HIPAA

Effective August 2013

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

For inquiries, contact the JFCS Privacy Officer at the address listed at the end of this notice.

WHO WILL FOLLOW THIS NOTICE

This notice describes information about privacy practices followed by all JFCS employees.

YOUR HEALTH INFORMATION

This notice applies to the information and records we have about your health, health status, and the healthcare and services you receive at this office. We are required by law to maintain the privacy of protected health information and to provide individuals with notice of its legal duties and private practices (this notice) with respect to protected health information.. It will tell you about the ways in which we may use and disclose health information about you and describes your rights and obligations regarding the use and disclosure of that information. The JFCS staff will not use or disclose your protected health information except as described in this notice, or otherwise authorized by law.

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU

Jewish Family & Career Services (hereafter JFCS) provides a broad range of services through a wide variety of health and human service programs. If you receive services from a JFCS program, our staff may use your protected health information and disclose it to other health and human service programs and outside JFCS for the following purposes:

For Treatment: We may use health information about you to provide you with behavioral health, counseling and social services. We may disclose health information about you to social workers, office staff and other personnel who are involved in providing these services to you.

For example, information obtained by a social worker or counselor, or member of your health care team will be recorded in your record and used to determine the course of treatment that should work best for you. This information may be shared with other program staff if it is necessary to determine the most appropriate care for you.

For Payment: A bill may be sent to you or any private or public source of health coverage you have identified. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, treatment, and services provided. 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.

For Healthcare Operations: We may use and disclose health information about you in order to run the office and make sure that you and our other clients receive quality care. For example, members of a quality assurance team may use information in your health record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and service we provide.

For Appointment Reminders: We may contact you by mail or telephone if we need to reach you, for example to confirm or change an appointment.

For Marketing/Fundraising Activities: We may use information about you including your name, address, phone number, and the dates you received care in order to contact you to raise money for JFCS. If you do not wish to be contacted, notify the Director of Professional Service (DPS) at JFCS and indicate that you do not wish to be contacted.

Other Treatment, Programs, and Services: We may tell you about or recommend other treatment options that may be of interest to you. We may tell you about related programs or services that may be of interest to you.

Please notify us in writing (at the address listed at the end of this notice) if you do not wish to be contacted at a particular telephone number or address. JFCS will accommodate reasonable requests to communicate health information by alternative means or at an alternative address.

SPECIAL SITUATIONS

We may use or disclose health information about you without your permission for the following purposes, subject to all applicable legal requirements and situations:

To Avert a Serious Threat to Health or Safety. We may use and disclose health information about you when necessary to prevent a serious threat to your health and safety of the public or another person.

To Report Abuse, Neglect or Domestic Violence. We may notify government authorities if we believe you are a victim of abuse, neglect or domestic violence. We will do this only when specifically required by law or when you agree to this disclosure.

Required By Law. We will disclose health information about you when required to do so by federal, state or local law.

Research. We may disclose information to researchers when the information is de-identified or when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.

Military, Veterans, National Security and Intelligence. If you are or were a member of the armed forces, or part of the national security or intelligence communities, we may be required by military command or other government authorities to release health information about you. We may also release information about foreign military personnel to the appropriate foreign military authority.

Workers’ Compensation. We may release health information about you for workers’ compensation or similar programs if your condition was the result of a workplace injury for which you are seeking workers’ compensation.

Public Health Risks. We may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

Health Oversight Activities. We may disclose health information to a health oversight agency for audits, investigations, inspections, or licensing purposes. These disclosures may be necessary for certain state and federal agencies to monitor the healthcare system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order. Subject to all applicable legal requirements, we may also disclose health information about you in response to a subpoena.

Law Enforcement. We may release health information if asked to do so by a law enforcement official in response to a court order, subpoena, warrant, summons or similar process, subject to all applicable legal requirements.

Correctional Institution. Should you be an inmate of a correctional institution, we may disclose to the institution or agents thereof any health information necessary for your health and the health and safety of other individuals, or for the administration of the institution.

Coroners, Medical Examiners and Funeral Directors. With the possible exception of certain information concerning mental health disorders and/or treatment, drug & alcohol abuse and/or treatment, and/or HIV status (for which we may need your specific authorization or a court order), we are also permitted to provide some health information to the coroner or a funeral director, if necessary, after a client’s death, and/or to the appropriate organ procurement organization, if the client wished to make an eye, organ or tissue donation after their death.

Information Not Personally Identifiable. We may use or disclose health information about you in a way that does not personally identify you or reveal who you are.

