150 Glenwood Lane
Birmingham, AL 35242
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.Glenwood, Inc is required by a federal law, the Health Information Portability and Accountability Act (HIPAA), to provide you with this notice, which describes how we may use and disclose your protected health information to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law. This notice also describes your rights to access and control your protected health information. “Protected health information” is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health condition and related health care services.
We will abide by the terms of this Notice of Privacy Practices. We may change the terms of our notice, at any time. The new notice will be effective for all protected health information that we maintain at that time. Current notices will be posted on our website, http://www.glenwood.org/.
You may also request a copy of any notice from our Privacy Officer, April Richardson by e-mail or by phone at (205)790-1334.
I. Uses and Disclosures of Protected Health Information for Treatment, Payment and Healthcare Operations
When you receive care from Glenwood, Inc., we may use your protected health information (PHI), without your authorization, for treating you, billing for services and conducting our normal business (healthcare operations). Examples of how we may use your PHI include:
We maintain records of the care and services provided to you. We will use and disclose these records to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with a third party for treatment purposes. For example, we may disclose your PHI, as necessary, to a pharmacy to fill a prescription or to a laboratory to order a blood test.
We may use or disclose your PHI, without your authorization, as needed, so that the treatment and services you receive at Glenwood are billed to, and payment is collected from your health insurance provider or other third party payer. For example, we may communicate with your health insurance company prior to provision of service – to determine benefits and eligibility or to obtain pre-authorization approval. In order to receive payment, we may also disclose PHI to your health insurance company to demonstrate medical necessity or for utilization review.
C. Healthcare Operations
We may use or disclose your PHI, without your authorization, for our own healthcare operations. These uses and disclosures are necessary to run our agency and to make sure that our clients receive quality care. These operations may include such activities as quality improvement activities; employee review activities; training programs; accreditation, certification, licensing or credentialing activities; and review and auditing activities. We may also use or disclose your PHI to another covered entity, with whom we participate in an organized health care arrangement, for their healthcare operations. Glenwood, Inc. participates in an organized healthcare arrangement with Southern Pharmaceutical Services.
We may also use or disclose your PHI to tell you about health services and products that may benefit you or remind you of an appointment.
II. Uses and Disclosures That May be Made Without Your Authorization, but for Which you will have an Opportunity to ObjectA. Agency Directory
We maintain a limited agency directory within our residential treatment facilities for the purpose of allowing visitors and callers to locate you. This limited information will only be provided to individuals who ask for you by name.
When you are admitted to one of our residential treatment facilities, you will generally have an opportunity to object to being included in our agency directory. If you choose NOT to be included in the agency directory, your directory information will not be provided to persons asking for you by name, nor will you be identified as present at the facility.
We do not maintain a directory at any of our day or outpatient programs. If asked, we will not confirm orally, in writing, or through any other medium that your are or current of former client, with the exceptions listed below under “Persons Involved in Your Care”.
B. Persons Involved in Your Care
We may provide health information about you to someone who helps pay for your care. We may use or disclose your health information to notify or assist in notifying a family member, or any other person that is responsible for your care, of your location, general condition or death.
In limited circumstances, we may disclose your PHI to a family member, or other person, who is involved in your care. If you are physically present and have the capacity to make health care decisions, your PHI may only be disclosed with your agreement, to persons you designate to be involved in your care.
III. Uses and Disclosures That May be Made Without Your Authorization or Opportunity to ObjectA. When an Emergency Treatment Situation Exists
B. When Required by Law
C. When There are Risks to Public Health
1. To prevent, control, or report disease, injury or disability, as permitted by law
2. To report vital events such as birth or death as permitted or required by law
3. To collect or report adverse events and product defects with drugs and medical devices
4. To conduct public health surveillance, investigations, and interventions as permitted or required by law
5. To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease, as authorized by law
6. To report to an employer information about an individual who is a member of the workforce, as legally permitted or required
D. When Required to Report Suspected Abuse, Neglect or Domestic Violence
E. When Required to Conduct Health Oversight Activities
Oversight activities include government agencies that oversee the health care system, government benefit programs such as Medicare and Medicaid, other government programs regulating health care, and civil rights laws
F. When Required by Court Order
In certain circumstances, we may disclose your PHI in response to a subpoena to the extent authorized by state law. We will not provide this information without your authorization if the request is for records related to psychotherapy notes, substance abuse, or HIV status.
