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HIPAA: Notice of Privacy Practices
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. You will be asked to acknowledge that you have received
our notice of privacy practices.
We understand that information about you and your health is very personal
and therefore, we will strive to protect your privacy as required by
law. We will only use and disclose your personal health information as
allowed by applicable law.
We are committed to excellence in the provision of state-of-the-art
health care services through the practice of patient care, education,
and research. Therefore, as described below, your health information
will be used to provide you care and may be used to educate health care
professionals and for research. We train our staff and workforce to be
sensitive about privacy and to respect the confidentiality of your personal
health information.
We are required by law to maintain the privacy of our patients' personal
health information and to provide you with notice of our legal duties
and privacy practices with respect to your personal health information.
We are required to abide by the terms of this Notice of Privacy Practices
so long as it remains in effect. We reserve the right to change the terms
of this Notice of Privacy Practices as necessary and to make the new
Notice of Privacy Practices effective for all personal health information
maintained by us. You may receive a copy of any revised notice at any
of our hospitals or doctors' offices, or a copy may be obtained by mailing
a request to the UPHS Privacy Office, 3rd floor, 3550 Market Street,
Philadelphia PA 19104-3329.
The terms of this Notice of Privacy Practices apply to the following
entities owned and operated by and affiliated with the Trustees of the
University of Pennsylvania operating as a clinically integrated health
care arrangement: the University of Pennsylvania Health System and its
subsidiaries, including but not limited to the Hospital of the University
of Pennsylvania, Pennsylvania Hospital, Penn Presbyterian Medical Center,
the Clinical Practices of the University of Pennsylvania(CPUP), Clinical
Care Associates(CCA), Penn Medicine at Radnor, Penn Center for Rehabilitation
and Care, Penn Home Infusion Therapy, Wissahickon Hospice, Penn Care
at Home, Penn Presbyterian Personal Care Residence, Inc., Penn Presbyterian
Anesthesiology Foundation, and Penn Presbyterian Multi-Specialty Group
Practice Foundation; the University of Pennsylvania School of Medicine,
and the physicians, licensed professionals, employees, volunteers, and
trainees seeing and treating patients at each of these care settings.
All of these entities and persons listed will share personal health information
of patients as necessary to carry out treatment, payment, and health
care operations as permitted by law. This Notice of Privacy Practices
does not apply when visiting a non-CPUP or non-CCA physician in their
private medical office.
USES AND DISCLOSURES OF YOUR PERSONAL HEALTH INFORMATION
The following categories detail the various ways in which we may use
or disclose your personal health information. For each category of
uses or disclosures we will give you illustrative examples. It should
be noted that while not every use or disclosure will be listed, each
of the ways we are permitted to use or disclose information will fall
into one of the following categories.
Your Authorization. Except as outlined below, we will not use
or disclose your personal health information for any purpose unless you
have signed a form authorizing the use or disclosure. This form will
describe what information will be disclosed, to whom, for what purpose,
and when. You have the right to revoke that authorization in writing,
except to the extent we have already relied upon it.
Uses and Disclosures for Treatment. We will make uses and disclosures
of your personal health information as necessary for your treatment.
For instance, doctors, nurses, and other professionals involved in your
care will use information in your medical record and information that
you provide about your symptoms and reactions to plan a course of treatment
for you that may include procedures, medications, tests, etc. We may
also disclose your personal health information to institutions and individuals
outside the University of Pennsylvania Health System and the University
of Pennsylvania School of Medicine that are or will be providingtreatment
to you.
Uses and Disclosures for Payment. We will make uses and disclosures
of your personal health information as necessary for payment purposes.
For instance, we may forward information regarding your medical procedures
and treatment to your insurance company to arrange payment for the services
provided to you or we may use your information to prepare a bill to send
to you or to the person responsible for your payment.
Uses and Disclosures for Health Care Operations. We will use
and disclose your personal health information as necessary, and as permitted
by law, for health care operations. This is necessary to run the University
of Pennsylvania Health System and the University of Pennsylvania School
of Medicine and to ensure that our patients receive high quality care
and that our health care professionals receive superior training. For
example, we may use your personal health information in order to conduct
an evaluation of the treatment and services we provide, or to review
the performance of our staff. And, for education and training purposes,
your health information may also be disclosed to doctors, nurses, technicians,
medical students, residents, fellows and others.