Family and Friends. In certain circumstances, we are permitted to share a limited amount of information with persons who are close to you, so long as we allow you the opportunity to agree to or object to the disclosure. We may provide a limited amount of your health information to a family member, friend or other person known to be involved in your care or in the payment for your care, unless you tell us not to. For example, if you have told us that a family member is going to be paying for your co-payment, and that person calls to confirm that you attended a treatment session on a particular day, we may confirm for them that you attended and what the co-payment will be, unless you tell us not to. Unless you tell us otherwise, we may disclose certain limited information about you (your general condition, location, etc.) to your emergency contact or another available family member or person believed to be close to you, should you need to be admitted to the hospital, for example.

Business Associates. There are some services provided in our organization through contracts with business associates; for example, record storage, billing services, and vendors of computer software for client information systems. When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we’ve asked them to do. However, we require the business associate to appropriately safeguard your information.

OTHER USES AND DISCLOSURES OF HEALTH INFORMATION

We will not use or disclose your health information for any purpose other than those identified in the previous sections without your specific, written Authorization. We must obtain your Authorization separate from any Consent we may have obtained from you. If you give us Authorization to use or disclose health 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 information about you for the reasons covered by your written Authorization, but we cannot take back any uses or disclosures already made with your permission. If we have HIV or substance abuse information about you, we cannot release that information without a specific Authorization from you. In order to disclose these types of information for purposes of treatment, payment or healthcare operations, we will have to have your signed Authorization, which complies with the law governing HIV or substance abuse records.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU

You have the following rights regarding protected health information we maintain about you.

Right to Inspect and Copy. You have the right to inspect and copy your health information, such as counseling, social work and billing records that we use to make decisions about your care. You must submit a written request to the Director of Professional Service at JFCS in order to inspect and/or copy your health information. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other associated supplies, as allowed by state law. We may deny your request to inspect and/or copy in certain limited circumstances. If we deny your request, we will tell you, in writing, our reasons for the denial. If you are denied access to your health information, you may ask that the denial be reviewed. If such a review is required by law, we will select a licensed healthcare professional to review your request and our denial. The person conducting the review will not be the person who denied your request, and we will comply with the outcome of the review.

Right To Amend. If you believe health information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment as long as the information is kept by this office. To request an amendment, complete and submit a Medical Record Amendment/Correction Form to the Director of Professional Service at JFCS. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
(a) We did not create, unless the person or entity that created the information is no longer available to make the amendment.
(b) Is not part of the health information that we keep
(c) You would not be permitted to inspect and copy.
(d) Is accurate and complete.
Our written denial will state the reasons that your request was denied and explain your right to file a statement of disagreement with us. If you do not wish to do so, you may ask that we include a copy of your request form, and our denial form, with all future disclosures of that health information. We may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal.

Right to an Accounting of Disclosures. You have the right to request an accounting of disclosures. This is a list of the disclosures we made of health information about you for purposes other than treatment, payment and healthcare operations. To obtain this list, you must submit your request in writing to the Director of Professional Service at JFCS. It must state a time period, which may not be longer than six (6) years and may not include dates before 2006. Your request should indicate in what form you want the list (for example, on paper or electronically). We may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions. You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment or healthcare operations. You also have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for it, like a family member or friend.

We are Not Required to Agree to Your Request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.

To request restrictions, you may complete and submit the Request For Restriction On Use/Disclosure of Health Information to the Director of Professional Service at JFCS.

Right to Request Confidential Communications. You have the right to request that we communicate with you about health 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 may complete and submit the Request for Restriction on Use/Disclosure of Health Information And/Or Confidential Communication to the Director of Professional Service at JFCS. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to a 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. To obtain such a copy, contact the Director of Professional Service at JFCS.

CHANGES TO THIS NOTICE

JFCS will abide by the terms of the notice current in effect. We reserve the right to materially change this notice, and to make the revised or changed notice effective for health information we already have about you as well as any information we receive in the future. We will post a summary of the current notice in the office with its effective date at the top. You are entitled to a copy of the notice currently in effect. Should our privacy practices change, we will provide you with a revised notice at the time of your first appointment following the change or mail you a copy to the address you have supplied us if you so request.

COMPLAINTS

If you believe your privacy rights have been violated, you can file a complaint with the Privacy Officer at JFCS.

JFCS Privacy Officer
2821 Klempner Way
Louisville, KY 40205
Phone: 502-452-6341
Fax: 502-452-6718

Or with the Secretary of the United States Department of Health and Human Services online or by mail to:

Region IV – Atlanta (AL, FL, GA, KY, MS, NC, SC, TN)
Roosevelt Freeman, Regional Manager
Office for Civil Rights
U.S. Department of Health and Human Services
Sam Nunn Atlanta Federal Center, Suite 16T70
61 Forsyth Street, S.W.
Atlanta, GA 30303-8909
Voice Phone: (800) 368-1019
Fax: (404) 562-7881
TDD: (800) 537-7697

You will not be penalized for filing a complaint.