Notice of Privacy Practices

Effective Date: January 2021
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

The Guthrie Clinic, including its affiliated entities, is required by law to maintain the privacy of Protected Health Information (PHI) and to provide each patient with The Guthrie Clinic “Notice of Privacy Practices” (“Notice”) detailing our legal duties and privacy practices with respect to PHI. A copy of the current Notice is posted in all our admissions and waiting areas. You will be provided with a copy of the Notice at the time of your initial visit to our facilities. You will also be able to obtain your own copy by accessing our website at www.Guthrie.org. or by calling the Privacy Officer at 1-888-841-4644 or guthrie.ethicspoint.com.

PHI is information that may identify you and that relates to your past, present, or future physical or mental health condition and related health care services. This Notice of Privacy Practices Guide outlines how we may use and disclose PHI to carry out treatment, payment or health care operations and for other specified purposes that are permitted or required by law. The Notice booklet details your rights with respect to your PHI. We are required to provide the Notice booklet to you by the Health Insurance Portability and Accountability Act (HIPAA).
The Guthrie Clinic is required to follow the terms contained in the “Notice of Privacy Practices”. We will not use or disclose your PHI without your written authorization, except as described or otherwise permitted in the Notice. We reserve the right to change our practices and the Notice and to make the new Notice effective for all PHI we maintain. Upon request, we will provide any revised Notice to you.

Examples of How We Use and Disclose Protected Health Information about You

The following categories describe different ways that we use and disclose your protected health information. We have provided you with examples in certain categories; however, not every use or disclosure in a category is listed.

Treatment: We may use your health information to provide and coordinate the treatment, medications, and services you receive. We may disclose medical information to doctors, nurses, technicians, administrators, staff, and others who are taking care of you in our system. We may also disclose medical information with non-Guthrie providers, treatment team members, agencies, business associates or facilities in order to provide treatment, coordination or continuity of your care.
Example: A doctor treating you for an injury asks another doctor about your overall health condition.

Payment: We may use your health information for various payment-related functions, and we may disclose medical information so that the treatment and services you receive may be billed and payment collected. We will bill you or a third-party payer for the cost of treatment, equipment, and supplies provided to you.
Example: We give information about you to your health insurance plan so it will pay for your services.

Health Care Operation: We may use your health information for certain operational, administrative, and quality assurance activities. We may use information in your health record to monitor the quality and performance and to comply with laws and regulations. This information will be used in an effort to continually improve the quality and effectiveness of the health care and services we provide.
Example: To reduce the infection rate after a surgery, it would be necessary to look at medical records to determine the rate of infections that occurred.

Appointment Reminders: We may contact you to remind you that you have an appointment at The Guthrie Clinic or provide information about treatment alternatives or other health-related benefits and services that may be of interest to you.

To Communicate with Individuals Involved in Your Care or Payment for Your Care: We may disclose to a family member, other relative, close personal friend or any other person you identify that PHI which is directly relevant to that person's involvement in your care or payment related to your care.

Notification: Unless you object, or as otherwise instructed by you, we may use or disclose your PHI to notify or assist in notifying a family member, personal representative, or another person responsible for your care or payment for your care, regarding your location, general condition, and in the unfortunate event of your death.

Patient Information Directory: While you are a hospital patient, your name, location, general condition (e.g., satisfactory) and your religious affiliation will be included in a patient information directory. Directory information, except for your religious affiliation, may be released to people who ask for you by name. Your religious affiliation may also be provided to members of the clergy of your congregation, even if they don’t ask for you by name. We will give you the opportunity to object to being included in the directory, unless an emergency situation prevents us from asking you.

We are permitted to use or disclose your PHI for the following purposes. The Guthrie Clinic may never have reason to make some of these disclosures.

Public Health: As required by law, we may disclose your PHI to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

Report Abuse: As required by law, we may disclose your PHI when the information relates to a victim of abuse, neglect, or domestic violence.

Law Enforcement: We may disclose your PHI for law enforcement purposes as required by law or in response to a subpoena or court order.

Lawsuits and Other Legal Actions: In connection with lawsuits or other legal proceedings we may disclose information in response to a court or administrative order or other lawful process.

As Required by Law: We will disclose your PHI when required to do so by federal, state, or local law.

Research: We may disclose your PHI to researchers when their research has been approved by an institutional review board or privacy board that has reviewed the research proposal and established protocols to ensure the privacy of your information.

Fundraising: We may use information about you to contact you in an effort to raise money for one or more of our facilities. We may use or disclose demographic and contact information (such as your name, address, phone, gender), the date and department of service and your treating physician. We will provide you an opportunity to opt out of these types of communications.

