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Privacy Statement

Carondelet Health Network

JOINT NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW PROTECTED HEALTH AND FINANCIAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.

Carondelet Health Network  and its Professional Staff members (“Carondelet”) are required to maintain the privacy of your health and financial information and to provide you with a notice of its legal duties and privacy practices.

Carondelet Health Network  and its staff have formed an Organized Health Care Agreement as set out in the HIPAA Privacy Regulations.  Carondelet will not use or disclose your protected health and financial information except as described in this notice.  This notice applies to all of the medical and financial records generated by Carondelet.  Carondelet may make authorized disclosure of information from the medical record electronically, and may also share data from another health care entity’s electronic medical record system, so long as the system is designated and operated with safeguards that ensure that only authorized disclosures are made. 

We are required to notify you in the event of a breach of your unsecured PHI.

EXAMPLES OF DISCLOSURES FOR TREATMENT, PAYMENT AND HEALTH OPERATIONS: 
The following categories describe the ways that Carondelet may use and disclose your protected health and financial information.

Treatment:  Carondelet will use your protected health and financial information in the provision and coordination of your healthcare.  Carondelet may disclose all or any portion of your protected health and financial information to your attending physician, consulting physician(s), nurses, technicians, medical students, and other health care providers who have a legitimate need for such information in the care and your continued treatment.  Different departments may share protected health and financial information about you in order to coordinate specific services, such as prescriptions, lab work and x-rays. Carondelet also may disclose your protected health and financial information to people outside of Carondelet who may be involved in your medical care after, your care delivery such as family members, clergy and others who provide services that are part of your care.  In addition, Carondelet may share your Health Information with a Health Information Exchange “HIE”, including but not limited to Health Information Network of Arizona ("HINAz") unless at the time of registration you request to "Opt Out" of sharing your information with this organization. If you elect to “Opt Out” of a specific Carondelet hospital, clinic, office or provider, your “Opt Out” status comprises all Carondelet hospitals, clinics, offices and providers.

Treatment Alternatives:  Carondelet may use and disclose your protected health and financial information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

Psychotherapy Notes: We must obtain your written authorization before we may use or disclose your psychotherapy notes, except for: use by the originator of the psychotherapy notes for treatment; use of disclosure by CHN, CMG or CSG for its own mental health training programs; or use or disclosure by CHN, CMG or CSGto defend itself in a legal action or other proceeding brought by the individual.

Family/Friends:  While you are receiving care at our facilities, you may have family or friends in your room or otherwise involved in your care. Carondelet and its providers may update you on your status and condition while family members or friends are with you. If you would prefer to receive care updates from the providers without family or friends in the room, please just let your nursing staff know so that we may maintain your privacy. Carondelet may also receive phone calls from family and friends requesting updates on your status. You have the right to notify us that you want to be a private or confidential patient. In that circumstance, Carondelet would not even acknowledge that you are a patient at our facilities and no information would be provided to a caller.    In addition, Carondelet may disclose protected health and financial information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, and location in such an emergency situation.

Payment:  Carondelet may release protected health and financial information about you for the purposes of determining coverage, billing, claims management, medical data processing, and reimbursement.  The information may be released to an insurance company for the coordination of benefits and to obtain payment under a contract of reinsurance, third party payer, member of the professional medical staff, or other entity (or their authorized representatives) involved in the payment of your medical bill and may include copies or excerpts of your medical record which are necessary for payment of your account.  For example, a bill sent to an insurance company that might include information that identifies you, your diagnosis, and the procedures and supplies used.

Routine Healthcare Operations:  Carondelet may use and disclose your protected health and financial information during routine healthcare operations, including quality assurance, utilization review, medical review, internal auditing, accreditation, certification, licensing or credentialing activities, medical research and educational purposes.

Phone Contacts:  Carondelet may use and disclose protected health and financial information to contact you as a reminder that you have an appointment for treatment, medical care at Carondelet or for an after-care follow-up questionnaire.

Hospital Directory:  Carondelet may include certain limited information about you in the Carondelet Directory while you are a patient at Carondelet.  This information may include your name, location at Carondelet, your general condition (e.g., fair, stable, etc.), and your religious affiliation.  This is so your family and friends can visit you at Carondelet and generally know how you are doing.  The directory information, except for your religious affiliation, may also be released to people who ask for you by name.  Your religious affiliation may be given to a member of the clergy, such as a priest, minister or rabbi, even if they don’t ask for you by name. If you do not want Carondelet to include your name in the hospital directory, you must notify us in writing.

Health Related Business and Services:  Carondelet may use and disclose your protected health and financial information to tell you of health-related benefits or services that may be of interest to you.  If you do not want this health –related and/or business services, you must notify Carondelet in writing.

Business Associates:  Carondelet may use and disclose certain protected health and financial information about you to business associates.  A business associate is an individual or entity under contract with Carondelet to perform or assist Carondelet in a function or activity, which necessitates the use or disclosure of protected health and financial information.  Examples of business associates, include, but are not limited to a copy service used by Carondelet to copy medical records, consultants, accountants, lawyers, medical transcriptions and third-party billing companies.  These business associates also have the obligation to protect the confidentiality of your protected health information.

