Circles of Care has adopted the following policies and procedures for protection of the privacy of the people we serve.

Our Obligation to You

We at Circles of Care respect your privacy. This is part of our code of ethics. We are required by law to maintain the privacy of “protected health information” about you, to notify you of our legal duties and your legal rights, and to follow the privacy policies described in this notice. “Protected health information” means any information that we create or receive that identifies you and relates to your health or payment for services to you.

Use and Disclosure of Information about You

Use and disclosure for treatment, payment and health care operations.

We will use your protected health information and disclose it to others as necessary to provide treatment to you. Here are some examples:

• Various members of our staff may see your clinical record in the course of our care for you. This includes clinical assistants, nurses, physicians and other therapists.
• It may be necessary to send blood or other samples to a laboratory for analysis to help us evaluate your medical condition.
• We may provide information to your health plan or another treatment provider in order to arrange for a referral or clinical consultation.
• We may contact you to remind you of appointments.

We will use or disclose your protected health information as needed to arrange for payment for service to you. For example, information about your diagnosis and the service we render is included in the bills that we submit to your health insurance plan. Your health plan may require health information in order to confirm that the service rendered is covered by your benefit program and medically necessary. A health care provider that delivers service to you, such as a clinical laboratory, may need information about you in order to arrange for payment for its services.

It may also be necessary to use or disclose protected health information for our health care operations or those of another organization that has a relationship with you. For example, our quality assurance staff reviews records to be sure that we deliver appropriate treatment of high quality. Your health plan may wish to review your records to be sure that we meet national standards for quality of care.

Our Policy:

We will ask your written permission to use or disclose your protected health information for treatment, payment or health care operations purposes, although we are not required to.

Emergencies. If there is an emergency, we will disclose your protected health information as needed to enable people to care for you.

Disclosure to your family and friends. If you an adult, you have the right to control disclosure of information about you to any other person, including family members or friends. If you ask us to keep your information confidential, we will respect your wishes.

Disclosure to health oversight agencies. We are legally obligated to disclose protected health information to certain government agencies, including the federal Department of Health and Human Services.

Disclosures to child or adult protection agencies. We will disclose protected health information as needed to comply with state law requiring reports of suspected incidents of child, elder, or disabled adult abuse or neglect.

Other disclosures without written permission.There are other circumstances in which we may be required by law to disclose protected health information without your permission. They include disclosures made:

• Pursuant to some court orders;
• To public health authorities;
• To law enforcement officials in some circumstances;
• To correctional institutions regarding inmates;
• To federal officials for lawful military or intelligence activities;
• To coroners, medical examiners and funeral directors;
• To researchers involved in approved research projects; and
• As otherwise required by law.

Other disclosures. We will follow the provisions of 42 CFR Part 2 governing disclosure of protected health information. Except for the circumstances described above, we will not disclose protected health information to a third party without your written permission of the individual or a court order. If a request for disclosure of your patient record is received, you will be contacted and asked whether you wish to authorize disclosure. If you refuse to authorize disclosure, or it is not possible for us to contact you in person, we will not disclose your information without a court order.

Disclosures with your permission. No other disclosure of protected health information will be made unless you give written Authorization for the specific disclosure.

Your Legal Rights

Right to request confidential communications. You may request that communications to you, such as appointment reminders, bills, or explanations of health benefits be made in a confidential manner. We will accommodate any such request, as long as you provide a means for us to process payment transactions.

Right to request restrictions on use and disclosure of your information. You have the right to request restrictions on our use of your protected health information for particular purposes, or our disclosure of that information to certain third parties. We are not obligated to agree to a requested restriction, but we will consider your request.

Right to revoke an Authorization. You may revoke a written Authorization for us to disclose your protected health information. The revocation will not affect any previous disclosure of your information.

Right to review and copy record. You have the right to see records used to make decisions about you. We will allow you to review your record unless a clinical professional determines that would create a substantial risk of physical harm to you or someone else or if the professional determines that it would not be in your best interest. A written report of examination and treatment may be provided in lieu of complete copies of your records, consistent with Florida statute 455.667(4).If another person provided information about to our clinical staff in confidence, that information may be removed from the record before it is shared with you. We will also delete any protected health information about other people.

At your request, we will make a copy of your record for you. We will charge a reasonable fee for this service.

Right to "amend" record. If you believe your records contains an error, you may ask us to amend it. If there is a mistake, a note will be entered in the record to correct the error. If not, you will be told and allowed the opportunity to add a short statement to the record explaining why you believe the record is inaccurate. This information will be included as part of the total record and shared with others if it might affect decisions they make about you.

Right to an accounting. You have the right to an accounting of some disclosures of your protected health information to third parties. This does not include disclosures that you authorize, or disclosures that occur in the context of treatment, payment or health care operations. We will provide an accounting of other disclosures made in the preceding six years. If requested by law enforcement authorities that are conducting a criminal investigation, we will suspend accounting of disclosures made to them.

Right to a paper copy of this Notice.You have the right to a paper copy of any Notice of Privacy Practices posted on our web site.

How to Exercise Your Rights

Questions about our policies and procedures, requests to exercise individual rights, and complaints should be directed to our Contact Person.

Our Contact Person is Bettie Grossman. She can be reached at 321-722-5236.

Personal representatives. A “personal representative” of a patient may act on their behalf in exercising their privacy rights. This includes the parent or legal guardian of a minor. In some cases, adolescents who are “emancipated minors” may make their own decisions about receiving treatment and disclosure of protected health information about them. If an adult is incapable of acting on his or her own behalf, the personal representative would ordinarily be his or her spouse or another member of the immediate family. An individual can also grant another person the right to act as his or her personal representative in an advance directive or living will.

Disclosure of protected health information to personal representatives/guardians may be limited in cases of domestic abuse, child abuse, elder abuse or disabled adult abuse.

Complaints

If you have any complaints or concerns about our privacy policies or practices, you may submit a Complaint to our Contact Person by phone, e-mail or fax. If you wish, you may submit the complaint in writing to the Contact Person.

You can also submit a complaint to the United States Department of Health and Human Services. Send your complaint to:

Office for Civil Rights
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Room 509F, HHH Building
Washington, D.C. 20201
OCR Hotlines-Voice: 1-800-368-1019

We will never retaliate against you for filing a complaint.

Effective Date

These policies and procedures are effective as of April 14, 2003

Joint Commission Information

The quality of care and safety of our patients is a priority at Circles of Care.

As a Joint Commission on Accreditation of Healthcare Organization accredited facility, we encourage you to share your concerns regarding quality of care or safety with hospital or facility management.

Please use the numbers listed below to contact the appropriate hospital or facility.