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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.

Contents:


USE AND DISCLOSURE OF HEALTH INFORMATION

Milwaukee Catholic Home is required by law to maintain the privacy of your health information. Milwaukee Catholic Home (“We”) (“MCH”) is also required by law to provide you with this Notice of Privacy Practices (“Notice”) that describes our legal duties and privacy practices and your privacy rights with respect to your health information so that you will understand how we may use or share your information from your Designated Record Set.  The Designated Record Set includes financial and health information referred to in this Notice as “Protected Health Information” (“PHI”) or simply “health information.”

When using or disclosing health information, we adhere to Health Information Portability and Accountability Act ( HIPAA)’s minimum necessary rule which states that when a covered entity uses or discloses health information, they must take reasonable steps to limit the use or disclosure of, and requests for, protected health information to the minimum necessary to accomplish the intended purpose.

Milwaukee Catholic Home is required by law to adhere to the privacy practices outlined in this Notice.

HOW MILWAUKEE CATHOLIC HOME MAY USE OR DISCLOSE YOUR HEALTH INFORMATION FOR TREATMENT, PAYMENT AND HEALTH CARE OPERATIONS

The following categories describe the ways MCH may use or disclose your health information. Not every use or disclosure in a category will be listed.  However, all of the ways we are permitted to use and disclose information will fall into one of the categories.

  • For Treatment.  We may use or disclose health information about you to provide you with medical treatment. We may disclose health information about you to doctors, nurses, therapists or other MCH personnel who are involved in taking care of you while at MCH. Our methods of communication may be by land-line telephone, cell-phones, e-mail, fax or United States Postal Service. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process.  In addition, the doctor may need to tell the dietitian if you have diabetes so that we can plan your meals. Different departments of MCH may also share health information about you in order to coordinate your care and provide you with medication, lab work and x-rays.  We may also disclose health information about you to people outside MCH known as Business Associates, who may be involved in your medical care while a patient of or after you leave MCH.  This may include the facilities medical director, ancillary services (i.e. lab and radiology companies) and visiting nurses to provide care in your home.
  • For Payment.  We may use and disclose health information about you so that the treatment and services you receive at MCH may be billed to you, an insurance company or a third party.  For example, we may use your information to send a bill to your insurance provider for reimbursement of the health care services provided to you by MCH. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
  •  For Health Care OperationsMCH may use and disclose health information about you for our day-to-day health care operations.  This is necessary to ensure that all residents receive quality care.  Healthcare operations include activities such as:
    • Quality assessment and improvement activities.
    • Activities designed to improve health or reduce healthcare costs.
    • Protocol development, case management and care coordination.
    • Contacting health care providers and residents 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 students, trainees, or practitioners in health care learn under supervision.
    • Training of non-healthcare professionals.
    • Accreditation, certification, licensing, or credentialing activities.
    • Review and auditing, including compliance reviews, medical reviews, legal services, and compliance programs.
    • Business planning and development including cost management and planning-related analyses and formulary development.
    • Business management and general administrative activities of MCH.
    • Fundraising for the benefit of MCH and certain marketing activities.

For example, MCH may use your health information to evaluate its staff performance, combine your health information with other MCH residents in evaluating how to more effectively serve all of MCH’s residents, disclose your health information to MCH staff and contracted personnel for training purposes, use your health information to contact you or your family as part of general fundraising and community information mailings (unless you tell us you do not want to be contacted). We may remove information that identifies you so that the health information may be used to study health care and health care delivery without learning the identities of residents.  Unless you object, we may disclose your age, birth date and general information about you on our activities calendar, and to entities within the MCH community that wish to acknowledge your birthday or commemorate your achievements on special occasions.

