involved in your care or other notification and location purposes;
  • To federal officials for national security or intelligence purposes;
  • To a correctional institution or law enforcement official that has custody of you;
  • That are part of a limited data set; and
  • To a health oversight or law enforcement official or agency provided the official or agency notifies us in writing that providing an Accounting of Disclosures to you would be reasonably likely to impede the official’s or agency’s activities.

To request a listing of disclosures you must submit your request in writing to the Compliance Officer on the form entitled “Resident Request for an Accounting of Disclosures of Protected Health Information” and state a time period (it cannot be earlier than six (6) years prior to the date of your request or include dates before April 14, 2003). You need to tell us in what form you want to receive the listing. For example: on paper or via electronic means.  You will not be charged for the listing of disclosures for the first time in a twelve (12) month period. You may be charged a reasonable, cost-based fee for any additional requests you make within the time frame and will be told the cost of each. You can decide whether to withdraw or modify your request before any costs are incurred.

Right to Receive a Paper Copy of this Notice: You may request a copy of this Notice even if you have agreed to receive this Notice electronically. To receive a paper copy of this Notice, contact the Compliance Officer.

  1. Complaints

If you believe that your privacy rights have been violated, you may file a complaint in writing to the Compliance Officer listed below at The Hill at Whitemarsh or with the Secretary of the Department of Health and Human Services. The complaint form may be obtained from the Compliance Officer. You will not be penalized or retaliated against in any way for filing a complaint.

The Hill at Whitemarsh
Compliance Officer
215-402-8500

The U.S. Department of Health and Human Services
Direct:  202-619-0257
Toll Free:  1-877-696-6775

  1. For Further Information

If you have any questions about this Notice or would like further information concerning your privacy rights, please contact the Chief Financial Officer, who is The Hill at Whitemarsh’s Chief Compliance Officer, at (215) 402-8500.

Effective September 23, 2013