PRIVACY PRACTICES

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 read it carefully.

The Federal HIPAA Privacy Rule requires that we protect the privacy of health information that identifies a patient, or where the information may be used to identify a patient.  This Notice describes your rights as our patient and our obligations regarding the use and disclosure of personal health information or PHI.

PHI is information that identifies you that we create or get from you or from another health care provider, health plan, your employer or a health care clearinghouse that relates to your past, present or future physical or mental health or condition, the provision of health care to you, or the past, present or future payment for your health care.

We are required by law to:

  • Maintain the privacy of PHI about you,
  • Provide to you this Notice of our legal duties and privacy practices with respect to your  PHI,
  • Comply with the terms of our Notice of Privacy Practices that are currently in effect, and
  • Notify you if we become aware of a breach of your unsecured PHI.

USES AND DISCLOSURES WITHOUT AUTHORIZATION

Under the law, we may use or disclose your PHI under certain circumstances without your permission.  The following categories describe the different ways we may use and disclose your PHI without your permission.  For each category, we will give some examples.  Not every use or disclosure in a category will be listed, however all of the ways in which we are permitted to use and disclose PHI will fall within one of the categories.

For Treatment.    The physicians and other clinicians and staff members within our Practice will use and disclose your PHI in providing you with medical care.  We may also disclose your PHI to health care providers outside our Practice who are involved in your care.  We may contact you to remind you about an appointment.  We may use and disclose your PHI to give you information about treatment alternatives or other health-related benefits and services.

For Payment.   We will use and disclose your PHI for billing and receiving payment for the medical care you receive.  For billing and payment purposes, we may disclose your PHI to your representative, an insurance or managed care company, Medicare, Medicaid, another third party payor, or the person you tell us is responsible for paying for your care.  For example, we may contact Medicare or your health plan to confirm your coverage or to request prior approval for a proposed treatment or service.

For Health Care Operations.   We may use and disclose your PHI for the operations of our Practice.  These uses and disclosures are necessary to manage our Practice and to monitor and improve our quality of care.  For example, we may use and disclose your PHI to review the qualifications and performance of our health care providers and to train our staff.   We may use and disclose your PHI to conduct or arrange for services, such as medical quality review by your health plan; accounting, legal, risk management, and insurance services; and compliance and audit functions.

We may also disclose PHI for the health care operations of any “organized health care arrangement” in which we participate.

OTHER USES AND DISCLOSURES WITHOUT AUTHORIZATION

Some of the other ways that we may use or disclose your PHI without your authorization are as follows:

Notification to Family and Others:   Unless you object, we may disclose PHI to a family member, other relative, close personal friend, or any other person identified by you, who is involved in your care or the payment for your care.  We may notify such persons of your location, general condition, or death.  We may also make reasonable decisions in allowing a person to act on your behalf to pick up filled prescriptions, medical supplies, X-rays, or related items that contain PHI about you.

As Required by Law:  We may disclose your PHI when required to do so by federal, state, or local law, including when requested by the Secretary of the United States Department of Health and Human Services to review our compliance with HIPAA.

Judicial and Administrative Proceedings:  We may disclose PHI in the course of judicial or administrative proceedings, such as in response to a court or administrative order, or in response to a subpoena, discovery request, or other legal process.

Public Health and Safety Activities:  We may disclose your PHI to carry out certain activities related to public health and safety.  Examples of these types of disclosures are:

  • To prevent or control disease, injury, or disability
  • To report to the federal Food and Drug Administration (FDA) adverse events or problems with products for tracking products in certain circumstances, to enable product  recalls, or to comply with other FDA requirements
  • To report suspected abuse, neglect, or domestic violence to public authorities
  • To prevent or reduce a serious, immediate threat to the health or safety of a person or the public

Law Enforcement:  We may disclose PHI to law enforcement officials for law enforcement purposes such as reporting certain types of injuries, locating missing persons, or reporting a victim of a crime.

Upon Death:  We may disclose PHI to a coroner or medical examiner to identify a deceased person and determine the cause of death, and to funeral directors, as authorized by law.

Organ Donation:  We may disclose PHI to organizations that help procure, locate, and transplant organs in order to facilitate an organ, eye, or tissue donation and transplantation.

Health Oversight Activities:  We may disclose your PHI to a health oversight agency for oversight activities authorized by law.  These may include, for example, audits, investigations, inspections, and licensure actions or other legal proceedings.   These activities are necessary for government oversight of the health care system, government payment or regulatory programs, and compliance with civil rights laws.

Disaster Relief:  We may disclose your PHI to an organization assisting in a disaster relief effort to assist in notification of your location and general condition to family or others involved in your care.