Research:  Under certain circumstances, Carondelet may use and disclose protected health and financial information about you to researchers when their clinical research study has been approved by Carondelet’s Human Subjects Committee.  While most clinical research studies require specific patient consent, there are some instances where a retrospective record review with no patient contact may be conducted by such researchers.  For example, the research project may involve comparing the health and recovery of certain patients with the same medical condition who received one medication to those who received another.

Organ Procurement Organizations:  To the extent allowed by law, Carondelet may disclose your protected health information to organizations that obtain organs for the purpose of tissue donation and transplant.  For example, Carondelet is required to report a positive communicable disease test result, before or after transplantation to the medical director or executive director of the organization and the Donor Network of Arizona according to Donor Network of Arizona regulations.

Fundraising:   Carondelet may use protected health and financial information to contact you in an effort to raise money for Carondelet and its operations.  Carondelet may disclose certain protected health and financial information to the Carondelet Foundation so that the Foundation may contact you in raising money for Carondelet.  The information released would only be contact information, such as your name, address, phone number and the dates you received treatment or services at Carondelet.  We may communicate with you as part of our fundraising activities, but you have the right to opt out of receiving such communications. If you do not want Carondelet to contact you for fundraising efforts, you must notify Carondelet in writing.

Marketing:   We must obtain your written authorization before we may use or disclose your PHI for marketing purposes, except for face-to-face communications made by us to you or a promotional gift or nominal value provided by us to you. We must obtain your written authorization before we sell your PHI.

Regulatory Agencies:  Carondelet may disclose your protected health and financial information to a governmental oversight agency for activities authorized by law, including, but not limited to, licensure, certification, audits, investigations and inspections.  In addition, CHN may disclose your protected health information to certain private oversight health agencies such as the Joint Commission (JC).

Law Enforcement/Litigation:  Carondelet may disclose your protected health and financial information for law enforcement purposes as required by law or in response to a valid subpoena or court order.

Public Health: As required by law, Carondelet may disclose your protected health and financial information to public health or legal authorities charged with preventing or controlling disease, injury or disability.  For example, Carondelet is required to report the existence of a communicable disease, such as acquired immune deficiency syndrome (“AIDS”), to the Arizona State Department of Health Services to protect the health and well being of the general public.

Workers Compensation:  Carondelet may release protected health and financial information about you to your employer, your worker’s compensation carrier, and/or the appropriate industrial commission for workers’ compensation benefits or similar programs.

Military/Veterans:   Carondelet may disclose your protected health and financial information as required by military command authorities, if you are a member of the armed forces.

Inmates:  If you are an inmate of a correctional institute or under the custody of a law enforcement officer, Carondelet may release your protected health and financial information to the appropriate correctional institute or law enforcement official.

Required by Law:  Carondelet will disclose protected health and financial information about you when required to do so by law.  For example, Carondelet may disclose certain protected health and financial information to those persons who have a risk exposure related to a communicable disease, according to Arizona law.

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

Other Uses: Any other uses and disclosures not allowed by law or regulations will be made only with your written authorization. If you would ever like to revoke your permission, please notify the Privacy Officer in writing.

PATIENT HEALTH INFORMATION RIGHTS:
Although all records concerning your hospitalization and treatment obtained at Carondelet are the property of Carondelet, you have the following rights concerning your protected health and financial information.

Right to Confidential Communications: You have the right to receive confidential communications of your protected health and financial information by alternative means or at alternative locations.  For example, you may request that Carondelet only contact you at work or by mail.

Right to Request and Inspect a Copy: You have the right to request inspection and request a copy your protected health and financial information.  A reasonable fee will be charged for these services.

Right to Amend: You have the right to request an amendment to your protected health and financial information according to Carondelet policy.

Right to an Accounting: You have the right to obtain a statement of the disclosures of your protected health and financial information as provided by the HIPAA Federal Privacy Law and Regulations.  You have the right to one free accounting in a twelve-month period.

Right to Request Restrictions: You have the right to request restrictions on certain uses and disclosures of your medical record, protected health information as provided by the Federal Privacy Law.  Carondelet may decide not to honor your request, except for when you request that we not disclose information to your health plan about services for which you paid out-of-pocket in full. In those cases, we will honor your request, unless the disclosure is necessary for your treatment or is required by law.

Right to Receive Copy of this Notice: You have the right to receive a paper copy of this Notice upon request.

Right to Revoke Authorization: You have the right to revoke your authorization to use or disclose your protected health and financial information except to the extent that action has already been taken based on original authorization.  A written request to the Director of Health Information Management at Carondelet St. Mary’s, Carondelet St. Joseph’s or Holy Cross Hospitals.

FOR MORE INFORMATION OR TO REPORT A PROBLEM:
If you have questions and would like additional information, you may contact the Carondelet Health Network  Privacy Officer, Pat Wilson, at 520-872-4472.  If you believe your privacy rights have been violated, you may file a complaint with Carondelet or with the Secretary of the Department of Health and Human Services.  To file a complaint with Carondelet, please contact the Privacy Officer.  All complaints must be submitted in writing and sent to St. Mary’s Hospital, Medical Records- Privacy Officer, 1601 West St. Mary’s Road, Tucson AZ, 85745.  There will be no retaliation for filing a complaint.

CHANGES TO THIS NOTICE:
Carondelet will abide by the terms of this notice.  Carondelet reserves the right to change the terms and conditions of this notice at any time.