Client Confidentiality Notice
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 are or become a client of Renewal Care Partners LLC or its affiliates (collectively, “Renewal Care”), Renewal Care is required by law to maintain the privacy of your personally-identifiable health information collected and maintained as part of your medical record, or as part of the services we provide you, including any and all protected health information (“Health Information”). By law, Renewal Care must also follow the terms of the Client Confidentiality Notice (“Notice”) that we have in effect at that time.
In general, when we release your Health Information, we must release only the information we need to achieve the purpose of the use or disclosure. However, all of your Health Information that you designate will be available for release if you sign an authorization form, if you request information for yourself, or if it is being released to a provider regarding your treatment or due to a legal requirement.
We reserve the right to revise or amend our privacy practices described in this Notice in accordance with law. Any revision or amendment to this Notice will be effective for all of your Health Information which Renewal Care has created or maintained in the past, and for any of your records we may create or maintain in the future.
IF YOU HAVE QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT RENEWAL CARE’S PRIVACY OFFICER IN ANY OF THE FOLLOWING WAYS:
By phone: (877) 544-8161
By email: [email protected]
By mail: Renewal Care, Attn: Privacy Officer, 52 Vanderbilt Avenue, Floor 14, New York, New York 10017
The above contact information for Renewal Care’s Privacy Officer applies when contacting the Privacy Officer for any reason pursuant to this Notice.
I. Uses and Disclosures of Health Information
The law permits Renewal Care to use and disclose Health Information about you without your consent or written authorization when such use or disclosure is necessary to assist us with providing your health care services. We are also allowed to disclose Health Information about you to your insurance company or other responsible payor and to hospitals, physicians, nurses, providers, suppliers or other persons or entities for the provision of health care services. Examples of the various ways in which we may use or disclose your Health Information for purposes of treatment, payment and health care operations include the following:
For Treatment and Services
We may use and disclose your Health Information when providing you with treatment and services and coordinating your care with other health care providers involved in your care. For example, we may contact your authorized medical practitioner to discuss your plan of care. Your Health Information may be used by nurses and home health aides as well as by physical therapists, pharmacists, medical equipment suppliers, or other persons or entities involved in your care.
We may use and disclose your Health Information for billing and payment purposes, including disclosing such information to an insurance company, another third-party payor, or to your authorized personal representative. We may also use your Health Information to bill you directly for items and services if you are the financially responsible party.
For Health Care Operations
We may use and disclose your Health Information as necessary for health care operations, such as management, staff evaluations, education and training, and for quality assurance. For example, Health Information of many clients may be combined and analyzed for purposes such as evaluating and improving quality of care and planning for services.
II. Specific Uses And Disclosures of Your Health Information
We are also permitted to use or disclose your Health Information without your consent or written authorization as follows:
- Individuals Involved in Your Care or Payment for Your Care: Unless you object, we may disclose Health Information about you to a family member, close personal friend, or other person you identify, including clergy, who is involved in your care or who is helping pay for your care.
- As Authorized or Required By Law: We may use or disclose your Health Information when authorized or required by federal, state or local law to do so.
- Public Health Activities: We may disclose your Health Information for public health activities, such as reporting to a public health authority that is required by law to collect information for the purpose of (i) preventing or controlling disease, injury or disability; (ii) maintaining vital records such as births and deaths; (iii) reporting child abuse or neglect; (iv) notifying a person regarding a potential risk for spreading or contracting a disease or condition; (v) reporting to the FDA reaction to drugs or problems with products or devices; (vi) notifying individuals if a product or device they may be using has been recalled; or (vii) notifying your employer under limited circumstances related primarily to evaluation of a work-related illness or injury or evaluation related to medical surveillance of the work place.
- Reporting Victims of Abuse, Neglect or Domestic Violence: If we believe that you have been a victim of abuse, neglect or domestic violence, we may use and disclose your Health Information to notify a government authority, if authorized by law or if you agree to the report.
