Notice of Privacy Practices, Long Version

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.

If you have questions and would like additional information, you may contact the Privacy Contact for the Health Department, Kim White R.N. at 922-2746.

The Health Insurance Portability and Accountability Act of 1996 ("HIPAA") is a federal program that requires that all medical records and other health information we collect be kept confidential. This Act gives you significant new rights to understand and control how your health information is used. HIPAA provides penalties for misuse of personal health information. We are required under HIPAA to give you a Notice of Privacy Practices.

Understanding Your Health Record/Protected Health Information

Each time you visit the Health Department; a record of your visit is made. Typically, this record may contain your health history, coordination of care, symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment.

This information, often referred to as your health or medical record, is also called your Protected Health Information. This record serves as a:

• Basis for planning the coordination of your care and treatment
• Means of communication among the many health professionals who contribute to your care
• Legal document describing the care you received
• Means by which you or a third-party payer (like insurance) can verify that services billed were actually provided
• Tool in educating health professionals
• Source of data for medical research
• Source of information for public health officials
• Source of data for facility planning
• Tool with which we can assess and continually work to improve the care we give and the outcomes we achieve.

Understanding what is in your record and how your health information is used, helps you to:

• Better understand who, what, when, where, and why others may access your health information
• Ensure the accuracy of your record
• Make more informed decisions when authorizing disclosure (release of your protected health information) to others.

This Notice of Privacy Practices will describe how we may use and disclose your protected health information to carry out treatment, payment, and healthcare operations and for other purposes that are permitted or required by law.

Our Responsibilities

Grand Traverse County Health Department is required by law to:

• Maintain and protect the privacy of your health information
• Provide you with this notice as to our legal duties and privacy practices with respect to information we collect and maintain about you
• Abide by the terms of this notice currently in effect
• Notify you if we are unable to agree to a requested restriction
• Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.

We at the Health Department take confidentiality and privacy very seriously. Every employee is required to be trained in privacy and security policies, and must sign a confidentiality statement. We make every effort to maintain privacy with our written and oral communications. Written and electronic protected health information is kept in secure and private locations.

We will not use or disclose your health information without your authorization, except as described in this notice.

How we may use and disclose medical information about you

You will be asked by Health Department staff to sign an acknowledgment that you have been offered a Notice of Privacy Practices.

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

Treatment

We may use and disclose your protected health information to provide, coordinate, or manage your health care and any related services. Information obtained from you by Health Department staff, (in verbal, written, or electronic forms) will be recorded in your record and used to determine the plan of care that may work best for you. The staff will record the actions they take and their observations. For example: a clerk at the front desk may request personal identification information from you, then a nurse may obtain medical information, and later a Nurse Practitioner may examine you, all at the same visit. These staff members will share information in your record to create a plan of care. This written communication allows us to provide ongoing continuity of care. We may also provide a physician or a subsequent healthcare provider with copies of pertinent protected health information if needed to provide ongoing care, when we have the necessary permission from you.

Payment

Your protected health information will be used, as needed, to obtain payment for your health care services. For example, if you have Medicaid, we will need to disclose your health information to the Medicaid Program in order to be reimbursed for our services.

Healthcare Operations

We may use or disclose, as needed, your protected health information in order to support the activities of the Health Department. These activities include, but are not limited to, quality assessment and assurance activities, government health oversight activities authorized by State or Federal requirements, like audits, inspections, and licensure, and training of medical and nursing students.

For example, we may disclose your protected health information to medical or nursing school students that observe in our clinics or on home visits. They are required to sign our Health Department confidentiality statement to protect the privacy of your protected health information.

In addition, we may use a sign-in sheet at the registration desk areas where you will be asked to sign your name. We may also call you by name in the waiting room when our staff is ready to see you. We may use or disclose your protected health information, as necessary, to contact you to remind you of or reschedule your appointment.

We may share your protected health information with business associates that perform various activities for the Health Department. For example, the Health Department may send blood work to an outside laboratory, or may refer a client to have a chest x-ray at the hospital. Whenever an arrangement between our office and a business associate involves the use or disclosure of your protected health information, we will have a written contract that contains terms that will protect the privacy of your protected health information.

Others Involved in Your Healthcare

With your written consent, we may disclose your protected health information to a member of your family, a relative, a close friend or any other person you identify. We may also use or disclose your protected health information to an entity to assisting in disaster relief efforts so that your family can be notified about your condition, status, and location.