Our Facility Directory. We use information to maintain a directory
function listing your name, room number, general condition and, if you
wish, your religious affiliation. Unless you choose to have your information
excluded from this directory, the information, excluding your religious
affiliation, will be disclosed to anyone who requests it by asking for
you by name. This information, including your religious affiliation,
may also be provided to members of the clergy, even if they don't ask
for you by name. Please let our staff know when you check in or register
if you would like to have your information excluded from this directory
function.
Persons Involved In Your Care. Unless you object, we may in our
professional judgment disclose to a member of your family, a close friend,
or any other person you identify, your personal health information to
facilitate that person's involvement in caring for you or in payment
for that care. We may use or disclose personal health information to
assist in notifying a family member, personal representative or any other
person that is responsible for your care of your location and general
condition. Finally, we may also disclose limited personal health information
to a public or private entity that is authorized to assist in disaster
relief efforts in order for that entity to locate a family member or
other persons that may be involved in some aspect of caring for you.
Fundraising. We may contact you, at times in coordination with
your physician, to donate to a fundraising effort on our behalf. If we
contact you for fundraising purposes, you will be provided with the opportunity
to opt out of receiving any future solicitations.
Appointments and Services. We may use your personal health information
to remind you about appointments or to follow up on your visit.
Health Products and Services. We may from time to time use your
personal health information to communicate with you about treatment alternatives
and other health-related benefits and services that may be of interest
to you.
Research. We may use and disclose your personal health information
as permitted or required by law, for research, subject to your explicit
authorization, and/or oversight by the University of Pennsylvania Institutional
Review Boards, committees charged with protecting the privacy rights
and safety of human subject research, or similar committee. In all cases
where your specific authorization has not been obtained, your privacy
will be protected by confidentiality requirements evaluated by such committee.
This is necessary to investigate cutting-edge health care through improved
treatments, medications and outcomes research. For example, you may be
approached by your physician to ask if you would be interested in participating
in a clinical trial of a new drug for your condition. Or, your health
information may be used with the approval of the committee charged with
protecting the rights of research subjects, described above, to conduct
outcomes research to see if a particular procedure is effective.
Business Associates. Certain aspects and components of our services
are performed through contracts with outside persons or organizations,
such as auditing, accreditation, legal services, etc. At times it may
be necessary for us to provide certain of your personal health information
to one or more of these outside persons or organizations who assist us
with our payment/billing activities and health care operations. In such
cases, we require these business associates to appropriately safeguard
the privacy of your information.
Other Uses and Disclosures. We are permitted or required by law
to make certain other uses and disclosures of your personal health information
without your consent or authorization. Subject to conditions specified
by law:
- We may release your personal health information for any purpose required
by law;
- We may release your personal health information for public health
activities, such as required reporting of disease, injury, and birth
and death, and for required public health investigations;
- We may release your personal health information to certain governmental
agencies if we suspect child abuse or neglect; we may also release
your personal health information to certain governmental agencies if
we believe you to be a victim of abuse, neglect, or domestic violence;
- We may release your personal health information to entities regulated
by the Food and Drug Administration if necessary to report adverse
events, product defects, or to participate in product recalls;
- We may release your personal health information to your employer
when we have provided health care to you at the request of your employer
for purposes related to occupational health and safety; in most cases
you will receive notice that information is disclosed to your employer;
- We may release your personal health information if required by law
to a government oversight agency conducting audits, investigations,
inspections and related oversight functions;
- We may use or disclose your personal health information in emergency
circumstances, such as to prevent a serious and imminent threat to
a person or the public;
- We may release your personal health information if required to do
so by a court or administrative order, subpoena or discovery request;
in most cases you will have notice of such release;
- We may release your personal health information to law enforcement
officials to identify or locate suspects, fugitives or witnesses, or
victims of crime, or for other allowable law enforcement purposes;
- We may release your personal health information to coroners, medical
examiners, and/or funeral directors;
- We may release your personal health information if necessary to
arrange an organ or tissue donation from you or a transplant for you;
- We may release your personal health information if you are a member
of the military for activities set out by certain military command
authorities as required by armed forces services; we may also release
your personal health information if necessary for national security,
intelligence, or protective services activities; and
- We may release your personal health information if necessary for
purposes related to your workers' compensation benefits.