G. When Required for Law Enforcement Purposes
H. When Requested by Coroners, Funeral Directors or for Organ Donation, as Required by Law
I. When Required for Research Purposes
We may use or disclose your PHI for research when the use or disclosure has been approved by an Institutional Review Board that has reviewed the research proposal and research protocols to address the privacy of your protected health information.
J. When Required to Prevent or Lessen a Serious and Imminent threat to Your Health or Safety or to the Health and Safety of the Public
K. When Required for Specialized Government Functions Such as Intelligence and National Security
L. When Required to Comply with Workers’ Compensation Laws or Similar Programs
IV. Uses and Disclosures Which You Authorize
Other than as stated above in Sections II and III, Glenwood, Inc. will not disclose your health information without your written permission, called an “authorization”. You may revoke your authorization in writing at any time. If you revoke your authorization, we will not make any further uses or disclosures of your PHI under that authorization, unless we have already taken an action relying upon the uses or disclosures you have previously authorized.
V. Your Rights Regarding Your Healthcare Information
A. Right to Inspect and CopyYou have the right to request an opportunity to inspect or copy health information used to make decisions about your care. Usually, this would include clinical and billing records, but not psychotherapy notes.
You must submit your request in writing to our Privacy Officer at 150 Glenwood Lane, Birmingham, AL 35242. We may charge a fee for the cost of copying and/or mailing this information.
Under federal law, you may not inspect or copy certain information – for example, psychotherapy notes. Depending on the circumstances, you may have the right to have a decision to deny access reviewed.
B. Right to Amend
You may request an amendment of PHI about you for as long as we maintain this information. In certain cases, we may deny your request for an amendment. If we deny your request for amendment, you have the right to file a statement of disagreement.
You must submit your request for amendment in writing to our Privacy Officer. In this written request, you must also provide a reason to support the requested amendment(s).
C. Right to an Accounting of Disclosures
You have the right to request an accounting of disclosures of your protected health information made by Glenwood, Inc. This right applies to disclosures for purposes other than treatment, payment of healthcare operations, and other disclosures we are permitted to make without your authorization as described in this Privacy Notice.
You must submit your request for accounting in writing to our Privacy Officer. The request should specify the time period sought for the accounting. We are not required to provide accounting for disclosures that take place prior to April 14, 2003, nor for time periods exceeding six (6) years.
We will provide the first accounting you request without charge. Subsequent accounting requests will be subject to a reasonable fee for cost of production.
D. Right to Request Restrictions
You may ask us not to use or disclose certain parts of your protected health information for the purposes of treatment, payment, or health care operations. You may also request that we not disclose your health information to family members or others who may be involved in your care or for notification purposes, as described earlier in this Privacy Notice.
You must submit your request for restriction in writing to our Privacy Officer. The request must state the specific restriction requested and to whom you want the restriction to apply.
We are not required to agree to a restriction that you may request. If we do agree, we will honor your request, unless the restricted PHI is needed to provide you with emergency treatment.
E. Right to Request Confidential Communications
You have the right to request that we communicate with you about your health care only in certain ways. For example, you may request that we contact you only by e-mail.
You must submit your request for confidential communication in writing to our Privacy Officer. You do not need to give a reason for the request, but you must specify how or where you wish to be contacted.
We will accommodate all reasonable requests.
F. Right to Obtain a Paper Copy of this Notice
You have the right to obtain a paper copy of this Notice of Privacy Practices at any time.
You have the right to register a complaint with Glenwood, Inc. and to the Secretary of Health and Human Services, if you feel your privacy rights have been violated. You may present your complaint to Glenwood by contacting the Privacy Officer, either verbally or in writing, using the contact information listed below. You may present your complaint to the Secretary of HHS, using the contact information listed below.Glenwood will investigate all complaints and will not penalize or treat you any differently for filing a complaint.
VII. Contact Information
A. Glenwood’s contact person for all issues regarding privacy and your rights under the federal privacy standards is the Privacy Officer. Our Privacy Officer is April Richardson. You may reach her at the address and phone number listed below:
April M. Richardson, MSM, M.S.
Director-Compliance & Performance Improvement
150 Glenwood Lane
Birmingham, AL 35242
B. Direct all complaints to the Secretary of Health
and Human Services to the address listed below:
Region IV, Office of Civil Rights
Department of Health and Human Services
Atlanta Federal Center, Suite 3B70
61 Forsyth Street, S.W.
Atlanta, GA 30303—8909
VIII. Effective Date
This Notice is effective April 13, 2003