THE CHILDREN’S INSTITUTE OF PITTSBURGH
NOTICE OF PRIVACY PRACTICES
Effective Date: October 30, 2006
Revised: July 24, 2013
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED (SHARED) AND HOW YOU CAN GET ACCESS TO (SEE AND COPY) THIS INFORMATION. PLEASE REVIEW THIS CAREFULLY.
The Children’s Institute of Pittsburgh (CI) understands that your or your child’s health information is personal. We create and maintain a record with information about the medical care and services that each patient/student/client (henceforward referred to as Individual) receives at CI. We need this information to provide quality care and to comply with the law. This Notice of Privacy Practices (Notice) applies to all information about your care that CI may create, maintain or receive, including information we receive from other doctors and medical facilities that are not part of CI but that we keep to help give you better care. This Notice tells you about the ways we may use and share your health information, as well as the legal duties we have concerning your health information. This Notice also tells you about your rights under the laws of the United States and Pennsylvania. For purposes of this Notice, the use of the words “we”, “us” and “our” mean CI and all the people and places that make up CI which are described below. Also, throughout this notice when we refer to your medical information, this will mean you or your child’s medical information.
CI is comprised of three main components (the Hospital, The Day School and Project STAR) and offers services at a number of locations, such as our hospital and its satellites. This notice applies to hospital services and Project STAR medical foster care services. This also includes all departments, units and staff within our health care facilities, all health care professionals permitted by us to provide services to you, and students, residents, trainees, volunteers and others involved in providing your care. These places and people may share your health information with each other for the treatment, payment, or health care operations that this Notice describes. All these places and people follow this Notice.
Our Pledge to Protect Your Health Information
We are required by law to make sure that information that identifies you is kept private. We are also required to make available to you this Notice of Privacy Practices that describes how we use and share your health information as well as your rights under the law about your health information and to follow the Notice of Privacy Practices that is currently in effect.
The law permits us to use and share your health information in certain ways. The list below tells you about different ways that we may use your health information and share it with others, as well as some examples of what we mean. When sharing this information with others outside of CI, we share only what is reasonably necessary, unless we are sharing information to help treat you; in response to your written permission, or as the law requires. In these three cases we share all information that you, your health care provider or the law has asked for. We will use health information that does not identify you whenever possible. Every possible example of how we may use or share information is not listed; however, all of the ways we are permitted to use and share this information fall into one of the groups below.
1) Ways we are allowed to use and share your health information with others without your Permission:a) Treatment. We may use your health information to give you medical treatment or services. We may share your health information with doctors, nurses, therapists and other personnel who are involved in providing your health care. For example, if you have a feeding disorder, the doctor may need to tell the dietitian about your disorder so that you get the kind of meals you need. We may share health information about you with people outside of CI who perform services related to your treatment, such as lab work or x-rays or for consultation purposes, or to provide follow-up care to you, such as residential homes or coordination of your care upon discharge.b) Payment. In order to receive payment for the services we provide to you, we may use and share your health information with your insurance company or a third party payment agency. We may also share your health information with another doctor or facility that has treated you so that they can bill you, your insurance company or a third party payment agency. For example, some health plans require your health information to be pre-authorized for rehabilitative services before they pay us.
c) Health Care Operations. We may use and share your health information so that we, or others that have provided treatment to you, can better operate the office or facility. For example, we may use your health information to review the treatment and services we gave you and to see how well our staff cared for you. We may share information with our students, trainees and staff for review and learning purposes.
