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PRIVACY POLICY

NOTICE OF PROTECTED HEALTH INFORMATION PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU AND YOUR LOVED ONES MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW CAREFULLY.

 

I. Privacy

A. Respect for our participants’ and families’ privacy, especially with regard to medical information, has long been a consideration of the George G. Glenner Alzheimer’s Family Centers, Inc.® (GGG/AFC). The trust of our families is our most valuable asset. We understand that the proper handling of medical information is critical to earning that trust.

B. We are providing you with this notice in accordance with federal health privacy regulations that were issued as a result of the Health Insurance Portability and Accountability Act (“HIPAA”) of 1996. It obliges us to maintain the privacy of your medical information. We are required to:

1. Provide you with notice of our legal duties and privacy practices regarding your medical information.

2. Provide you with a paper copy of this notice upon your request, even if you receive it electronically.

3. Comply with the terms of our privacy regulation that are in effect. We reserve the right to change this notice, and such change will apply to all medical information we maintain. If we make a material change to this notice, we will promptly send a revised notice to all concerned. You may receive additional privacy notices from us with respect to personal and financial information.

C. This federal rule requires doctors, hospitals, and health care providers to take steps to increase the protection of medical information and gives participants new rights of which to be informed and new rights to manage their own records.

 

II. Medical Information Usage and Disclosure

A. Uses and disclosures and those incidentals to such are permitted without a signed authorization for the areas described below. We will not use your medical information for any other purpose, or disclose to any other person, unless we have your written authorization to do so.

B. We may use or share your medical information to: 1. Provide you with medical treatment or services.

2. Doctors, nurses, technicians, students, or other center personnel who are involved in taking care of your loved one at the center.

3. Examples of how your information may be used:

 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 center if you have diabetes so that we can arrange for appropriate meals.

 We may also share your medical information with other center personnel in order to coordinate the different services you need, such as prescriptions, lab work, and x-rays.

 We also may disclose your medical information to people outside the center who may be involved in your continuing medical care after you leave the center, such as other health care providers, transport companies, community agencies and family members.

C. For Payment: We are permitted to use and disclose your medical information for our payment related purposes or those of another insurer, health plan, or health care professional. Among payment related uses and disclosures that are permitted are:

1. Billing for the George G. Glenner Alzheimer’s Family Centers, Inc.®

2. Determining benefit eligibility

3. Related health care data processing collection and/or legal issues.

4. PACE billing

5. Payment collection

6. Third party payees, such as Veterans Administration, PACE, and others.

 

For Healthcare Operations: We are permitted to use and disclose your medical information for purposes related to our operations. We may also use and disclose such information in areas of medical review, utilization review, quality control, legal services or auditing, including fraud and abuse detection and program compliance. We may disclose information to doctors, nurses, technicians, medical students, and other center personnel for review and learning purposes. We may use and disclose such information for business planning and development to improve care or coverage procedures. We may include certain limited information about you in the center’s newsletter/calendar while you are a participant at the center. We may remove information that identifies you from this set of medical information so others may use to study health care and health care delivery without learning who the specific participants are. Information may also be used to comply with HIPAA policies.

D. Public health, government or similar activities: We are permitted to disclose your medical information:

1. To an authorized public health authority for public health purposes related to health or safety.

2. To an appropriate authority authorized to receive reports of abuse or neglect.

3. To a health oversight agency for authorized oversight activities as authorized or required by law (e.g. Department of Health Services, Department of Social Services Community Care Licensing, Department of Aging).

 

III. Authorization To Use and Disclose Medical Information

We are required to have the signed written authorization of you or your representative to use or disclose your medical information. You have the right to revoke in writing at any time any authorization you give to us. We may also use or disclose your medical information for judicial or law enforcement purposes to avert a serious threat to health or safety, or for worker’s compensation or similar purposes as authorized or required by law.

