Notice of Privacy Practice

THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

We are required by law to:

·         Make sure that medical information that identifies you is kept private

·         Give you this Notice of our legal duties and privacy practices with respect to medical information about you

·         Notify you if your medical information is used by or disclosed to an unauthorized person

·         Follow the terms of the Notice that is currently in effect

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU

The following categories describe different ways we use and disclose medical information. For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

To You and Your Personal Representative: We may disclose your protected health information to you or your personal representative (someone who has the legal right to act for you).

For Treatment: We may use your medical information to provide you with medical treatment or services. We may disclose medical information about you to doctors, nurses, technicians, students, or other Health System personnel involved in taking care of you in the Health System (although we will request your consent to use substance abuse records and confidential/privileged communications with a social worker or licensed counselor for non-emergency situations). 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.

For Payment: We may use and disclose medical information about you so the treatment and services you receive at the Health System can be billed and payment may be collected from you, an insurance company or other third parties (although we will request your consent to use substance abuse records and confidential/privileged communications with a social worker or licensed counselor for non-emergency situations). For example, we may need to give your health plan information about surgery you received at the Health System so your health plan will pay us or reimburse you for the surgery. We may also 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. You have the right to pay for any services yourself (self-pay) and request that we do not give information regarding services you pay for yourself (self-pay) to your health plan, but it is your responsibility to inform other providers like pharmacies or your primary care physician not to share information about that service to your health plan.

For Health Care Operations: We may use and disclose medical information about you for Health System operations. These uses and disclosures are necessary to run the Health System and make sure that all of our patients receive quality care (although we will request your consent to use substance abuse records and confidential/privileged communications with a social worker or licensed counselor for non-emergency situations). For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also disclose information to doctors, nurses, technicians, students, and other Health System personnel for review and learning purposes. We may release information to an organization to assist us in evaluating the care that you receive. We may also combine medical information we have with medical information from other hospitals to compare how we are doing and see where we can make improvement in the care and services we offer.

Reminders: We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at the Hospital. We may also use and disclose medical information to contact you to remind you to refill a prescription if you use our pharmacy.

Treatment Alternatives: We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

Health Information Exchange:  We share your health records electronically through state and national health information exchanges for the purpose of improving the overall quality of healthcare services provided to you, including avoiding unnecessary duplicative testing, and for public healthcare research and initiatives.  One of these exchanges is the Michigan Health Information Network (MiHIN).   The MiHIN regulates access to, use, and disclosure of the health information.  You may be able to “opt out” of having your records being disclosed by MiHIN by contacting it at 120 West Saginaw Hwy., East Lansing, MI 48823 (Tel. 517-336-2430).

Health-Related Benefits and Services: We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

Marketing and Fundraising Activities: As a nonprofit community health system, we may use certain information about your care to contact you in an effort to raise funds for NOCHS, or to advise you of products or services that may interest you. You have the right to opt out of receiving such communications.

Facility Directory: We may include certain limited information about you in the facility directory while you are staying with us. You may tell us you do not want the information included. This information may include your name, location in the facility, your general condition (e.g., fair, stable, etc.) and your religious affiliation. The directory information may be released to people who ask for you by your full name.

Individuals Involved in Your Care or Payment for Your Care: We may release medical information about you to a friend or family member who is involved in your medical care. We may also give information to someone who helps pay for your care. We may also tell your family and friends your general condition and that you are in the Health System if they ask about you by your full name. We may also use a code protocol, where you may give a code to family members or friends you want to have medical information about you. You have the right to request that we do not release medical information about you to certain individuals.

To Avert a Serious Threat to Health or Safety: We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety and the safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat (i.e. law enforcement).

For Special Purposes: We may disclose medical information about you for special purposes as permitted or required by law, including the following:

·         Community/Public Health Activities and Reports such as disease control, abuse, or neglect, (except that information regarding HIV/AIDS will not be disclosed without consent or a court order), and health and vital statistics.

·         Administrative Oversight for such things as audits, investigations, licensure, or determining cause of death.

·         Court Orders or Other Legal Processes related to law enforcement activities, including custody of inmates, legal actions, or national security activities.