d) Health Information Organization. CI participates in a health information organization. A health information organization is an electronic method to share medical information about your care with other health care providers. Providers must have an established treatment relationship in order to see your information. You have the right to opt-out of the Health Information Organization (HIO) and may notify CI to do so.e) Business Associates. We may share your health information with others who perform services on our behalf that we call “Business Associates.” The Business Associate must agree in writing to protect the confidentiality of your information. For example, we may share your health information with a billing company that bills for the services we provided.f) Appointment Reminders. We may use and share your health information to remind you of your appointment for treatment or medical care. For example, if your doctor has sent you for a test, the place where the testing will be done may call you to remind you of the date you are scheduled.g) Fundraising Activities. We may use and share with a Business Associate or a foundation that is related to us. The following information may be used for fundraising purposes or disclosed to a business associate: (i) demographic information relating to an individual, including name, address, other contact information, age, gender, and date of birth; (ii) dates of health care provided to an individual; (iii) program information; (iv) treating physician; (v) outcome information; and (vi) health insurance status. Or, we may ask you for a donation to CI. For example, you may receive a letter from CI asking for a donation to support CI’s Annual Fund. You have the right to opt-out of receiving such fundraising communication by contacting 412-420-2203. If you opt-out, you may also later decide to again receive such fundraising communications by contacting 412-420-2203.h) Marketing Activities: We may use or share your health information for marketing purposes without your permission in circumstances such as face to face marketing about treatment therapies, products and services. Other types of marketing will require your written permission.i) Research in Certain Cases: We may use and share your health information for research in certain circumstances, and under the supervision of an Institutional Review Board (IRB) in order to assist medical research.j) Special Situations In the following situations, the law permits, and under some circumstances requires us to use or share your health information with others. These disclosures may be further limited by the requirements of Pennsylvania law, which includes but are not limited to, special considerations for behavioral health information, drug and alcohol treatment information and HIV status:When required by law: We may share your health information when a law requires that we report information about suspected abuse, neglect or domestic violence, or relating to suspected criminal activity, or in response to a court order. We must also disclose health information to authorities that monitor compliance with these privacy requirements.For public health activities: We may disclose your health information when we are required to collect information about disease or injury, or to report vital statistics to the public health authority.For health oversight activities: We may disclose your health information to a protection and advocacy agency, or another agency responsible for monitoring the health care system for such purposes as reporting or investigation of unusual incidents.To avert threat to health or safety: In order to avoid a serious threat to health or safety, we may disclose health information as necessary to law enforcement or other persons who can reasonably prevent or lessen the threat of harm.For specific government functions: We may disclose health information to correctional facilities in certain situations, to government benefit programs relating to eligibility and enrollment, and for national security reasons, such as protection of the President.Relating to decedents: We may disclose health information relating to an individual's death to coroners, medical examiners or funeral directors, and to organ procurement organizations relating to organ, eye, or tissue donations or transplants.
2) Ways we are allowed to use and give your health information to others with your verbal permission:
3) IN ALL OTHER WAYS, WE WILL REQUIRE YOUR WRITTEN PERMISSION BEFORE YOUR HEALTH INFORMATION IS USED OR SHARED WITH OTHERS.
Certain uses of your medical information, such as the use or disclosure of or access to psychotherapy notes, or use of disclosure for marketing purposes (other than in a face to face communication with you regarding new therapies, products or services for you or your child’s care), require your written permission. In addition, except as stated above, your written permission is required before we can use or share your health information to anyone outside of CI, We also cannot sell your health information without your permission. This permission is provided through a release of information authorization form. If you give us permission to use or share health information about you, you may cancel that permission, in writing, at any time. If you cancel your permission, we will no longer use or share your health information for the reasons you have given us in your written permission. However, we are unable to take back any information that we have already shared with your permission.
The law gives you the following rights about your health information:
If you believe your privacy has been violated by us, you may file a complaint directly with us. You can do this by contacting the Compliance Office at 412-420-2193 or by calling the CI Compliance Hotline at 1-877-874-8417. Complaints to us can be oral (by contacting the above numbers) or in writing addressed to:
The Children’s Institute of Pittsburgh
1405 Shady Avenue
Pittsburgh, PA 15217
You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. To file a complaint with the Secretary of Health and Human Services, you must: 1) name CI or the person that you believe violated your privacy rights and describe how that person/place violated your privacy rights and 2) file the complaint within 180 days of when you knew or should have known that the violation occurred. All complaints to the Secretary of the U.S. Department of Health and Human Services must be in writing. You will not be penalized for filing a complaint.
If You Have Questions About This Notice
If you have any questions about this Notice, please contact the Compliance Office at 412-420-2193 or the Security Officer at 412-420-2397.