A. Individuals Involved in Your Care or Payment for Such Care: If you send us a written request, we will disclose your medical information that we have to you. We may disclose your medical information to your family member, friend, personal representative, or other individual you identify who is involved in your care or finances, but we will first give you an opportunity to give or withhold your consent, where possible. If you are not available to give your consent to such a disclosure or in an emergency, we may disclose your medical information that is directly relevant to such person’s involvement with your care or payment for such care. HIPAA requires that a personal representative be treated as the individual for purposes of use or disclosure of personal medical protected information. This includes the representatives of adults. In determining who is a personal representative of a participant California law would apply. We may elect not to treat a person as a personal representative if in the professional judgment of the GGG/AFC provider there is reasonable belief the participant has been or may be subjected to domestic violence, abuse or neglect by such person; or treating such person as the personal representative could otherwise endanger the participant; and it is not in the best interest of the participant to treat the person as the individual representative. In such a situation a referral to the appropriate oversight agency would be implemented.

B. Appointment Reminders: We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at the Center.

C. Health-Related Benefits and services: We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

D. Fundraising Activities: We may contact you to provide information about the GGG/AFC sponsored activities, including fundraising programs and events. We would only use contact information, such as your name, address, e-mail address, and phone number. If you do not want the GGG/AFC to contact you for fundraising efforts, you must notify the Administrator in writing.

E. Research: Under certain circumstances, we may use and disclose medical information about you for research purposes. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with participants' need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, but we may, however, disclose medical information about you to people preparing to conduct a research project, for example, to help them look for participants with specific medical needs, so long

as the medical information they review does not leave the Center. We will almost always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at the Center.

 

Rights Regarding Your Medical Information

A. Request Restrictions: You have the right to request a restriction or limitation on the medical information we use or disclose about your medical information that otherwise would be permitted. This must be done in writing and be specific as to your restriction of data.

B. Inspect and Copy: You have the right to inspect and obtain a copy of your medical information maintained in our records but not information we compile in anticipation of a legal proceeding. To make a request, please submit it in writing to the address at the end of this notice. We have a right to decline your request in limited situations, such as where a doctor or other health professional has determined that substantial harm could be caused to you or another person by giving your medical information to you. In that event, you would be given a right to have such denials reviewed by alternate health care professional designated by us. We will give you a written explanation and advise you of your rights to pursue a review of your decision. We will respond to your request for access within thirty (30) days of receiving your written request.

C. Confidential Communications: You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. You may request that we send your medical information to you at a different location or by means other than mail. Any such request should be sent in writing. We will respond within 30 days.

D. Amendment Rights: You have the right to request that we amend your medical information in our records if you believe it is inaccurate or incomplete. We will respond to your written request within thirty (30) days. If we accept the validity of your request, we will amend all appropriate records. We may deny your request if the record was not created by the GGG/AFC, is accurate or if it relates to an anticipated legal proceeding. In that case, we will tell in writing why we declined your request and permit you to submit a written statement of disagreement.

E. Accounting: You have the right to request an accounting of disclosures we made of your medical information. We will respond to your written request within 30 days.

 

CONTACTING US

If you have any concerns about your privacy rights, please send your request in writing to the GGG/AFC at the address below. If you believe your privacy rights have been violated, you may file a complaint with:

The George G. Glenner Alzheimer’s Family Centers, Inc.®
2765 Main St., Suite A
Chula Vista, CA 91911

Phone number: (619) 543-4700

Be sure to include the following information in your request:

  • Your full name
  • Full address and zip code
  • Full phone number and area code
  • Detailed information relating to your request.

A written complaint may also be submitted to:

Department of Public Health (for ADHC)
7575 Metropolitan Drive, #211, San Diego, CA 92108 | (619) 688-6190

Dept. of Social Services, Community Care Licensing (for ADP)
7575 Metropolitan Drive, #109, San Diego, CA 92108 | (619) 767-2301

We reserve the right to change the privacy practices of the GGG/AFC. This notice will contain an effective date on the first page in top right-hand corner. You may at any time request a copy of the current notice in effect. It will be posted at corporate office and at each GGG/AFC center.

We will retain our records of the care provided to you as required by law. We are committed to protecting your personal medical information and we will implement policies and practices that will enable us to reasonably and appropriately protect your privacy while carrying out our mission of care, service, and education.