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Notice of Privacy Practices

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EFFECTIVE DATE: August 1, 2012

NOTICE OF PRIVACY PRACTICES

This Notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully. If you have any questions about this Notice, please contact the SCHS Privacy and Information Security Officer at (541) 706-7760 or toll-free at (877) 847-4535.

The law requires us to:

  • Make sure that your medical information is kept private;
  • Provide you with this Notice of our legal duties and privacy;
  • Practices with respect to medical information;
  • Follow the terms of this Notice.

The people bound by this Notice include:

  • All health care professionals authorized to enter information into your St. Charles Health System, Inc. ("SCHS") medical records;
  • All caregivers, physicians, employees, volunteers, independent contractors, trainees, students, non-staff clergy, and other personnel providing services in our hospitals, clinics and other facilities;
  • All providers affiliated with SCHS through participation in an organized health care arrangement, including members of our medical staff while they are practicing in our hospitals, clinics and other facilities.

The entities or businesses bound by this Notice include:

  • The inpatient and outpatient departments and units of St. Charles Bend, St. Charles Redmond, St. Charles Prineville, St. Charles Madras;
  • St. Charles Medical Group and its outpatient clinics, including St. Charles Anticoagulation Clinic, St. Charles Cancer Center, St. Charles Cardiothoracic Surgery, St. Charles Family Care, St. Charles Medical Supply, St. Charles Ob/Gyn, St. Charles Pulmonary Clinic, St. Charles Sleep Center and such other St. Charles clinics as may be established, from time to time;
  • St. Charles Foundation, Inc.;
  • St. Charles Health System, Inc. d/b/a SharedCare;
  • St. Charles Health System Group Health Plan;
  • Cascadia Insurance Company, Inc.;

These people, entities, sites and locations listed above may share medical information with one another for treatment, payment, healthcare operations, and other purposes described in this Notice.

While SCHS participates with some providers in an organized health arrangement for purposes of complying with the federal and state information privacy and security laws, SCHS does not employ or otherwise contract with many of these providers and, therefore, accepts no responsibility or liability for acts or omissions of such providers.

The Health Information Exchange

In addition to sharing medical information with the people and entities listed above, SCHS participates in a health information exchange. This exchange allows SCHS to share medical information with providers throughout Oregon, some of whom have no affiliation with SCHS. When you receive care or have your laboratory tests performed at SCHS facilities, your information is automatically shared through the health information exchange, unless you specifically request otherwise. Your rights to restrict the use and sharing of your medical information, and to discontinue the sharing of your medical information through the health information exchange, are described in the "Your Rights" portion of this Notice.

How we may use and disclose medical information

The following categories describe different ways that we use and disclose medical information. All the ways we use and disclose information fall within one of the categories listed below. However, not all uses and disclosures falling within each category are listed or described.

