Notice of Privacy Practices
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU AND/OR YOUR CHILD MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
This Notice is provided to you as the parent/guardian on behalf of St. Christopher’s, Inc. and the agency’s service providers with medical and clinical privileges. We understand that your and/or your child’s medical information is private and confidential. Furthermore, we are required by law to maintain the privacy of “protected health information” or PHI. PHI includes any individually identifiable information that we obtain from you or others that relates to your and/or your child’s past, present or future physical or mental health, the health care your child has received, or payment for your child’s health care. We will share PHI with one another, as necessary, to carry out treatment, payment or health care operations relating to the services to be rendered at St. Christopher’s, Inc. facilities.
St. Christopher’s, Inc. is required to abide by the terms of this Privacy Notice. The Notice may be amended or updated from time to time. Should that happen the new Notice will be effective for all PHI at that time, and the updated Privacy Notice will be posted on our website and at our locations. Upon request, St. Christopher’s, Inc. will provide you with the most current Notice or you can access it on our website at http://stchristophersinc.org.
How We May Use and Disclose Medical Information
Your and/or your child’s PHI may be used and shared by appropriate St. Christopher’s, Inc. administrative, supervisory or treatment team members that are involved in your and/or your child’s care for the purpose of providing services to you. The following examples are not meant to include all possibilities:
For Treatment: To provide you and/or your child with medical treatment or services, we may need to use or disclose information about you and/or your child to professionals involved in treatment. For example, our medical staff may need to review the medical history or consult with another healthcare provider before providing treatment.
For Payment: We may use and disclose PHI to bill and receive payment for treatment received from us. For example, we may share medical information about your insurance company to determine whether the proposed course of treatment will be covered or to obtain payment.
For Health Care Operations: We can use and disclose PHI about you and/or your child for our operations. These uses and disclosures are necessary to run our organization and make sure our clients receive quality care. For example, we may use your PHI to decide what additional services to offer and what services are not needed.
Other Uses and Disclosures of Medical Information that Do Not Require Your Authorization
We can use or disclose PHI without your authorization when there is an emergency, when we are required by law to treat your child, or when we are required by law to use or disclose certain information. We may use or disclose PHI without your authorization in any of the following circumstances:
- To a personal representative who has the authority to make health care decisions for you and/or your child.
For public health activities, such as reporting child abuse or neglect.
- To avoid a serious threat to another’s health and safety.
- For health oversight activities, such as audits and inspections.
- As required by law and law enforcement.
- For specialized government functions.
- With correctional institutions if you and/or your child are an inmate of the facility.
- If emergency treatment is required and the provider has been unsuccessful in obtaining your consent.
- For research projects approved by a review board.
- To business associates with whom the agency contracts to provide you and/or your child or the agency with a service. St. Christopher’s, Inc. will have written assurance that the associate will maintain the same standards of safeguarding your and/or your child’s privacy that we require of our employees.
- In public relations situations, only when the information has been de-identified.
- Special situations such as organ and tissue donation; military and veteran requests for information; worker’s compensation; national security and intelligence; and to coroners, medical examiners or funeral directors as necessary.
If your authorization is needed, and you provide St. Christopher’s, Inc. authorization to use or disclose PHI about you, you may revoke that permission, in writing, at any time by sending a notice of revocation to the HIPAA Compliance Officer at the address provided below. If you revoke your permission, St. Christopher’s, Inc. will no longer use or disclose PHI about you for the reasons covered by your written authorization. St. Christopher’s, Inc. will not be able to reverse any disclosures made prior to your revocation.
St. Christopher’s, Inc. may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.
Note: Special rules may apply with respect to the use and disclosure of genetic and HIV testing information. You may contact the HIPAA Compliance Officer for more information about these rules.
Use of Psychotherapy Notes
St. Christopher’s, Inc. must obtain an authorization from you for any use or disclosure of psychotherapy notes pertaining to your and/or your child’s sessions except to carry out the following treatment, payment, or health care operations:
- Your and/or your child’s therapist, who wrote the notes, may use them for treatment.
St. Christopher’s, Inc. may use or disclose what is contained in the psychotherapy notes in our own training programs in which staff or residents learn, under supervision, to practice or improve their skills in individual, group, joint, or family counseling.