·         Military and Veteran Reporting on members of the Armed Forces of the U.S. or foreign military as required by military command authorities.

·         Organ and Tissue Donation and Transplant Reports when required by regulatory organizations as necessary to facilitate organ or tissue donation and transplant.

·         Workers’ Compensation or Other Rehabilitative Activities reporting as required by law or insurers in order to provide benefits for work-related or victim injuries or illnesses.

Law Enforcement: If asked to do so by a law enforcement official, we may disclose medical information:

·         To identify or locate a suspect, fugitive, material witness, or missing person;

·         About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s consent;

·         About a death we believe may be the result of criminal conduct;

·         About criminal conduct at any of the Health System’s locations;

·         In emergency circumstances, to report a crime, the location of the crime or victims, or the identity, description or location of the person who committed the crime.

Coroners, Medical Examiners, and Funeral Directors: We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information about patients to funeral directors as necessary to carry out their duties.

National Security and Intelligence Agencies: We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Protective Services for the President and Others: We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state, or to conduct special investigations.

Inmates: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or law enforcement official as necessary for the institution to provide you with health care, to protect your health and safety or the health and safety of others, or for the safety and security of the correctional institution.

OTHER USES OF HEALTH INFORMATION: Other uses and disclosure of medical information not covered by this Notice or the laws that apply to us will be made only with your written authorization. If you provide us an authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by the written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization and that we are required to retain our records of the care that we provide to you.

YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU

Right to Inspect and Copy: You have the right to inspect and copy medical information that may be used to make decisions about your care. To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to Health Information Manager at 1309 Sheldon Rd., Grand Haven, MI 49417. If you request a copy of the information, we may charge a reasonable fee for the costs of copying, mailing or other supplies associated with your request.

Right to Amend: If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to add a statement to your medical record. To request an amendment, your request must be made in writing and submitted to Health Information Manager at 1309 Sheldon Rd., Grand Haven, MI 49417. In addition, you must provide a reason that supports your request.

Right to an Accounting of Disclosures: You have the right to request an accounting of certain disclosures. This is a list of the disclosures we have made of medical information about you. To request this list of accounting disclosures, you must submit your request in writing to Health Information Manager at 1309 Sheldon Rd., Grand Haven, MI 49417. Your request must state the time period for the accounting, which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list.

Right to Request Restrictions: You have the right to request a restriction or limitation on the medical information we use or disclose about you. We will comply with your request unless the information is needed to provide you with emergency treatment, the release is required for a transfer to another health care facility, as required by law or third party payment contract, or as permitted or required under the Health Insurance Portability and Accountability Act (HIPAA) (1996), as amended, Public Law 104-191, or related regulations. To request restrictions, you must make your request in writing to Health Information Manager at 1309 Sheldon Rd., Grand Haven, MI 49417.

Right to Request Confidential Communications: You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request at the time of your admission and/or at the time of registration. We will not ask you the reason for your request.

Right to Paper Copy of this Notice: You have the right to a paper copy of this Notice. You may ask us to give you a copy of this Notice at any time. Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy of this Notice.

CHANGES TO THIS NOTICE

We reserve the right to change this Notice at any time. We reserve the right to make the revised or changed Notice effective for medical information we already have about you as well as any information we receive in the future. The Notice currently in effect will be posted in public areas within the Health System. In addition, the next time you register at or are admitted to the Health System for treatment or health care services as an in-patient or out-patient, we will offer you a copy of the Notice currently in effect.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with the Health System or with the Secretary of the Department of Health and Human Services. To file a complaint with the Health System, you must submit your complaint in writing to 1309 Sheldon Rd., Grand Haven, MI 49417. If you wish to discuss your complaint, you may call the Patient Satisfaction Director at 616-847-5569. You will not be retaliated against in any way for filing a complaint.

North Ottawa Community Health System is committed to protecting medical information about you. This Notice describes the Health System’s privacy practices and that of all its departments and units, all employees, staff, volunteers, other Health System personnel, and services of the Health System. Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your medical information created in the doctor’s office or clinic.

For further information about this Notice, you may contact the Privacy Officer at 616.847.5390.

Effective Date of this Notice: 03/09/21