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.
Our Commitment to Your Privacy It is our duty to maintain the privacy and confidentiality of your protected health information (PHI). We will create records regarding you and the treatment and service we provide to you. We are required by law to maintain the privacy of your PHI, which includes any individually identifiable information that we obtain from you or others that relates to your past, present, or future physical or mental health; the healthcare you have received; or payment for your healthcare. We will share protected health information with one another, as necessary, to carry out treatment, payment, or healthcare operations relating to the services to be rendered at the pharmacy. As required by law, this notice provides you with information about your rights and our legal duties and privacy practices with respect to the privacy of PHI. This notice also discusses the uses and disclosures we will make of your PHI.
We must comply with the provisions of this notice as currently in effect, although we reserve the right to change the terms of this notice from time to time and to make the revised notice effective for all PHI we maintain. You can always request a written copy of our most current privacy notice from our Privacy Officer. Permitted Uses and Disclosures We can use or disclose your PHI for purposes of treatment, payment, and healthcare operations. For each of these categories of uses and disclosures, we have provided a description and an example below. However, not every particular use or disclosure in every category will be listed. Treatment means providing services as ordered by your physician. Treatment also includes coordination and consultations with other healthcare providers relating to your care and referrals for healthcare from one healthcare provider to another. We may also disclose PHI to outside entities performing other services related to your treatment such as hospitals, diagnostic laboratories, home health or hospice agencies, etc. Payment refers to the activities we undertake to obtain reimbursement for the healthcare provided to you, including billing, collections, claims management, prior approval, determinations of eligibility and coverage, and other utilization review activities.
Federal or state law may require us to obtain a written release from you prior to disclosing certain specially protected PHI for payment purposes, therefore we will ask you to sign a release when necessary under applicable law. Healthcare operations means the support functions of the pharmacy related to treatment and payment, such as quality assurance activities, case management, receiving and responding to patient comments and complaints, physician reviews, compliance programs, audits, business planning, development, management, and administrative activities. We may use your PHI to evaluate the performance of our staff when caring for you. We may also combine PHI about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose PHI for review and learning purposes.
In addition, we may remove information that identifies you so that others can use the de-identified information to study healthcare and healthcare delivery without learning who you are.
Other Uses and Disclosures of PHI
We may also use your PHI in the following ways:
- To provide appointment reminders for treatment or medical care
- To inform or recommend possible treatment alternatives or other health-related benefits and services that may be of interest to you
To disclose information to your family or friends or any other individual identified by you to the extent directly related to such person’s involvement in your care or the payment for your care. We may use or disclose your PHI to notify, or assist in the notification of, a family member, a personal representative, or another person responsible for your care of your location, general condition, or death. If you are available, we will give you an opportunity to object to these disclosures and we will not make these disclosures if you object. If you are not available, we will determine whether a disclosure to your family or friends is in your best interest considering the circumstances and based upon our professional judgment.
When permitted by law, we may coordinate our uses and disclosures of PHI with public or private entities authorized by law or by charter to assist in disaster relief efforts. We will allow your family and friends to act on your behalf to pick up filled prescriptions, medical supplies, X-rays, and similar forms of PHI, when we determine, in our professional judgment, that it is in your best interest to make such disclosures.
We may use or disclose your PHI for research purposes, subject to the requirements of applicable law. For example, a research project may involve comparisons of the health and recovery of all patients who received a particular medication. All research projects are subject to a special approval process which balances research needs with a patient’s need for privacy. When required, we will obtain a written authorization from you prior to using your health information for research. We will use or disclose PHI about you when required to do so by applicable law. In accordance with applicable law, we may disclose your PHI to your employer if we are retained to conduct an evaluation relating to medical surveillance of your workplace or to evaluate whether you have a work-related illness or injury.
You will be notified of these disclosures by your employer or the pharmacy as required by applicable law. Note: incidental uses and disclosures of PHI sometimes occur and are not considered to be a violation of your rights. Incidental uses and disclosures are by-products of otherwise permitted uses or disclosures which are limited in nature and cannot be reasonably prevented.
Subject to the requirements of applicable law, we will make the following uses and disclosures of your PHI:
- Organ and Tissue Donation. If you are an organ donor, we may release PHI to organizations that handle organ procurement or transplantation 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 PHI about you as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.
- Worker’s Compensation. We may release PHI about you for programs that provide benefits for work-related injuries or illnesses.
- Public Health Activities. We may disclose PHI about you for public health activities, including disclosures: • to prevent or control disease, injury, or disability • to report births and deaths • to report child abuse or neglect • to persons subject to the jurisdiction of the Food and Drug Administration (FDA) for activities related to the quality, safety, or effectiveness of FDA-regulated products or services and to report reactions to medications or problems with products • to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition • to notify the appropriate government authority if we believe that an adult patient has been the victim of abuse, neglect, or domestic violence. We will only make this disclosure if the patient agrees or when required or authorized by law.
- Health Oversight Activities. We may disclose PHI to federal or state agencies that oversee our activities (e.g. providing healthcare, seeking payment, and civil rights).
- Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose PHI subject to certain limitations.
- Law Enforcement. We may release PHI if asked to do so by a law enforcement official: • In response to a court order, warrant, summons, or similar process • To identify or locate a suspect, fugitive, material witness, or missing person • About the victim of a crime under certain limited circumstances • About a death we believe may be the result of criminal conduct • About criminal conduct on our premises • In emergency circumstances, to report a crime, the location of the crime, or the victims, or the identity, description, or location of the person who committed the crime Coroners, Medical Examiners, and Funeral Directors. We may release PHI to a coroner or medical examiner. We may also release PHI about patients to funeral directors as necessary to carry out their duties.
- National Security and Intelligence Activities. We may release PHI about you to authorized federal officials for intelligence, counterintelligence, other national security activities authorized by law or to authorized federal officials so they may provide protection to the president or foreign heads of state. Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release PHI about you to the correctional institution or law enforcement official. This release would be necessary (1) to provide you with health care, (2) to protect your health and safety or the health and safety of others, or (3) for the safety and security of the correctional institution.
- Serious Threats. As permitted by applicable law and standards of ethical conduct, we may use and disclose PHI if we, in good faith, believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public or is necessary for law enforcement authorities to identify or apprehend an individual. Note: HIV-related information, genetic information, alcohol and/or substance abuse records, mental health records, and other specially protected health information may qualify for certain special confidentiality protections under applicable state and federal law. Any disclosures of these types of records will be subject to these special protections.
Other Uses of Your Health Information Certain uses and disclosures of PHI will be made only with your written authorization, including uses and/or disclosures: (1) of psychotherapy notes (where appropriate), (2) for marketing purposes, and (3) that constitute a sale of PHI under the Privacy Rule. Other uses and disclosures of PHI not covered by this notice or the laws that apply to us will be made only with your written authorization. You have the right to revoke that authorization at any time, provided that the revocation is in writing, except to the extent that we have already taken action in reliance on your authorization.