Emergencies

We may use or disclose your protected health information in an emergency treatment situation. The Health Department shall try to obtain your consent as soon as possible after such treatment.

Communication Barriers

We may use and disclose your protected health information if the Health Department staff attempts to obtain consent from you but is unable to do so due to substantial communication barriers and the staff determines, using professional judgment, that you intend to consent to use or disclosure under the circumstances.

Special Situations

We may use or disclose your protected health information in the following situations without your consent or authorization. These situations include the following:

Required By Law or Public Health Authority

• To prevent or control disease, injury or disability
• To report child abuse or neglect
• To report reactions to medications or problems with products
• To notify a person who may have been exposed to a communicable disease or may be at risk for contracting or spreading a disease or condition
• To notify the appropriate government authority if we believe a client has been the victim of abuse, neglect or domestic violence
• To share immunization records with private physicians, schools, parents, and legal guardians

Law Enforcement/ Legal Proceedings

We may release protected health information if asked to do so by a law enforcement official in response to a court order, subpoena, warrant, summons, or similar process.

Coroners, Medical Examiners, and Funeral Directors

We may disclose protected health 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 protected health information to funeral directors as necessary to carry out their duties.

Military and Veterans

If you are a member of the armed forces, we may release protected health information about you as required by military command authorities. We may also release protected health information about foreign military personnel to the appropriate foreign military authority.

National Security and Intelligence Activities

We may release protected health information about you to authorized federal officials for intelligence, and other national security activities authorized by law.

Workers' Compensation

We may disclose your protected health information to comply with workers' compensation laws and other similar programs. These programs provide benefits for work-related injuries or illness.

Inmates

If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release protected health information about you to the correctional institution or law enforcement official.

Required Uses and Disclosures

Under the law, we must make disclosures about you when required by the Secretary of the Department of Health and Human Services to investigate or determine our compliance with the requirements of the Privacy Rules.

Other Uses of Protected Health Information

Other uses and disclosures of protected health information not covered by this notice or the laws that apply to us will be made only with your written permission. Specific authorization is required for release of information regarding mental health, substance abuse, and HIV/AIDS issues. If you provide us permission to use or disclose medical information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

Your Health Information Rights

Although your health record is the physical property of the Health Department, the information belongs to you. The following is a list of your rights with respect to your protected health information and a brief description of how you may exercise these rights.

You have the right to inspect and copy your protected health information.

This means you may inspect and obtain a copy of protected health information about you from your record for as long as we maintain it. Usually this includes medical and billing records, but does not include psychotherapy notes, or records involved in civil or criminal action. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional will review your request and the denial. The person conducting the review will not be the same person who denied your request. We will comply with the outcome of the review. To inspect and copy medical information from your record, you must submit your request in writing to the Privacy Contact. The Privacy Contact will then arrange an appointment with you to inspect and copy your records. The Health Department may provide the information requested in summary form, and may also charge a fee for copying records. Please contact the Privacy Contact if you have questions about access to your medical record.

You have the right to request a restriction of your protected health information.

This means you may ask us not to use or disclose any part of your protected health information in your record for the purposes of treatment, payment or healthcare operations. The Health Department is not required to agree to a restriction that you may request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment. With this in mind, please submit any restriction you wish to request in writing to the Privacy Contact.

You have the right to request to receive confidential communications from us by alternative means or at an alternative location.

For example, this means that you have the right to request that we communicate with you in a certain way or at a certain location. We will accommodate reasonable requests. We will not ask the reason for your request. You may make this request by contacting Health Department staff, who will note this in your record.

You have the right to amend your protected health information.

If you feel that information we have about you is incorrect or incomplete, you may ask us to amend the information. Demographic information about you like your name, address, or telephone number can be changed, but medical information about you cannot be changed or deleted, only amended. You have the right to request an amendment for as long as the information is kept by the Health Department. This request must be made in writing and submitted to the Privacy Contact, and include a reason that supports your request. In certain cases we may deny your request. Please contact the Privacy Contact if you have any questions about amending your record.

You have the right to receive an accounting of certain disclosures we have made, if any, of your protected health information.

This is a list of the disclosures we made of your protected health information for purposes other than treatment, payment or healthcare operations. It excludes disclosures we may have made to you. You must submit a request in writing to the Privacy Contact. Please contact the Privacy Contact if you have questions about disclosures.

You have the right to obtain a paper copy of this notice from us.

You have the right to receive 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. You may obtain a copy of this notice on our website at www.grandtraverse.org. To