In this notice, we describe the ways that we may use and disclose health information about our patients. The HIPAA Privacy Rule requires that we protect the privacy of health information that identifies a patient, or may be used to identify a patient. This information is called “Protected Health Information” or “PHI.” This notice describes your rights as our patient and our obligations regarding the use and disclosure of PHI. We are required by law to:

• Maintain the privacy of PHI about you.
• Give you this Notice of our legal duties and privacy practices with respect to PHI.
• Comply with the terms of our Notice of Privacy Practices that is currently in effect.

We are required to abide by the terms of this notice, which we may change from time to time. Any new notice will be effective for all PHI that we maintain at that time. If and when this notice is changed, we will post a copy in our office in a prominent location. We will also provide you with a copy of the revised notice upon your request made to our Privacy Official.

HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU

Treatment: We may use and disclose PHI about you to provide, coordinate or manage your health care and related services.  We may consult with other health care providers regarding your treatment and coordinate and manage your health care with others.  For example, we may use and disclose PHI when you need a prescription, lab work, an x-ray, or other health care services.  In addition, we may use and disclose PHI about you when referring you to another health care provider so that the health care provider has the information necessary to treat you.

Payment: We may use and disclose PHI so that we can bill and collect payment for the treatment and services provided to you.  Before providing treatment or services, we may share details with your health plan concerning the services you are scheduled to receive.  For example, we may ask for payment approval from your health plan before we provide care or services.  We may use and disclose PHI to find out if your health plan will cover the cost of care and services we provide.  We may use and disclose PHI to confirm you are receiving the appropriate amount of care to obtain payment for services.  We may use and disclose PHI for billing, claims management, and collection activities.  We may disclose PHI to insurance companies providing you with additional coverage.  We may disclose limited PHI to consumer reporting agencies relating to collection of payments owed to us.  We may also disclose PHI to another health care provider or to a company or health plan required to comply with the HIPAA Privacy Rule for the payment activities of that health care provider, company, or health plan.  For example, we may allow a health insurance company to review PHI for the insurance company’s activities to determine the insurance benefits to be paid for your care.

Health Care Operations: We may use and disclose PHI in performing business activities that are called health care operations. Health care operations include doing things that allow us to improve the quality of care we provide and to reduce health care costs.  We may use and disclose PHI about you in health care operations such as:

¨       Reviewing and improving the quality, efficiency and cost of care that we provide to our patients.  For example, we may use PHI about you to develop ways to assist our physicians and staff in deciding how we can improve the medical treatment we provide to others.

¨       Improving health care and lowering costs for groups of people who have similar health problems and helping to manage and coordinate the care for these groups of people.  We may use PHI to identify groups of people with similar health problems to give them information, for instance, about treatment alternatives, and educational classes.

¨       Reviewing and evaluating the skills, qualifications, and performance of health care providers taking care of you and our other patients.

¨       Providing training programs for students, trainees, health care providers, or non-health care professionals (for example, billing personnel) to help them practice or improve their skills.

¨       Cooperating with various people who review our activities.  For example, PHI may be seen by doctors reviewing the services provided to you, and by accountants, lawyers, and others who assist us in complying with the law and managing our business.

¨       Assisting us in making plans for our practice’s future operations.

¨       Resolving complaints within our practice.

¨       Reviewing our activities and using or disclosing PHI in the event that we sell our practice to someone else or combine with another practice.

¨       Business planning and development, such as cost-management analyses.

¨       We will share your PHI with “business associates” who require the information to perform various activities (e.g. transcription services).

¨       We may use sign in sheets where you will be asked to sign your name and/or physician.  We may also call you by name in the waiting room when your doctor is ready to see you.  We may also call you on the telephone to remind you of an appointment.

OTHER USES AND DISCLOSURES WE CAN MAKE WITHOUT YOUR WRITTEN AUTHORIZATION

Required By Law: We may use and disclose PHI as required by federal, state, or local law.  Any disclosure complies with the law and is limited to the requirements of the law.

Public Health Activities: We may use or disclose PHI to public health authorities or other authorized persons to carry out certain activities related to public health, including the following activities:

¨       To prevent or control disease, injury, or disability;

¨       To report disease, injury, birth, or death;

¨       To report child abuse or neglect;

¨       To report reactions to medications or problems with products or devices regulated by the federal Food and Drug Administration or other activities related to quality, safety, or effectiveness of FDA-regulated products or activities;

¨       To locate and notify persons of recalls of products they may be using;

¨       To notify a person who may have been exposed to a communicable disease in order to control who may be at risk of contracting or spreading the disease; or

¨       To report to your employer, under limited circumstances, information related primarily to workplace injuries or illness, or workplace medical surveillance.

Abuse, Neglect, or Domestic Violence: We may disclose PHI in certain cases to proper government authorities if we reasonably believe that a patient has been a victim of domestic violence, abuse, or neglect.

Health Oversight Activities: We may disclose PHI to a health oversight agency for oversight activities including, for example, audits, investigations, inspections, licensure and disciplinary activities conducted by health oversight agencies.

Lawsuits and Other Legal Proceedings:  We may use or disclose PHI when required by a court or administrative tribunal order.  We may also disclose PHI in response to subpoenas, discovery requests, or other required legal processes.

