NOTICE OF HIPAA 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 this notice carefully.

ABOUT THIS NOTICE:

In this notice we use the terms “we,” “us,” and “our” to describe Signature Healthcare at Home—a group of Affiliated Covered Entities (ACE) that are under common ownership and control of Signature Group, LLC.   This notice describes our privacy practices and that of any employees, contractors, students, and other personnel; any health care professional authorized to enter information into your medical record; any volunteer we allow to assist you; any entity which is part of the Signature ACE either now or in the future; and any other entity under contract to assist in providing care in a clinically integrated manner.   A list of the entities which form the Signature ACE can be found on our website (www.signaturehch.com).

In this notice, protected health information (PHI) refers to any medical or financial information that can be used to identify you, your health or condition, the provision of care to you or the payment for that care.  This notice summarizes the way in which we may use or disclose your protected health information and describes your rights and our obligations regarding any such uses or disclosures but may not include every example or exception that may apply.  

This notice is based upon state and federal law which requires us to safeguard the privacy of your protected health information, provide you with this notice and follow the terms of this notice.   

We reserve the right to change the terms of this notice and to make the changes apply to all protected health information maintained by us.   Any revised notice will be available upon request or on our website (www.signaturehch.com).

OUR USES AND DISCLOSURES:

The following are the types of uses and disclosures we may make of your protected health information without your authorization: 

Treatment

We may use your protected health information to provide you with medical treatment or services.  We may disclose your protected health information to other health professionals who are involved with your care now or in the future.  For example, we may provide protected health information to your primary care physician for coordination of your care or provide protected health information to a skilled nursing facility for a hospice respite admission. 

Payment

We may use and disclose your protected health information for our payment purposes or for the payment purposes of other health care providers or health plans.   For example, we may disclose protected health information to your insurance company for billing or if you need emergency transport, we may disclose protected health information to the medical transport company for its billing purposes.

Health Care Operations

We may use or disclose your protected health information for our health care operations which are business activities that support the delivery of and payment for care.   For example, we may use your personal health information to assess and improve the quality and cost effectiveness of the care we deliver to you, to provide care management or to perform customer service functions.   We may also disclose your protected health information to other health professionals or health plans for their own health care operations as allowed by law. 

Appointment Reminders

We may use and disclose your protected health information to contact and remind you that you have an appointment for medical treatment or services.

Treatment Alternatives and Health-Related Benefits

We may use and disclose your protected health information to provide you with information about treatment alternatives or health-related benefits or services that may be of interest to you.

Friends, Family or Others

We may disclose and discuss protected health information with your family, friends or others involved in your care or payment for your care.   We will only disclose and discuss information if you agree, are given the opportunity to object and do not, or if in our professional judgment, it would be in your best interest to allow the person to receive the protected health information or act on your behalf.  In any case, we will disclose and discuss only the information that the person involved needs to know about your care or payment for your care.  

Business Associates

Some of the activities previously described are performed through contracts with outside vendors called business associates which may include quality reporting vendors or software companies.   We may disclose your protected health information to our business associates and allow them to create, use and disclose your protected health information to perform their services for us.  For example, we may disclose your protected health information to an outside billing company to assist us in billing a health plan for your care.   We require business associates to appropriately safeguard the privacy of your protected health information.

Public Health Activities

We may use or disclose your protected health information to public health authorities that are authorized by law to receive and collect protected health information for the purpose of preventing or controlling disease, injury, or disability.

Disaster Relief Efforts

Unless you object, we may disclose your protected health information to an entity assisting in a disaster relief effort as necessary to identify, locate and notify family members or others responsible for you. 

Abuse and Neglect

We may notify the appropriate government authority if we believe you have been the victim of abuse (physical or financial), neglect, domestic violence, or a crime.   Unless such disclosure is required or authorized by law (for example, to report a particular type of injury), we will only make this disclosure if you agree.

Health Oversight Activities

We may disclose your protected health information to a health oversight agency for activities authorized by law.   For example, we may disclose protected health information for 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.

Organ, Eye or Tissue Donation

If you are an organ donor, we may disclose your protected health information to organ, eye or tissue procurement, transplantation, or banking organizations as necessary to facilitate organ, eye or tissue donation and transplantation.

Research

We may use or disclose your protected health information for research purposes under certain limited circumstances.  For example, you have chosen to participate in a research study with an entity which is not a Signature ACE entity.

Workers’ Compensation

We may disclose protected health information about you for workers’ compensation programs when your health condition arising out of a work-related illness or injury.

Legal Proceedings

If you are involved in a lawsuit or a dispute, we may disclose your protected health information in response to a court or administrative order.   We may also disclose your protected health information in response to a subpoena, discovery request or other lawful process by someone else involved in the dispute.   In most circumstances, we will not disclose your protected health information until reasonable efforts have been made to notify you of the request or to obtain an order from the court protecting the information requested.