  • For Treatment. We may use medical information about you to provide you with medical treatment or services. We may disclose medical information about you to doctors, nurses, clergy staff, technicians, healthcare students, or other personnel who are involved in taking care of you at one of our facilities.
  • For Payment. We may use and disclose medical information about you so that the treatment and services you receive at our facilities may be billed to and payment may be collected from you, an insurance company or a third party.
  • For Health Care Operations. We may use and disclose medical information about you for our health care operations. These uses and disclosures are necessary to run our hospitals and facilities efficiently, ensure that our providers are rendering care safely, plan for future needs, and otherwise operate our business.
  • Appointment Reminders. We may use and disclose medical information to remind you of appointments for treatment or medical care at our facilities.
  • Treatment Alternatives. We may use and disclose medical information to identify and tell you about or recommend treatment options or alternatives that may be of interest to you.
  • Health-Related Benefits and Services. We may use and disclose medical information to identify and tell you about health-related benefits or services that may be of interest to you.
  • Fundraising Activities. We may disclose contact information such as your name, address, phone number and the dates you received treatment to the St. Charles Foundation so it may contact you for fundraising purposes. If you do not want to be contacted for fundraising efforts, you must notify us in writing at: St. Charles Foundation, 2500 NE Neff Road, Bend, OR 97701.
  • Patient Directory. We may include your name, location in the hospital, religious affiliation and/or general condition in our patient directory. We may release your location and general condition to individuals who ask for you by name, as well as to clergy members, even if they do not ask for you by name. If you do not want us to make these disclosures, then you must ask at registration to become an unlisted patient. Information about unlisted patients is still included in the directory, but it is not provided to visitors and family members who ask for it.
  • Individuals Involved in Your Care or Payment for Your Care. We may disclose medical information about you to a family member, friend, or other individual involved in your care or payment for your care, but only to the extent appropriate given that person's involvement in your care. For example, if you are unable to make health care decisions, then we may disclose your health care information to another, appropriate individual so that he or she can make the decision on your behalf. Unless you object, we may also disclose medical information about you to notify a family member, personal representative or any other person responsible for your care about your presence at SCHS, your general condition, or your death.
  • Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. All research projects are subject to a special approval process run by the Institutional Review Board. This review process governs patient safety and welfare and the privacy of your medical information.
  • Limited Data Set Information. We may disclose limited medical information to third parties for purposes of research, public health and health care operations. This limited data set will not include any information which could be used to identify you directly.
  • As Required By Law. We will disclose medical information about you when required to do so by federal or state laws and regulations.
  • Serious and Imminent Threat to Health or Safety. We may use and disclose medical information about you when necessary to prevent a serious and imminent threat to your health or safety or the health or safety of the public or another person.
  • Organ and Tissue Donation. If you are an organ donor, we may release medical information about you to organizations that handle organ procurement or organ, eye or tissue transplantation, or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.
  • Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by the military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authorities.
  • Workers' Compensation. We may release medical information about you for workers' compensation or similar programs that provide benefits for work-related injuries or illnesses.
  • Public Health Risks. We may disclose medical information about you for public health activities as required or authorized by state law. Some examples include disclosures made: o to prevent or control disease, injury or disability;
    • to report births and deaths; o to report child abuse or neglect; o to report reactions to medications or problems with products;
    • to provide notification of product recalls;
    • to provide notification of possible exposures to disease or risks of contracting or spreading a disease or condition;
    • to notify the appropriate government authorities of possible or suspected abuse, neglect or domestic
    • violence, but only if the potential victim consents to the disclosure or the disclosure is required by law.
  • Health Oversight Activities. We may disclose medical information about you to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
  • Lawful Subpoena, Court Order, or Lawsuits and Disputes. We may disclose medical information about you in response to a subpoena, court order, search warrant, or other investigative demand. In some circumstances, we must notify you and give you an opportunity to object to the disclosure before we release your medical information.
  • Law Enforcement. We may disclose medical information about you if asked to do so by a law enforcement official or other designated individual. Some examples include disclosures made:
    • in response to a court order, subpoena, search warrant, summons or similar process;
    • in response to a law enforcement officer's request for information needed to identify or locate a suspect, fugitive, material witness, or missing person;
    • in response to a law enforcement official's request for information about a victim or suspected victim of a crime, but only if the victim agrees or is unable to agree and we believe that disclosure is in the victim's best interests under the circumstances;
    • about a death that may be the result of criminal conduct;
    • about a crime or potential crime occurring at one of our facilities; and
    • in emergency circumstances to report a crime or details about a crime occurring outside of our facilities; 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 about you to a coroner or medical examiner or funeral director as required by or applicable to law.
  • National Security and Intelligence Activities. 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 United States President, other authorized persons, or foreign heads of state, or conduct special investigations.
  • Inmates. We may release medical information about you to any correctional institution or law enforcement official having legal custody of you. Some examples include disclosures necessary (1) for the institution to provide you with health care; (2) for the health and safety of you or others; or (3) for the safety and security of the correctional institution.
  • Disaster Relief. We may disclose medical information about you to an entity assisting in a disaster relief effort (for example, the Red Cross) so that your family can be notified about your condition, status and location.
  • Other Use of Medical Information. All other uses and disclosure of medical information not covered by this Notice or the law that apply to us will be made only with your written authorization. At any time, you may revoke any authorization that you have given us. After receiving your signed revocation authorization, we will stop using or disclosing your medical information for the purposes identified in your authorization. However, we will not be able to undo any uses or disclosures we made before receiving your revocation.

USES AND DISCLOSURES OF SPECIALLY PROTECTED INFORMATION

Oregon and federal law provide additional confidentiality protections in some circumstances and may require your specific authorization for release.