- Health Oversight Activities: We may disclose your Health Information to a health oversight agency for activities authorized by law, such as audits, investigations, inspections, surveys, licensure and disciplinary actions or for activities involving government oversight of government programs, compliance with civil rights laws and the health care system. We may not disclose your Health Information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.
- To Avert a Serious Threat to Health or Safety: We may use and disclose Health Information about you when necessary to prevent a serious threat to your health and safety or the safety of the public or another person. This type of disclosure would only be to those we believe would be able to help prevent such a threat.
- Judicial and Administrative Proceedings: We may disclose your Health Information in response to a court or administrative order if you are involved in a lawsuit or similar proceeding. We also may disclose your Health Information in response to a subpoena, discovery request, or other lawful order or process by another party involved in the dispute that is not accompanied by a court order, but only if efforts have been made to inform you of the request or to obtain an order protecting the information the party has requested.
- Business Associates: We may disclose your Health Information to a contractor or business associate who needs the information to perform services for Renewal Care. We require that our business associates and contractors be committed to preserving the confidentiality of Health Information disclosed to them and sign a business associate agreement with them to that effect.
- Law Enforcement: We may disclose your Health Information for certain law enforcement purposes, including, for example, (i) to comply with reporting requirements; (ii) to comply with a court order, subpoena, warrant, summons or similar legal process; (iii) regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement; (iv) concerning a death we believe might have resulted from criminal conduct; (v) regarding criminal conduct in our offices; (vi) to identify/locate a suspect, material witness, fugitive or missing person; (vii) to report a crime (including the location of victim(s) of the crime, or the description, identity or location of the perpetrator) in an emergency; or (viii) to answer certain requests for information concerning crimes.
- Research: We may use or disclose your Health Information for research purposes if the privacy aspects of the research have been reviewed and approved by Renewal Care.
- Coroners, Medical Examiners, Funeral Directors, Organ Procurement Organizations: We may release your Health Information to a coroner, medical examiner, funeral director or, if you are an organ donor, to an organ donor bank.
Disaster Relief: We may use or disclose your Health Information to a disaster relief organization for the purpose of coordinating with such entity in order to notify, or assist in the notification of (including identifying or locating), your family members, personal representatives, or other individuals responsible for your care of location, general condition, or death.
- Military, Veterans and other Specific Government Functions: If you are a member of the U.S. or foreign military forces (including veterans), we may use and disclose your Health Information as required by military command authorities.
- Workers’ Compensation: We may use or disclose your Health Information to comply with laws relating to workers’ compensation or similar programs.
- Appointment Reminders: We may use or disclose Health Information to remind you about appointments. If you have an answering machine we may leave the reminder in a message.
- Health-Related Benefits and Services: We may use or disclose your Health Information to inform you about treatment alternatives and health-related benefits and services that may be of interest to you.
- National Security: We may disclose your Health Information to federal officials for intelligence and national security activities authorized by law. We may also disclose your Health Information to federal officials in order to protect the President, other officials or foreign heads of state, or to conduct investigations.
III. Your Rights with Respect to Your Health Information
You and your authorized personal representatives have specific rights with respect to your Health Information, including the right to:
- Request restrictions on certain uses and disclosures of your Health Information. Renewal Care will try to honor your requests, but we are not required to agree to a requested restriction; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you. In order to request a restriction in our use or disclosure of your Health Information, you must make your request in writing to the Privacy Officer of Renewal Care and describe the information you wish restricted, whether you are requesting to limit our use, disclosure or both, and to whom you want the limits to apply.
- Request that we send you confidential communications of your Health Information at an alternative address or by alternative means. For example, you may ask that we contact you at home, rather than work. In order to request a type of confidential communication, you must make a written request to the Privacy Officer of Renewal Care, specifying the requested method of contact, or the location where you wish to be contacted. We will agree to your request as long as it is reasonably easy for us to do so.