Marketing: We are not permitted to provide your health information to any other person or company for marketing to you of any products or services, unless with your express written authorization. We are also not permitted to receive payment in exchange for making such marketing communication to you. We may, however, provide you with marketing materials in a face-to- face encounter without obtaining your authorization. In addition, we may tell you about our own health care products and services relating to your treatment, case management or care coordination, or alternative treatments, therapies, providers or care settings without obtaining your authorization. We are also permitted to give you a promotional gift of nominal value, if we so choose, without obtaining your authorization. We will provide you an opportunity to opt out of these types of communications.

Respond to Organ and Tissue Donation Requests. We can share health information about you with organ procurement organizations.

Work with Coroners, Medical Examiner or Funeral Director. We can share health information with a coroner, medical examiner, or funeral director as permitted by law to carry out their duties; when an individual dies.

Workers’ Compensation: We may release medical information about you to programs that provide benefits for work-related injury or illness.

To Avert a Serious and Imminent Threat to Health or Safety. We may use your health information or share it with others when necessary to prevent a serious and imminent threat to your health or safety, or the health or safety of another person or the public.

Health Oversight Activities. We may disclose your medical information to health oversight organizations authorized to conduct audits, investigations, and inspections of our facilities.

Specialized Government Functions: We will disclose your PHI regarding government functions such as military, national security and intelligence activities. We will use or disclose PHI to the Department of Veterans Affairs to determine whether you are eligible for certain benefits.

Inmates. If you are an inmate of a correctional facility, we may disclose to the institution or agents of the institution health information necessary for your health and the health and safety of other individuals.

Other Uses and Disclosures of PHI: We will obtain your written authorization before using or disclosing your PHI for purposes other than those provided for above (or as otherwise permitted or required by law). You may revoke an authorization in writing at any time. Upon receipt of the written revocation, we will stop using or disclosing your PHI, except in the following situations:

The revocation does not apply:

To the extent that we have already taken action in reliance on the authorization; and If the authorization is to permit disclosure of PHI to an insurance company, as a condition of obtaining coverage, to the extent that other law allows the insurer to contest claims or coverage.

Your Health Information Rights 

Obtain a paper copy of the Notice upon request: You may request a copy of our current “Notice of Privacy Practices” at any time. You may obtain a paper copy throughout The Guthrie Clinic or on our website at www.Guthrie.org.

Request a restriction on certain uses and disclosures of PHI: You have the right to request additional restrictions on our use or disclosure of your PHI by sending a written request to the Privacy Officer. We may not be required to agree to those restrictions. We cannot agree to restrictions on uses or disclosures that are legally required, or which are necessary to administer our business. We will agree to restrictions to withhold information from a health plan where you, the individual, pay out-of-pocket in full for the services ahead of time.

Inspect and obtain a copy of PHI: In most cases, you have the right to access and copy the PHI that we maintain about you. To inspect or copy your PHI, you must send a written request to the Health Information Department. We may charge you a fee for the costs of copying, mailing and supplies that are necessary to fulfill your request. We may deny your request to inspect and copy in certain limited circumstances.

Request an amendment of PHI: If you feel the PHI we maintain about you is incomplete or incorrect, you may request that we amend it. To request an amendment, you must send a written request to the Privacy Officer. You must include a reason that supports your request. In certain cases, we may deny your request for amendment, but we will inform you of our decision within 60 days.

Receive an accounting of disclosures of PHI: You have the right to receive an accounting of the disclosures we have made of your PHI after April 14, 2003 for most purposes other than treatment, payment, or health care operations. The right to receive an accounting is subject to certain exceptions, restrictions, and limitations. To request an accounting, you must submit a request in writing to the Privacy Officer. Your request must specify the time period. The time period may not be longer than six years and may not include dates before April 14, 2003. We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Request communications of PHI by alternative means or at alternative locations: For instance, you may request that we contact you at a different residence or post office box. To request confidential communication of your PHI, you must submit a request in writing to the Privacy Officer. Your request must tell us how or where you would like to be contacted. We will accommodate all reasonable requests.

Notification of Breach: Affected individuals will be notified of breaches of their unsecured PHI pursuant to state and federal laws.

For More Information or To Report a Problem

If you have questions or would like additional information about The Guthrie Clinic privacy practices, you may contact our Privacy Officer at The Guthrie Clinic. If you believe your privacy rights have been violated, you can file a complaint with the Privacy Officer at 1-888-841-4644 or guthrie.ethicspoint.com or with the Secretary of Health and Human Services (HHS) at www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

The Guthrie Clinic reserves the right to change our privacy practices and the “Notice of Privacy Practices” at any time. We will make available the current Notice at all The Guthrie Clinic facilities and on our website at www.Guthrie.org. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

This Notice of Privacy Practices Applies to All of The Guthrie Clinic Entities. This initial Document was approved in 2003. The most recent prior update was December 2018.