Law Enforcement:  Under certain conditions, we may disclose PHI to law enforcement officials.  These law enforcement purposes include:

¨       Limited requests for identification and location purposes.

¨       Legal processes required by law.

¨       Suspicion that death has occurred as a result of criminal conduct.

¨       In the event that a crime occurs on the premises of the practice.

¨       Pertaining to victims of a crime.

¨       In response to a medical emergency not occurring at the office, where it is likely that a crime has occurred.

Coroners and Medical Examiners:  We may disclose PHI to a coroner or medical examiner to identity a deceased person and determine the cause of death.

Organ and Tissue Donation:  It you are an organ donor, we may use or disclose PHI to organizations that help procure, locate, and transplant organs in order to facilitate an organ, eye, or tissue donation and transplantation.

Research: We may use and disclose PHI about you for research purposes under certain limited circumstances.  We must obtain a written authorization to use and disclose PHI about you for research purposes except in situations where a research project meets specific, detailed criteria established by the HIPAA Privacy Rule.

To Avert a Serious Threat to Health or Safety:  We may use or disclose PHI about you in limited circumstances when necessary to prevent a threat to the health or safety of a person or to the public.  This disclosure can only be made to a person who is able to help prevent the threat.

Specialized Government Functions: Under certain circumstances we may disclose PHI:

¨       For certain military and veteran activities, including determination of eligibility for veterans benefits and where deemed necessary by military command authorities.

¨       For national security and intelligence activities.

¨       To help provide protective services for the president and others.

¨       For the health or safety of inmates and others at correctional institutions.

Disclosures required by HIPAA Privacy Rule: We are required to disclose PHI to the Secretary of the United States Department of Health and Human Services when requested by the Secretary to review our compliance with the HIPAA Privacy Rule.  We are also required in certain cases to disclose PHI to you upon your request to access PHI or for an accounting of certain disclosures of PHI about you.

Workers’ Compensation: We may disclose PHI as authorized by workers’ compensation laws or other similar programs that provide benefits for work-related injuries or illness.

OTHER USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION REQUIRE YOUR AUTHORIZATION

All other uses and disclosures of PHI about you will only be made with your written authorization.   If you have authorized us to use or disclose PHI about you, you may revoke your authorization at any time, except to the extent we have taken action based on the authorization.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU

Under federal law, you have the following rights regarding PHI about you:

Right to Request Restrictions: You have the right to request additional restrictions on the PHI that we may use for treatment, payment and health care operations.  You may also request additional restrictions on our disclosure of PHI to certain individuals involved in your care that otherwise are permitted by the Privacy Rule.  We are not required to agree to your request.  If we do agree to your request, we are required to comply with our agreement except in certain cases, including where the information is needed to treat you in the case of an emergency.  To request restrictions, you must make your request in writing to our Privacy Official.  In your request, please include (1) the information that you want to restrict (2) how you want to restrict the information, and (3) to whom you want those restrictions to apply.

Right to Receive Confidential Communications: You have the right to request that you receive communications regarding PHI in a certain manner or at a certain location.  For example, you may request that we contact you at home, rather than at work.  You must make your request in writing to our Privacy Official.  You must specify how you would like to be contacted (for example, by regular mail to your post office box and not your home).  We are required to accommodate reasonable requests.

Right to Inspect and Copy: You have the right to request the opportunity to inspect and receive a copy of PHI about you in certain records that we maintain.  This includes your medical and billing records but does not include psychotherapy notes or information gathered or prepared for a civil, criminal, or administrative proceeding.  We may deny your request to inspect and copy PHI only in limited circumstances.  Please contact our Privacy Official if you have questions about access to your medical record.  If you request a copy of PHI about you, we may charge you a reasonable fee for the copying, postage labor and supplies used in meeting your request.

Right to Amend: You have the right to request that we amend PHI about you as long as such information is kept by or for our office. To make this type of request you must submit your request in writing to our Privacy Official.  You must also give us a reason for your request.  We may deny your request in certain cases.  Requests for amendments must be in writing and must give us a reason for the request.

Right to Receive an Accounting of Disclosures: You have the right to request an “accounting” of certain disclosures that we have made of PHI about you.  This is a list of disclosures made by us other than disclosures made for treatment, payment, and health care operations. You have the right to receive specific information regarding these disclosures that occurred after April 14, 2003.  The first list that you request in a 12-month period will be free, but we may charge you for our reasonable costs of providing additional lists in the same 12-month period.  We will tell you about these costs, and you may choose to cancel your request at any time before costs are incurred.

Right to a Paper Copy of this Notice: You have a right to receive a paper copy of this notice at any time.  You are entitled to a paper copy of this notice even if you have previously agreed to receive this notice electronically.  To obtain a paper copy of this notice, please contact our Privacy Official.

COMPLAINTS

It you believe your privacy rights have been violated, you may file a complaint with us and/or the Secretary of the United States Department of Health and Human Services.  To file a complaint with our office, please contact our Privacy Official at the address and number listed below.  We will not retaliate or take action against you for filing a complaint.   We would appreciate your contacting us first so that we may address your concerns.

PRIVACY OFFICIAL CONTACT INFORMATION

You may contact our Privacy Official at the following address and phone number:

2 Dudley Street Suite 370
Providence, RI 02905
(401) 444-7646