NOTICE OF PRIVACY PRACTICES
For
Pravin P. Puri, M.D.
(referred to in this document as “the practice”)
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.
This Notice of Privacy Practices is being provided to you as a
requirement of the Health Insurance Portability and Accountability Act (HIPAA).
This Notice describes how we may use and disclose your protected health
information to carry out treatment, payment or health care operations and for
other purposes that are permitted or required by law. It also describes your
rights to access and control your protected health information in some cases.
Your “protected health information” means any of your written and oral health
information, including demographic data that can be used to identify you. This
is health information that is created or received by your health care provider
and that relates to your past, present or future physical or mental health or
condition.
I. Uses and Disclosures of Protected Health Information
The practice may use your protected health information for purposes
of providing treatment, obtaining payment for treatment, and conducting health
care operations. Your protected health information may be used or disclosed
only for these purposes unless the practice has obtained your authorization or
the use or disclosure is otherwise permitted by the HIPAA Privacy Regulations
or State law. Disclosures of your protected health information for the purposes
described in this Notice may be made in writing, orally, or by facsimile.
A. Treatment. We will use and disclose your protected
health information to provide, coordinate, or manage your health care and any
related services. This includes the coordination or management of your health
care with a third party for treatment purposes. For example, we may disclose
your protected health information to a pharmacy to fulfill a prescription, to a
laboratory to order a blood test, or to a home health agency that is providing
care in your home. We may also disclose protected health information to other
physicians who may be treating you or consulting with your physician with
respect to your care. In some cases, we may also disclose your protected health
information to an outside treatment provider for purposes of the treatment
activities of the other provider.
B. Payment. Your protected health information will be
used, as needed, to obtain payment for the services that we provide. This may
include certain communications to your health insurer to get approval for the
treatment that we recommend. For example, if a hospital admission is
recommended, we may need to disclose information to your health insurer to get
prior approval for the hospitalization.
1. We may also disclose protected health information to your
insurance company to determine whether you are eligible for benefits or whether
a particular service is covered under your health plan. In order to get payment
for your services, we may also need to disclose your protected health
information to your insurance company to demonstrate the medical necessity of
the services or, as required by your insurance company, for utilization review.
We may also disclose patient information to another provider involved in your
care for the other provider’s payment activities.
C. Operations. We may use or disclose your protected
health information, as necessary, for our own health care operations in order
to facilitate the function of the practice and to provide quality care to all
patients. Health care operations include such activities as:
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Quality assessment and improvement activities.
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Employee review activities.
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Training programs including those in which students, trainees, or
practitioners in health care learn under supervision.
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Accreditation, certification, licensing or credentialing
activities.
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Review and auditing, including compliance reviews, medical reviews,
legal services and maintaining compliance programs.
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Business management and general administrative activities.
In certain situations, we may also disclose patient information to
another provider or health plan for their health care operations.
D. Other Uses and Disclosures. As part of treatment,
payment and health care operations, we may also use or disclose your protected
health information for the following purposes:
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To remind you of an appointment.
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To inform you of potential treatment alternatives or options.
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To inform you of health-related benefits or services that may be of
interest to you.
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To contact you to raise funds for the practice or an institutional
foundation related to the practice. If you do not wish to be contacted
regarding fundraising, please contact our Privacy Officer.
II. Uses and Disclosures Beyond Treatment, Payment, and Health Care
Operations Permitted Without Authorization or Opportunity to Object
Federal privacy rules allow us to use or disclose your protected health
information without your permission or authorization for a number of reasons
including the following:
A. When Legally Required. We will disclose your
protected health information when we are required to do so by any Federal,
State or local law.
B. When There Are Risks to Public Health. We may
disclose your protected health information for the following public activities
and purposes:
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To prevent, control or report disease, injury or disability as
permitted by law.
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To report vital events such as birth or death as permitted or
required by law.
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To conduct public health surveillance, investigations and
interventions as permitted or required by law.
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To collect or report adverse events and product defects, track FDA
regulated products, enable product recalls, repairs or replacements to the FDA
and to conduct post marketing surveillance.
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To notify a person who has been exposed to a communicable disease
or who may be at risk of contracting or spreading a disease as authorized by
law.
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To report to an employer information about an individual who is a
member of the workforce as legally permitted or required.