HOW MILWAUKEE CATHOLIC HOME MAY USE OR DISCLOSE YOUR HEALTH INFORMATION WITHOUT YOUR WRITTEN AUTHORIZATION

  • As Required By Law.  We will disclose health information about you when required to do so by federal, state or local law.
  • Reporting Federal and state laws may require or permit MCH to disclose certain health information related to the following:
    • Public Health Risks.  We may disclose health information about you for public health purposes, including:
      • Prevention or control of disease, injury or disability
      • Reporting births and deaths;
      • Reporting child abuse or neglect;
      • Reporting reactions to medications or problems with products;
      • Notifying people of recalls of products;
      • Notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease;
      • Notifying the appropriate government authority if we believe a resident has been the victim of abuse, neglect or domestic violence.  We will only make this disclosure if you agree or when required or authorized by law.
    • Health Oversight Activities.  We may disclose health information to a health oversight agency for activities authorized by law.  These oversight activities may include audits, investigations, inspections, and licensure.  These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
    • Judicial and Administrative Proceedings:  If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order.  We may also disclose health information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
    • Reporting Abuse, Neglect or Domestic Violence:  Notifying the appropriate government agency if we believe a resident has been the victim of abuse, neglect or domestic violence.
  • Law Enforcement.  We may disclose health information when requested by a law enforcement official:
  • In response to a court order, subpoena, warrant, summons or similar process;
  • To identify or locate a suspect, fugitive, material witness, or missing person;
  • About you, the victim of a crime if, under certain limited circumstances, we are unable to obtain your agreement;
  • About a death we believe may be the result of criminal conduct;
  • About criminal conduct at MCH; and
  • In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime. 
  • Coroners, Medical Examiners and Funeral Directors.  We may disclose medical information to a coroner or medical examiner.  This may be necessary to identify a deceased person or determine the cause of death.  We may also disclose medical information to funeral directors as necessary to carry out their duties. 
  • Organ and Tissue Donation.  If you are an organ donor, we may disclose health information to organizations that handle organ procurement to facilitate donation and transplantation.
  • In the Event of a  Serious Threat to Health or Safety.  We may use and disclose health information about you in good faith if we believe it will prevent a serious threat to your health and safety or the health and safety of the public or another person.
  • Specialized Government Functions.  Federal regulations allow the use and disclosure of health information about you to authorized federal officials for intelligence, counterintelligence, protective services for the President and other national security activities authorized by law. 

If you are a member of the armed forces, we may disclose health information about you as required by military authorities.  We may also disclose health information about foreign military personnel to the appropriate foreign military authority.

  • Treatment Alternatives and Health Related Benefits.  We may use and disclose health information to tell you about possible treatment options or alternatives or other health related benefits and services that may be of interest to you. 
  • Milwaukee Catholic Home Directory.  We may include information about you in MCH directory while you are a resident.  This information may include your name, location in MCH, your general condition (e.g., fair, stable, etc.) and your religion.  The directory information, except for your religion, may be disclosed to people who ask for you by name.  Your religion may be given to a member of the clergy, such as a priest or rabbi, even if they don’t ask for you by name.  This is so your family, friends and clergy can visit you in MCH and generally know how you are doing.  We are obligated to give you information regarding the directory and the opportunity for you to decide if you want to object the release of this information from our directory.

Unless you object, we may disclose health information about you someone whom you have identified as a friend, family member or person who is involved in your care or helps pay for your care.  In addition, we may disclose health information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.

  • Research.  Under certain circumstances, we may use and disclose health information about you for research purposes.  For example, a research project may involve comparing the health and recovery of all residents who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process.  This process evaluates a proposed research project and its use of health information, trying to balance the research needs with residents’ need for privacy of their health information.  Before we use or disclose health information for research, the project will have been approved through this research approval process.  We may, however, disclose health information about you to people preparing to conduct a research project so long as the health information they review does not leave a MCH.

WHEN MILWAUKEE CATHOLIC HOME IS REQUIRED TO OBTAIN AN AUTHORIZATION TO USE OR DISCLOSE YOUR HEALTH INFORMATION

Except as described in this Notice of Privacy Practices, MCH will not use or disclose your health information without written authorization from you. For example, uses and disclosures made for the purpose of psychotherapy, marketing and the sale of protected health information require your authorization.

We may use health information about you to contact you in an effort to raise money as part of a fundraising effort.  You have a right to opt out of receiving communications from MCH for the purpose of fundraising.

