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PRIVACY POLICY

HOSH Surgery Affiliates is committed to ensuring the privacy and security of protected health information. Federal laws and regulations pertaining to the Health Insurance Portability and Accountability Act (HIPAA) have established standards with which health care organizations must comply to maintain the security and confidentiality of protected health information (PHI). To support our commitment to security of patient health information, all employees of HOSH Surgery Affiliates will receive appropriate training as required under 45 CFR 164.308.

The HIPAA Privacy Rule regulates the use and disclosure of PHI by HIPAA-covered entities. The Privacy Rule defines PHI as all individually identifiable health information transmitted or maintained in any format, including paper and electronic records. The term "individually identifiable health information" means information, including demographic information, collected from an individual that: (1) is created or received by a health care provider, health plan, employer, or health care clearinghouse; (2) relates to either the past, present, or future physical or mental health or condition of an individual; the provision of health care to an individual; or the past, present, or future payment for the provision of health care to an individual; and (3) either identifies the individual, or there is a reasonable basis to believe the information can be used to identify the individual.

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.

INTRODUCTION

At HOSH SURGERY, we are committed to treating and using protected health information about you responsibly. This Notice of Health Information Practices describes the personal information we collect, and how and when we use or disclose that information. It also describes your rights as they relate to your protected health information. This Notice is effective April 14, 2003 and applies to all protected health information as defined by federal regulations.

UNDERSTANDING YOUR HEALTH RECORD/INFORMATION

Each time you visit HOSH SURGERY, a record of your visit is made. Typically, this record contains your 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 records, serves as a:
Basis for planning 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 can verify that services billed were actually provided,
A tool in educating health professionals,
A source of data for medical research,
A source of information for public health officials charged with improving the health of this state and the nation,
A source of data for our planning and marketing, and
A tool with which we can assess and continually work to improve the care we render and the outcome we achieve.

Understanding what is in your record and how your health information is used helps you to: ensure its accuracy, better understand who, what, when, where and why others may access your health information, and make informed decisions when authorizing disclosure to others.

YOUR HEALTH INFORMATION RIGHTS

Although your health record is the physical property of HOSH SURGERY, the information belongs to you. You have the right to:
Obtain a paper copy of this notice of information practices upon request,
Inspect and copy your health record as provided for in 45 CFR 164.524,
Amend your health record as provided in 45 CFR 164.528
Obtain an accounting of disclosures of your health information as provided in 45 CFR 164.528
Request communications of your health information by alternative means or at alternative locations,
Request a restriction on certain uses and disclosures of your information as provided by 45 CFR 164.522, and
Revoke your authorization to use or disclose health information except to the extent that action has already been taken.

OUR RESPONSIBILITIES

HOSH SURGERY is required to:
Maintain 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,
Notify you if we are unable to agree to a requested restriction, and
Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations

We reserve the right to change our practices and to make the new provisions effective for all protected health information we maintain. Should our information practices change, we will provide at the time of your next visit to the facility a revised notice.

We will not use or disclose your health information without your authorization, except as described in this notice. We will also discontinue to use or disclose your health information after we have received a written revocation of the authorization according to the procedures included in the authorization.

FOR MORE INFORMATION OR TO REPORT A PROBLEM

If you have questions and would like additional information, you may contact the facility's Privacy Officer at the number shown on the "Contact Us" page of this web site. Should you wish to file an anonymous complaint, contact the Compliance Hotline at 1-877-874-8415.

If you believe your privacy rights have been violated, you can file a complaint with the practice's Privacy Officer or with the Office for Civil Rights, U.S. Department of Health and Human Services. There will be no retaliation for filing a complaint with either the Privacy Officer or the Office for Civil Rights.

The address for the OCR is:
Office for Civil Rights
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Room 509F, HHH Building
Washington, D.C. 20201

EXAMPLES OF DISCLOSURES FOR TREATMENT, PAYMENT AND HEALTH OPERATIONS

We will use your health information for treatment.
Example: Information obtained by a nurse, physician, or other 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. Your physician will document in your record his or her expectations of the members of your health care team. Members of your health care team will then record the actions they took and their observations. In that way, the physician will know how you are responding to treatment.

We will also provide your physician or subsequent health care provider with copies of various reports that should assist him or her in treating you once you're discharged from this facility.
We will use your health information for payment
.
Example: A bill may be sent to you or a third-party payer. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, procedures, and supplies used.

We will use your health information for regular health operations.
Example: Members of the medical staff, the risk or quality improvement manager, or members of the quality improvement 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.

Business associates
There are some services provided in our organization through contacts with business associates. Examples include physician services in the emergency department and radiology, certain laboratory tests, and a copy service we use when making copies of your health record. When these services are contracted, we may disclose your health information to our business associates so that they can perform the job we've asked them to do and bill you or your third-party payer for services rendered. To protect your health information, however, we require the business associate to appropriately safeguard your information.

Directory
Unless you notify us that you object, we will use your name, location in the facility, general condition, and religious affiliation for directory purposes. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name.

Notification
We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.

Communication with family
Health professionals, using their best judgment, may disclose to a family member, other relatives, close personal friend or any other person you identify, health information relevant to that person's involvement in your care or payment related to your care.

Research
We may disclose information to researchers when an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information, has approved their research.

Marketing
We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.

Fundraising
We may contact you as part of a fundraising effort.

Food and Drug Administration (FDA)
We may disclose to the FDA health information relative to adverse events with respect to food, supplements, product and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.

Workers compensation
We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law.

Public health
As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

Law enforcement
We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena.

Federal law makes provisions for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public.
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