YOUR RIGHTS REGARDING MEDICAL INFORMATION.

You have the following rights regarding medical information we maintain 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. Usually, this information includes medical and billing records, but does not include psychotherapy notes. Copies of records may be provided to you in an electronic or paper format depending on your request and the technology in which the records are maintained. There is a charge for the cost of copying, mailing or other supplies associated with your request. To request a copy of your medical record, please contact Health Information Management (HIM) at (541) 706-7784.
  • Right to Amend. If you feel that your medical information is incorrect or incomplete, you may ask us to amend the information. To exercise this right, you must contact the Privacy and Information Security Officer at 541-706-7760 to obtain an amendment form. You must then submit your request on the form in writing. We will put any denial in writing and explain our reason for denial. You have the right to respond in writing to our explanation of denial. You also have the right to request that the denial, and a statement of disagreement, if any, be included in future releases of your medical record.
  • Right to an Accounting of Disclosures. You have the right to request an accounting of disclosures we made of your medical information in the previous six years. You are not entitled to an accounting of disclosures made for purposes of treatment, payment and health care operations, disclosures you authorized, disclosures to you, incidental disclosures, disclosures to family or other persons involved in your care, disclosures to correctional institutions and law enforcement in some circumstances, disclosures of limited data set information or disclosures for national security or law enforcement purposes. To exercise your right to an accounting of disclosures, you must contact the Privacy and Information Security Officer at 541-706-7760 to obtain an accounting form. You must then submit your request on the form in writing.
  • Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information about you we use or disclose for treatment, payment or health care operations. You also have the right to request a limit on the medical information about you we disclose to someone who is involved in your care or the payment for your care, like a family member or friend. To exercise these rights, you must submit a written request to the Privacy and Information Security Officer. In your request, you must tell us: (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.
     
    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.
  • Restriction on Disclosure to Health Plan. You have the right to request that medical information about you not be sent to your health plan. Unlike other types of restriction requests, we will always agree to this request if you pay for the item or service at issue up front and in full and the relevant information would have been disclosed to a health plan for purposes of payment or health care operations (not treatment).
  • Restriction on Sharing With the Health Information Exchange. You have the right to request that medical information about you not be included in, or sent to, the health information exchange. To exercise this right, you must contact the Privacy and Information Security Officer at 541-706-7760 to obtain an opt-out form. You must then submit your request on the form in writing. Although opting out of the health information exchange will prevent your medical information from being shared through the exchange, it will not otherwise prevent your medical information from being used and disclosed in accordance with this Notice and the law.
  • 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. You must submit your request for confidential communication in writing at the time of your care. 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 the 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. You may request a copy by contacting any area where registration occurs, or by contacting the Privacy and Information Security Officer at 541-706-7760.

CHANGES TO THIS NOTICE

We may change the terms of the Notice at any time. If we change the Notice, we will post the new Notice in locations where patients receive services and on our Internet site www.stcharleshealthcare.org. Whenever there is a material change to the Notice, we will promptly distribute the revised version on or after its effective date.

COMPLAINTS

If you believe your privacy rights have been violated, you may contact or file a written complaint with the SCHS Privacy and Information Security Officer at 2500 NE Neff Rd, Bend, OR 97701.

If we cannot resolve your concern, you may file a written complaint with the Office of Civil Rights, U.S. Department of Health & Human Services, 90 7th Street, Suite 4-100, San Francisco, CA 94103, 1-800-368-1019, or 1-800-537-7697(TDD).

Your privacy is one of our greatest concerns and we will not penalize or retaliate against you in any way if you choose to file a complaint.

OTHER USES OF MEDICAL INFORMATION.

Uses and disclosures of medical information not covered by this Notice or the laws that apply to us will be made only with your written permission. 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 cannot undo 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.

PRIVACY/INFORMATION SECURITY AND CONTACT PERSON:

If you have any questions about this Notice or wish to object or complain about any use of disclosure as explained above, please contact our Privacy and Information Security Officer at:

Compliance & Privacy Officer
St. Charles Health System
2500 NE Neff Road
Bend, OR 97701
(541) 706-7760
privacyofficer@stcharleshealthcare.org