Notice of Rights

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.

Centers for Independence and its affiliates are required by law to maintain the privacy of your personal health information and to provide you with this notice of our legal duties and privacy practices concerning your personal health information as defined in the Privacy Rule of the Health Insurance Portability and Accountability Act of 1996. 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 personal health information that you designate may be available for release if you sign an authorization form, if you request the information for yourself, to a provider regarding your treatment, or due to a legal requirement. You have a right to be notified following a breach of your personal health information.

We must follow the privacy practices described in this notice. However, we reserve the right to change the privacy practices described in this notice, in accordance with the law. If we change our privacy practices, you will receive a revised copy. This notice will be posted in all of our offices and on our web sites.

How Your Health Information May be Used and Disclosed

Without your written authorization, we can use your health information for the following purposes:

Treatment: We may use your health information to provide, coordinate and manage care to you and disclose your health information to others who also provide care to you. This may involve our Psychiatrist, Pharmacist, Case Managers, Nurses and other staff talking to other health care providers or doctors about your care. If we are treating you for HIV or AIDS we will not release your information unless you give us permission; we are required to by law; or a court order or subpoena requires us to release the information.

Assist in payment activities: These activities include determining eligibility for plan benefits, facilitating payment for the treatment or for services you receive from health care providers, determining plan responsibility for benefits, and coordinating benefits. We may need to include your health information in invoices or electronic transactions to collect payment from third parties or an insurance company for the services we have provided. As a result, we will pass such health information onto an insurer in order to help receive payment for your medical bills.

Health Care Operations: We may use and disclose health information in order to conduct our own health care operations and in order to provide quality care to all of our clients. Some of these health care operations are as follows:

• Quality Assessment and improvement activities;
• activities designed to improve health or reduce health care costs;
• contacting health care providers and patients with information about treatment alternatives and other related functions that do not include treatment;
• professional review and performance evaluation;
• training programs including those in which trainees or students in health care learn under supervision;
• accreditation, certification, licensing or credentialing activities and also reviews and audits conducted by CFI, its affiliates and staff, CARF, The Joint Commission, county governments and the Wisconsin Department of Health Services;
• business planning and development including cost management and planning related analysis and formulary development;
• business management and general administrative activities.

For example, we may look at your medical record to determine the date and time of your next appointment with us, and then send you a reminder letter to help you remember the appointment. Or, we may look at your medical information and decide that another treatment or a new service we offer may interest you.

Your health information may be disclosed to another entity that has a relationship with you and is subject to the federal Privacy Rules, for their health care operations relating to quality assessment and improvement activities, reviewing the competence or qualifications of health care professionals, or detecting or preventing heath care fraud and abuse.

Health information may be shared with family members or friends when you indicate they are involved in your medical care. In certain disasters and related emergency situations, health information about you may be shared with disaster relief organizations (such as the Red Cross, etc.) so that your family can be notified about your condition, status and location. If you agree or, if you are unavailable to agree, when the situation, such as medical emergency or disaster relief, indicates that disclosure would be in your best interest, your health information may be disclosed to the extent necessary to help with your health care or with payment for your health cares.

Furthermore, we may want to use information found in your medical record, such as your name, address, phone number and treatment dates, to contact you for our fund-raising purposes. You may choose to opt out of such communications.

As required or permitted by law. Sometimes we must report some of your health information to legal authorities, such as law enforcement officials, court officials, or government agencies. For example, we may have to report abuse, neglect, domestic violence or certain physical injuries, or to respond to a court order.

For health oversight activities. We may disclose your health information to authorities so they can monitor, investigate, inspect, discipline or license those who work in the health care system or for government benefit programs. This includes but is not limited to CARF, The Joint Commission, Wisconsin Department of Health Services and Milwaukee County. Examples of situations that may require release of health information about you include: emergencies, as a matter of public health record, health or safety threats, health oversight and audit activities, national security, research studies, coroners, medical examiners, funeral directors, organ/tissue donation, and workers’ compensation.

NOTE: Except for the situations listed above, we must obtain your specific written authorization for any other release of your health information. A separate authorization is required for psychotherapy notes, using PHI for marketing or for any disclosure constituting the sale of PHI.

If you sign an authorization form, you may withdraw your authorization at any time, as long as your withdrawal is in writing. If you wish to withdraw your authorization, please submit your written withdrawal to CFI Client Records Department.

Your Health Information Rights

You have several rights with regard to your health information. If you wish to exercise any of the following rights, please contact in writing the CFI Client Records Department.

• Inspect and copy your health information. With a few exceptions, you have the right to inspect and obtain a copy of your health information; this also pertains to records kept in an electronic format. To do so, you must submit your request in writing. We will provide this information within 30 days of your request or provide a written explanation of any delay. However, this right does not apply to psychotherapy notes or information gathered for legal proceedings, for example.
• Request to correct your health information. If you believe your health information is incorrect, you may ask us to correct the information. You may be asked to make such requests in writing and to give a reason as to why your health information should be changed. However, if we did not create the health information that you believe is incorrect, or if we disagree with you and believe your health information is correct, we may deny your request. We will notify you within 60 days of our decision. You may appeal our decision by sending a written request to CFI, Attention: Privacy Officer.
• Receive a record of disclosures of your health information. As a provider who uses electronic records you have a right to request an accounting of disclosures made for payment, treatment, and healthcare operations for the prior six years from the date of your request. This list must include the date of each disclosure, who received the disclosed health information, a brief description of the health information disclosed, and why the disclosure was made. We must comply with your request for a list within 60 days, unless you agree to a 30-day extension, and we may not charge you for the list, unless you request such list more than once per year. In addition, we will not include in the list disclosures made to you, or for national security, to law enforcement or corrections officials, and certain health oversight activities.
• As applicable, receive confidential communication of health information. You have the right to ask that we communicate your health information to you in different ways or places. You may do so by sending a request in writing to CFI Client Records Department. For example, you may wish to receive information about your health status in a special, private room or through a written letter sent to a private address. We must accommodate reasonable requests.
• Obtain a paper copy of this notice. Upon your request, you may at any time receive a paper copy of this notice.
• Complaint. If you believe your privacy rights have been violated, you may file a complaint with us and with the federal Department of Health and Human Services. We will not retaliate against you for filing such a complaint. To file a complaint with either entity, please contact the CFI Privacy Officer, who will provide you with the necessary assistance and paperwork.

Again, if you have any questions or concerns regarding your privacy rights or the information in this notice, please contact the CFI Privacy Officer at 414-937-2020