C. To Report Abuse, Neglect or Domestic Violence. We
may notify government authorities if we believe that a patient is the victim of
abuse, neglect or domestic violence. We will make this disclosure only when
specifically required or authorized by law or when the patient agrees to the
disclosure.
D. To Conduct Health Oversight Activities. We may
disclose your protected health information to a health oversight agency for
activities including audits; civil, administrative, or criminal investigations,
proceedings, or actions; inspections; licensure or disciplinary actions; or
other activities necessary for appropriate oversight as authorized by law. We
will 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.
E. In Connection With Judicial and Administrative Proceedings.
We may disclose your protected health information in the course of any judicial
or administrative proceeding in response to an order of a court or
administrative tribunal as expressly authorized by such order or in response to
a signed authorization (in a format approved by the Michigan Court
Administrator).
F. For Law Enforcement Purposes. We may disclose your
protected health information to a law enforcement official for law enforcement
purposes as follows:
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As required by law for reporting of certain types of wounds or
other physical injuries.
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Pursuant to court order, court-ordered warrant, subpoena, summons
or similar process.
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For the purpose of identifying or locating a suspect, fugitive,
material witness or missing person.
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Under certain limited circumstances, when you are the victim of a
crime.
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To a law enforcement official if the practice has a suspicion that
your death was the result of criminal conduct.
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In an emergency in order to report a crime.
G. To Coroners, Funeral Directors, and for Organ Donation.
We may disclose protected health information to a coroner or medical examiner
for identification purposes, to determine cause of death or for the coroner or
medical examiner to perform other duties authorized by law. We may also
disclose protected health information to a funeral director, as authorized by
law, in order to permit the funeral director to carry out their duties. We may
disclose such information in reasonable anticipation of death. Protected health
information may be used and disclosed for cadaveric organ, eye or tissue
donation purposes.
H. For Research Purposes. We may use or disclose your
protected health information for research when the use or disclosure for
research has been approved by an institutional review board or privacy board
that has reviewed the research proposal and research protocols to address the
privacy of your protected health information.
I. In the Event of a Serious Threat to Health or Safety.
We may, consistent with applicable law and ethical standards of conduct, use or
disclose your protected health information if we believe, in good faith, that
such use or disclosure is necessary to prevent or lessen a serious and imminent
threat to your health or safety or to the health and safety of the public.
J. For Specified Government Functions. In certain
circumstances, the Federal regulations authorize the practice to use or
disclose your protected health information to facilitate specified government
functions relating to military and veterans activities, national security and
intelligence activities, protective services for the President and others,
medical suitability determinations, correctional institutions, and law
enforcement custodial situations.
K. For Worker’s Compensation. The practice may
release your health information to comply with worker’s compensation laws or
similar programs.
III. Uses and Disclosures Permitted Without Authorization But With
Opportunity to Object
We may disclose your protected health information to your family
member or a close personal friend if it is directly relevant to the person’s
involvement in your care or payment related to your care. We can also disclose
your information in connection with trying to locate or notify family members
or others involved in your care concerning your location, condition or death.
You may object to these disclosures. If you do not object to these
disclosures or we can infer from the circumstances that you do not object or we
determine, in the exercise of our professional judgment, that it is in your
best interests for us to make disclosure of information that is directly
relevant to the person’s involvement with your care, we may disclose your
protected health information as described.
IV. Uses and Disclosures Which You Authorize
Other than as stated above, we will not disclose your health
information other than with your written authorization. You may revoke your
authorization in writing at any time except to the extent that we have taken
action in reliance upon the authorization.
V. Your Rights
You have the following rights regarding your health information:
A. The right to inspect and copy your protected health information.
You may inspect and obtain a copy of your protected health information that is
contained in a designated record set for as long as we maintain the protected
health information. A “designated record set” contains medical and billing
records and any other records that your physician and the practice uses for
making decisions about you.
Under Federal law, however, you may not inspect or copy the
following records: psychotherapy notes; information compiled in reasonable
anticipation of, or for use in, a civil, criminal, or administrative action or
proceeding; and protected health information that is subject to a law that
prohibits access to protected health information. Depending on the
circumstances, you may have the right to have a decision to deny access
reviewed.
We may deny your request to inspect or copy your protected health
information if, in our professional judgment, we determine that the access
requested is likely to endanger your life or safety or that of another person,
or that it is likely to cause substantial harm to another person referenced
within the information. You have the right to request a review of this
decision.