- Inspect and copy your Health Information. Please note that in some cases we may be required or permitted to deny access to certain information as required or allowed by law; however, you may request a review of our denial. A reasonable copying charge may be imposed for the cost of copying, mailing, labor and supplies, not to exceed the maximum amount allowable under New York law. You must submit your request in writing to the Privacy Officer of Renewal Care in order to inspect and/or obtain a copy of your Health Information. Renewal Care must act upon your request within thirty (30) days of receiving it. If we are unable to do so, we may extend our time to respond for an additional thirty (30) days as long as we inform you of the reasons for our delay and the date when we will respond.
- Request to amend your Health Information. If you feel that Health Information about you is incorrect, you may ask us to amend the record if the information is kept by Renewal Care. The request must be made in writing, and include a description of the reason that supports your request. We must act upon your request within sixty (60) days of receiving it. If we are unable to do so, we may extend our time to respond for an additional thirty (30) days as long as we inform you of the reasons for our delay and the date when we will respond. If your request is denied, you may submit a written statement of your disagreement and we may submit a rebuttal of such statement to be placed in your medical record.
- Receive an accounting of disclosures of your Health Information. You are entitled to receive an accounting of disclosures made by Renewal Care in the six (6) years prior to the date on which the accounting is requested; however, we are not required to provide an accounting of information shared or disclosed: (i) for treatment, payment, and health care operations purposes; (ii) pursuant to your written authorization; (iii) for national security or intelligence purposes; (iv) to correctional institutions, law enforcement officials or health oversight agencies; or (v) as part of a limited data set for research, public health or health care operations purposes. You must submit your requests for an accounting of disclosures in writing. We will attempt to respond to the requests within sixty (60) days, unless an additional thirty (30) days are needed, in which case we will inform you of the reasons for our delay and the date when we will respond. We will provide you with one free accounting every twelve (12) months. A reasonable fee may be charged for any additional accountings within a twelve (12) month period; we will tell you in advance how much the accounting will cost so that you have opportunity to withdraw or amend your request.
- Receive notification of any breach of your unsecured Health Information. In the event your unsecured Health Information (Health Information that is not secured through the use of certain approved technologies or methodologies that would render the information unusable, unreadable or undecipherable to unauthorized individuals) has been, or is reasonably believed to have been accessed, acquired, used or disclosed due to a breach, we will notify you in writing without unreasonable delay, and in no case later than sixty (60) days following the discovery of the breach.
- Obtain a written copy of this Notice.
IV. Authorizations For Certain Uses and Disclosures of Health Information Other Than As Specified Above
Except as described in this Notice or permitted by law, Renewal Care will not use or disclose any of your Health Information for the following purposes without your written authorization:
- Uses and disclosures for marketing purposes;
- Uses and disclosures that constitute the sale of your Health Information;
- Most uses and disclosures of psychotherapy notes; and
- Other uses and disclosures not described in this Notice or permitted by applicable law.
If you provide us with authorization to use or disclose your Health Information, you may revoke the authorization at any time by writing to us. If you revoke an authorization, we will no longer use or disclose your Health Information for the purposes covered by the authorization, except where we have already relied on the authorization. Please note we are still permitted to use and disclose your Health Information for purposes not requiring your express authorization.
V. Complaints and Inquiries
You may file a complaint with Renewal Care if you believe that your privacy rights have been violated. If you wish to do so, or to request additional information related to this Notice, you should contact the Privacy Officer of Renewal Care. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. You will not be retaliated against for filing a complaint.
VI. Changes to this Notice
Renewal Care is required to abide by the terms of this Notice of Privacy Practices as currently in effect. Renewal Care reserves the right to change the terms of this Notice and to make the new Notice provisions effective for all Health Information we maintain. Prior to implementing any revised Notice, Renewal Care Partners will provide you with a copy. This Notice is effective October 23rd, 2014.