If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time.  If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization.  You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU

Although your health record is the property of MCH, the information contained in your health record belongs to you.  You have the following rights regarding your health information:

  • Right to Inspect and Request a Copy.  You have the right to inspect and obtain a copy of your health care information. You have the right to request that the copy be provided in an electronic form or format (e.g., PDF saved onto CD). If the form and format are not readily producible, then the organization will work with you to provide it in a reasonable electronic form or format.  This right of access does not apply to psychotherapy notes, which are maintained for the personal use of a mental health professional. Your request for inspection or access must be submitted in writing to MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308. In addition, we may charge you a reasonable fee, as allowed by law, to cover our expenses for copying your health information.
  • Right to Amend.  If you feel that health information in your record is incorrect or incomplete, you have a right to request an amendment to your health information.  For example, if you believe the date of your joint replacement surgery is incorrect; you may request that the information be corrected.  To request an amendment, you must contact MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308 to make your request in writing on the form provided. You must also provide a reason for your request.
    • We may deny your request for an amendment if it is not in writing or does not include a reason to support the request.  In addition, we may deny your request if you ask us to amend information that:
    • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
    • Is not part of the health information kept by or for MCH; or
    • Is accurate and complete.

  • Right to an Accounting of Disclosures.  You have the right to request an “accounting of disclosures”.  This is a list of certain disclosures we made in compliance with state and federal laws, of your health information. This list will 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.

You must submit your request in writing to MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308.  Your request must state a time period which may not be longer than six years from the date the request is submitted and may not include dates before April 14, 2003.  Your request should indicate in what form you want the list (for example, on paper or electronically).  The first list you request within a twelve month period will be free.  For additional lists, we may charge you for the costs of providing the list.  We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

  • Right to Request Restrictions.  You have the right to request a restriction or limitation on the health information we use or disclose about you.  For example, you may request that we limit the health information we disclose to someone who is involved in your care or the payment for your care. You could ask that we not use or disclose any health information about you to any particular family member or friend. Also, you have a right to restrict use or disclosure of your health information to a health plan if you have paid for a service in full and out of pocket. For example, if you had a procedure done and you paid out of pocket for that procedure, you may request any information regarding that procedure is not to be disclosed to your health plan.

We are not required to agree to your request for restrictions.  You must submit your request in writing to MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308.  In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.

  • Right to Request Alternate Communications.  You have the right to request that we communicate with you about medical matters in a confidential manner or at a specific location.  For example, you may ask that we only speak to you about your health status in a private area, away from family or via a written letter.

You must submit your request in writing to MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308.  We will not ask you the reason for your request.   Your request must specify how or where you wish to be contacted. We will accommodate all reasonable requests.

  • Right to a Paper Copy of This Notice.  You have the right to a paper copy of this Notice of Privacy Practices even if you previously agreed to receive the Notice electronically.  You may ask us to give you a copy of this Notice at any time.

 

This Notice of Privacy Practices is available on the MCH website at www.milwaukeecatholichome.org or a paper copy can be obtained by sending a request in writing to MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308.

  • Right to be Notified in the Event of a Breach. Your provider is required by law to maintain the privacy of your protected health information and provide you with notice of its legal duties and privacy practices with respect to protected health information and to notify you following any breach of unsecured protected health information.

“Unsecured” is defined as health information that is not secured through the application of a technology or methodology that renders it unusable, unreadable, or indecipherable to unauthorized individuals and that meets standards specified in guidance published by the government.

  • Right to File a Complaint. If you believe your privacy rights have been violated, you have a right to file a complaint with MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308 who will provide you with any additional assistance with your complaint or offer you additional information on how to file a complaint with the Secretary of the Department of Health and Human Services.  All complaints must be submitted in writing to help better assist you with the investigation of your complaint. You will not be penalized or retaliated against for filing a complaint.

CHANGES TO THIS NOTICE

We reserve the right to change the privacy practices described in this Notice to coincide with current laws.  We reserve the right to make the revised or changed Notice effective for health information we already have about you as well as any information we receive in the future.  We will post a copy of the current Notice in a conspicuous place at MCH and on the MCH website at www.milwaukeecatholichome.org.   In addition, if changes are made to this Notice, the Notice will contain an effective date for the revisions and copies will be made available by contacting MCH’s Health Information Coordinator/ Privacy Officer at 414-220-4610 extension 3308.

If you have any questions about this Notice, please contact MCH’s Privacy Officer at 414-220-4610 extension 3308.

Effective Date of This Notice: September 23, 2013