Confidentiality of Alcohol and Drug Abuse Patient Records, HIV-Related
Information, and Mental Health Records. The confidentiality of
alcohol and drug abuse patient records, HIV-related information, and
mental health records maintained by us is specifically protected by
state and/or Federal law and regulations. Generally, we may not disclose
such information unless you consent in writing, the disclosure is allowed
by a court order, or in limited and regulated other circumstances.
RIGHTS THAT YOU HAVE
Access to Your Personal Health Information. Generally, you have
the right to access, inspect, and/or copy personal health information
that we maintain about you. Unless you are currently a patient in our
hospital or during a scheduled appointment with a clinician, requests
for access must be made in writing and be signed by you or your representative.
We will charge you for a copy of your medical records in accordance with
a schedule of fees established by applicable state law. You may obtain
an access request form from the doctor's office or Medical Records department
of the hospital you visited.
Amendments to Your Personal Health Information. You have the
right to request that personal health information that we maintain about
you be amended or corrected. We are not obligated to make all requested
amendments but will give each request careful consideration. All amendment
requests, in order to be considered by us, must be in writing, signed
by you or your representative, and must state the reasons for the amendment/correction
request. If an amendment or correction you request is made by us, we
may also notify others who work with us and have copies of the uncorrected
record if we believe that such notification is necessary. Please note
that even if we accept your request, we may not delete any information
already documented in your medical record. You may obtain an amendment
request form from the doctor's office or Medical Records department of
the hospital you visited.
Accounting for Disclosures of Your Personal Health Information. You
have the right to receive an accounting of certain disclosures made by
us of your personal health information after April 14, 2003 except for
disclosures made for purposes of treatment, payment, and healthcare operations
or for certain other limited exceptions. Requests must be made in writing
and signed by you or your representative. Accounting request forms are
available from the doctor's office or Guest Services department of the
hospital you visited. The first accounting in any 12-month period is
free; you will be charged a fee of $20 for each subsequent accounting
you request within a 12-month period.
Restrictions on Use and Disclosure of Your Personal Health Information. You
have the right to request restrictions on certain of our uses and disclosures
of your personal health information for treatment, payment, or health
care operations. For example, you may request that we do not share your
health information with a certain family member. A restriction request
form can be obtained from the doctor's office or Guest Services department
of the hospital you visited. We are not required to agree to your restriction
request but will attempt to accommodate reasonable requests when appropriate
and we retain the right to terminate an agreed-to restriction if we believe
such termination is appropriate. In the event we have terminated an agreed
upon restriction, we will notify you of such termination.
Confidential Communications. You have the right to request communications
regarding your personal health information from us by alternative means
or at alternative locations and we will accommodate reasonable requests
by you. You must request such confidential communication in writing to
each department to which you would like the request to apply.
Paper Copy of Notice. As a patient you retain the right to obtain
a paper copy of this Notice of Privacy Practices, even if you have requested
such copy by e-mail or other electronic means. You may also print this
web page or download a copy (requires free
Adobe Acrobat Reader).
ADDITIONAL INFORMATION
Complaints. If you believe your privacy rights have been violated,
you may file a complaint in writing with the doctor's office or Guest
Services department of the hospital you visited. You may also file a
complaint with the Secretary of the U.S. Department of Health and Human
Services in Washington D.C. All complaints must be made in writing and
in no way will affect the quality of care you receive from us.
For further information. If you have questions or need further
assistance regarding this Notice of Privacy Practices, you may contact
us in writing at UPHS Privacy Office, 3rd floor, 3550 Market Street,
Philadelphia, PA 19104-3329, or by telephone at (215) 615-0638, or by
e-mail at privacy@uphs.upenn.edu.
Effective Date. This Notice of Privacy Practices is effective
August 1, 2004
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