Law Enforcement

We may disclose your protected health information if requested to do so by a law enforcement official in limited circumstances including but not limited to:

·       In response to a court order, subpoena, warrant, summons or similar process

·       To alert authorities of a death we believe may be the result of criminal conduct

·       In emergency circumstances to report the suspicion of a crime against one of our patients including the crime, the location of the crime, the victim’s identity or a description or location of the person who committed the crime

·       To identify or locate a suspect, fugitive, material witness or missing person

·       As otherwise required by law

Threats to Health or Safety

We may use or disclose your protected health information to prevent a serious and imminent threat to health and safety if we, in good faith, believe the use or disclosure is necessary to prevent or lessen the threat and the disclosure is to a person reasonably able to prevent or lessen the threat (including the target) or is necessary for law enforcement authorities to identify or apprehend an individual involved in a crime.

Coroners, Medical Examiners or Funeral Directors

We may use or disclose your protected health information to a coroner or medical examiner for the purpose of identifying a deceased individual or to determine the cause of death.   We may also use or disclose your protected health information to funeral directors as necessary to carry out their duties.

Specialized Government Functions

We may disclose your protected health information for national security and intelligence activities authorized by law or for protected services of the President.   If you are military member, we may disclose your protected medical information as required by military command authorities.

Inmates

If you are an inmate of a correctional institute or under the custody of a law enforcement official, we may disclose to the institution, its agents or a law enforcement official, protected health information necessary for your health and the health and safety of other individuals.

Incidental Uses and Disclosures

There are certain incidental uses or disclosures of your protected health information that occur while we are providing service to you or conducting our business.   For example, family members may overhear information from the next room when a clinician is discussing medical information with the patient.    We will make reasonable efforts to limit these incidental uses and disclosures. 

OTHER USES AND DISCLOSURES:

All 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 authorization.  For example, the sale and marketing of your protected health information is prohibited without authorization.  In some situations, federal and state laws require authorization from you before we may disclose certain protected health information.   For example, information about mental health, drug and alcohol treatment and sexually transmitted diseases.

If you provide us with authorization to use or disclose your protected health information, you may revoke that authorization, in writing, at any time.   If you revoke your authorization, we will no longer use or disclose your protected health information for the purposes identified in the authorization.   Your revocation will not be effective for uses and disclosures made in reliance on your prior authorization.  

YOUR RIGHTS:

As a patient, you have the following rights regarding your protected health information:

Right to Inspect and Copy

You have the right to inspect and obtain copies of your protected health information maintained by us.   Copies may be provided in an electronic or paper form depending upon your request and how the records are maintained.   If you direct us to forward your protected health information to another person, we will do so, provided your signed, written direction clearly designates the recipient and location for delivery.  We may charge a fee for the costs of copying, mailing and other supplies or work associated with your request.  

Right to Request Restrictions

You have the right to request a restriction or limitation on the protected health information we use or disclose about you for treatment, payment, or health care operations or to persons involved in your care or payment for your care.   We are not required to agree to your request unless for disclosure to your health plan for payment or health care operations purposes if (i) you pay out of pocket in full for all expenses related to that service either at the time of service or within timeframes specified by our written polices and (ii) the disclosure is not otherwise required by law.  Such restriction will only apply to records that relate solely to the service for which you have paid in full.   If we later receive an authorization dated after the date of your requested restriction which authorizes us to disclose all of your records to your health plan, we will assume you have withdrawn your request for restriction.

Right to Amend

If you believe that your protected health information maintained by us is incorrect or incomplete, you may request, in writing, that we amend the information.  We are not required to make all requested amendments but will give each request careful consideration.   If we deny your request, we will provide you with a written explanation of the reasons and your rights.   We may deny your request for an amendment if it is not in writing, does not include a reason to support the request or if the information was not created by any Signature ACE entity.

Right to an Accounting of Disclosures

You have the right to request a list of certain disclosures of your protected health information made by us or our business associates.   You must state a time period for your request, which may not be longer than six years.   Your right to an account of disclosures does not include disclosures for treatment, payment or health care operations and certain other types of disclosures such as a disclosure permitted by your authorization.   A request for disclosure must be made in writing to the Privacy Officer. 

Right to Request Confidential Communications

You have the right to request that we communicate with you about your protected health information in a certain way or in a certain location.   For example, you can request that we only contact you on your cell phone.  We will agree to your request if it is reasonable and specifies how or where you want to be contacted. 

Right to a Paper Copy of this Notice

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

Right to Notice in Case of Breach

You have the right to receive notice in the event of a breach of your unsecured protected health information.   We will provide such notice to you without unreasonable delay but in no case later than sixty (60) days after we discover the breach. 

How to Exercise these Rights

All requests to exercise these rights must be in writing.   We will follow company policies to handle requests and notify you of our decision or actions and your rights. 

QUESTIONS AND CONCERNS:

If you have questions or concerns about any of our privacy practices or want to file a complaint about your privacy practices, you may contact the Signature ACE Privacy Officer using the contact information below.   You may also notify the U.S. Department of Health and Human Services Office (https://www.hhs.gov/hipaa/filing-a-complaint/what-to-expect/index.html).   You will not be penalized or retaliated against for filing a complaint. 

Signature ACE Privacy Officer

7632 SW Durham Road, Suite 105

Tigard, OR 97070

Phone:  844.744.2200

Email:  terri.roberts@sighch.com