- St. Christopher’s, Inc. may use psychotherapy notes pertaining to the sessions to defend itself in a legal action or other proceeding brought against our organization by you and/or your child.
- St. Christopher’s, Inc. may use or disclose psychotherapy notes without written authorization when legally required by law, to investigate St. Christopher’s Inc. compliance, for use of oversight of the therapist who wrote them, to a coroner or medical examiner, or to avert serious threats to health or safety.
Your Rights Regarding Protected Health Information
- Right to obtain a paper copy of this Notice of Privacy Practices upon request.
- Right to Inspect and Copy Your and/or Your Child’s Health Information: You have the right to inspect and copy certain health information. We ask that you make such a request in writing, sign it, date it, and send it to the HIPAA Compliance Officer at the address listed below. If you request copies of information, we may charge a reasonable fee to cover copying, mailing, and other costs and supplies associated with your request. In certain situations, St. Christopher’s may deny your request, but you have the right to have the denial reviewed.
- Right to Request Information in Certain Form and Location: You have the right to request to receive confidential communications of the PHI by alternative means or at alternative locations. You may request an electronic copy of the health record if maintained in that format. The agency must accommodate all reasonable requests if you state in writing that the disclosure of the information though normal channels could endanger you and/or your child. We ask that you make such a request in writing, sign it, date it, and send it to the HIPAA Compliance Officer at the address listed below.
- Right to Request Amendment to Health Information: You have a right to request that certain health information be amended if you believe that it is incorrect or incomplete. This request must be in writing, signed, and dated, and include the reason that supports your request. It should be sent to the HIPAA Compliance Officer at the address listed below. St. Christopher’s may deny the request if it is determined that the record was not originally created by St. Christopher’s, the information is not available for inspection, or is accurate and complete.
- Right to Request Restrictions: You have the right to ask that we limit our use or sharing of information about you and/or your child for treatment, payment, or health care operations. You also have the right to ask us to limit the medical information we disclose about you and/or your child to someone who is involved in the care or the payment for the care. We reserve the right to accept or reject most requests. Generally, we will not accept restrictions for treatment, payment, or health care operations. If we do agree, our agreement must be in writing, and we will comply with the restriction unless the information is needed to provide emergency treatment for you. You do, however, have the right to restrict certain disclosures of protected health information to a health plan if you pay for health care items or St. Christopher’s, Inc. services out of pocket in full; we must comply with such a request. If we agree to restrict our use or sharing of your information we are allowed to end the restriction if we tell you, unless you have paid for items or services in full out of pocket. If we end the restriction, it will only affect medical information that was created or received after we notify you.
- Right to Receive an Accounting of Disclosures: You have the right to receive an accounting of disclosures of PHI made by us to individuals or entities other than you for the six years prior to the date on which we receive the request. This list will not include uses or disclosures:
- to carry out treatment, payment, or health care operations;
- incidental to a use or disclosure otherwise permitted or required by law;
- to persons involved in your and/or your child’s care;
- for national security or intelligence purposes;
- to correctional institutions or law enforcement officials;
- as part of a limited data set.
Any request for this accounting must be made in writing to the Privacy Officer at the address listed below. Your request must state the time period for which you want the list, which may not exceed six years.
- Right to Breach Notification: You have the right to be notified following a breach of your and/or your child’s unsecured PHI.
How to Ask a Question or Report a Complaint
If you have questions about this Notice or want to talk about a problem without filing a formal complaint, please contact the HIPAA Compliance Officer at 914-693-3030. If you believe your and/or your child’s privacy rights have been violated, you may file a written complaint with us.
Please send it to the Compliance Office at St. Christopher’s, Inc. 71 South Broadway Dobbs Ferry, NY 10522 Attn: Privacy Issues. You may also file a complaint with the Secretary of the Department of Health and Human Services by contacting the Office for Civil Rights, DHHS – Jacob Javits Federal Building, 26 Federal Plaza Suite 3312; New York, NY 10278; Phone: (800) 368-1019; TDD: (800) 537-7697; Fax: (202) 619-7697. You will not be treated differently for filing a complaint.
EFFECTIVE DATE OF THIS NOTICE: OCTOBER 1, 2016
4831-0083-3839, V. 1