To inspect and copy your medical information, you must submit a
written request to the Privacy Officer whose contact information is listed on
the last pages of this Notice. If you request a copy of your information, we
may charge you a fee for the costs of copying, mailing or other costs incurred
by us in complying with your request.
Please contact our Privacy Officer if you have questions about
access to your medical record.
B. The right to request a restriction on uses and disclosures of your
protected health information. You may ask us not to use or
disclose certain parts of your protected health information for the purposes of
treatment, payment or health care operations. You may also request that we not
disclose your health information to family members or friends who may be
involved in your care or for notification purposes as described in this Notice
of Privacy Practices. Your request must state the specific restriction
requested and to whom you want the restriction to apply.
The practice is not required to agree to a restriction that you may
request. We will notify you if we deny your request to a restriction. If the
practice does agree to the requested restriction, we may not use or disclose
your protected health information in violation of that restriction unless it is
needed to provide emergency treatment. Under certain circumstances, we may
terminate our agreement to a restriction. You may request a restriction by
contacting the Privacy Officer.
C. The right to request to receive confidential communications from
us by alternative means or at an alternative location. You have
the right to request that we communicate with you in certain ways. We will
accommodate reasonable requests. We may condition this accommodation by asking
you for information as to how payment will be handled or specification of an
alternative address or other method of contact. We will not require you to
provide an explanation for your request. Requests must be made in writing to
our Privacy Officer.
D. The right to have your physician amend your protected health
information. You may request an amendment of protected health
information about you in a designated record set for as long as we maintain
this information. In certain cases, we may deny your request for an amendment.
If we deny your request for amendment, you have the right to file a statement
of disagreement with us and we may prepare a rebuttal to your statement and
will provide you with a copy of any such rebuttal. Requests for amendment must
be in writing and must be directed to our Privacy Officer. In this written
request, you must also provide a reason to support the requested amendments.
E. The right to receive an accounting. You have the
right to request an accounting of certain disclosures of your protected health
information made by the practice. This right applies to disclosures for
purposes other than treatment, payment or health care operations as described
in this Notice of Privacy Practices. We are also not required to account for
disclosures that you requested, disclosures that you agreed to by signing an
authorization form, disclosures for a facility directory, to friends or family
members involved in your care, or certain other disclosures we are permitted to
make without your authorization. The request for an accounting must be made in
writing to our Privacy Officer. The request should specify the time period
sought for the accounting.
We are not required to provide an accounting for disclosures that
take place prior to April 14, 2003. Accounting requests may not be made for
periods of time in excess of six years. We will provide the first accounting
you request during any 12-month period without charge. Subsequent accounting
requests may be subject to a reasonable cost-based fee.
F. The right to obtain a paper copy of this notice. Upon
request, we will provide a separate paper copy of this notice even if you have
already received a copy of the notice or have agreed to accept this notice
electronically.
VI. Our Duties
The practice is required by law to maintain the privacy of your
health information and to provide you with this Notice of our duties and
privacy practices. We are required to abide by terms of this Notice as may be
amended from time to time. We reserve the right to change the terms of this
Notice and to make the new Notice provisions effective for all protected health
information that we maintain. If the practice changes its Notice, we will
provide a copy of the revised Notice by sending a copy of the Revised Notice
via regular mail or through in-person contact.
VII. Complaints
You have the right to express complaints to the practice and to the
Secretary of Health and Human Services if you believe that your privacy rights
have been violated. You may complain to the practice by contacting the
practice’s Privacy Officer verbally or in writing, using the contact
information below. We encourage you to express any concerns you may have
regarding the privacy of your information. You will not be retaliated against
in any way for filing a complaint
VIII. Contact Person
The practice’s contact person for all issues regarding patient
privacy and your rights under the Federal privacy standards is the Privacy
Officer. Information regarding matters covered by this Notice can be requested
by contacting the Privacy Officer. Complaints against the practice can be
mailed to the Privacy Officer by sending it to:
Attn.: Privacy Officer
Pravin P. Puri, M.D.
130 Town Center Drive
Suite 201
Troy, MI 48084
The Privacy Officer can be contacted by telephone at (248) 362-2300.
IX. Effective Date
This Notice is effective April 14, 2003.