Research:  We may use or disclose PHI for research purposes if the privacy aspects of the research have been reviewed and approved by an institutional review board or privacy board, if the researcher is collecting information in preparing a research protocol, or if the research occurs after your death.

Specialized Government Functions:  We may use and disclose PHI for military and veterans activities, national security and intelligence activities, and to help provide protective services for the President of the United States and others.

Correctional Institutions:  We may disclose your PHI to a correctional institution or other law enforcement official having custody of you, such as in jail or prison, if necessary for your health and safety or the safety of others.

Workers’ Compensation:  We may disclose your PHI to comply with workers’ compensation laws or other similar programs. Washington state law requires disclosure of PHI to the Washington Department of Labor and Industries, the employer, and the payor for workers’ compensation and crime victims’ claims.  We also may disclose PHI for work-related conditions that could affect employee health.

Business Associates:    We contract with individuals and entities to provide certain types of services for our organization that may require them to create, maintain, use, and/or disclose your PHI.   An example is our billing service.  We may disclose your PHI to a business associate, but only after the business associate agrees in writing to safeguard your PHI in accordance with applicable law.

De-identifying Information:  We may use your PHI by removing any information that could be used to identify you.

Limited Data Set Disclosure:  We may use or disclose a limited data set for research, public health, or health care operations purposes.  The person receiving the information must sign an agreement to protect the information.

YOUR AUTHORIZATION IS REQUIRED FOR OTHER USES AND DISCLOSURES

Certain uses and disclosures of your PHI require your written authorization.  These are uses and disclosures for marketing purposes, sale of your PHI, and most uses and disclosures of psychotherapy notes.

We will use and disclose PHI other than as described in this Notice only with your written authorization.  In some situations, federal and state laws provide special protections for certain kinds of health information such as information about drug and/or alcohol abuse treatment, mental health or illness, HIV/AIDS, and sexually transmitted diseases.  We will not use or disclose that specially protected information without your written authorization as required by law.

You may revoke your prior authorizations to use or disclose PHI in writing, at any time.   If you revoke your authorization, we will no longer use or disclose your PHI for the purposes covered by the authorization, except that it will not affect information that has already been used or disclosed or any action taken before we receive the revocation.  Sometimes, you cannot revoke an authorization if its purpose was to obtain insurance.

YOUR RIGHTS REGARDING PHI

You have the following rights regarding your PHI. Under federal law you may exercise these rights by contacting the Privacy Officer at (206) 625-0578.

Requesting Restrictions:  You may request additional restrictions on the PHI that we use or disclose for treatment, payment and health care operations, or to individuals involved in your care or the payment for your care.  To request a restriction on who may have access to your PHI, you must submit a written request to the Privacy Officer.  We are not required to agree to your request unless you are asking us to restrict disclosure of your PHI to a health plan for payment or health care operations and the information you wish to restrict pertains solely to a health care item or service for which you have paid us “out of pocket” in full.  If we do agree to the requested restriction, we may not use or disclose your PHI in violation of that restriction unless it is needed to provide emergency treatment.

Receiving Confidential Communications:  You may request that we communicate with you regarding PHI in a certain manner or at a certain location.  For example, you can request that we contact you only at a certain phone number.  Please submit this type of request in writing.

Inspection & Copy:  You may request the opportunity to inspect and receive a copy of PHI about you in certain records that we maintain.  This includes your medical and billing records and other PHI that may be used to make decisions about your care, subject to some limited exceptions.  We may charge a reasonable fee for our costs in copying and mailing your requested information.   We may deny your request to inspect or receive copies in certain limited circumstances.  If you are denied access to PHI, in some cases, you will have a right to request review of the denial.  The review would be performed by a licensed healthcare professional designated by PAS who did not participate in the decision to deny your request.

Right to a Summary or Explanation:  We can provide a summary of your PHI, rather than the entire record, or we can provide an explanation of the PHI which has been provided to you, so long as you agree to this alternative form and pay the associated fees.

Right to an Electronic Copy of Electronic Medical Records:  If your PHI is maintained in an electronic format, you have the right to request that an electronic copy of your record be given to you or transmitted to another individual or entity.  If the PHI is not readily producible in the form or format you request, your record will be provided in either our standard electronic format or a readable hard copy form, as mutually agreed.

Amendment:  You may request that we amend PHI about you that is inaccurate or incomplete for as long as such information is kept by or for our office.  We may deny your request, and if we do, we will give you a written denial stating the reasons for the denial and your right to submit a written statement disagreeing with the denial.

Accounting of Disclosures:  You may request an “accounting” of certain disclosures that we have made of PHI about you, other than disclosures made for treatment, payment and health care operations, or certain other disclosures.  You may receive this information without charge once every 12 months; we may charge a reasonable, cost based fee for fulfilling additional requests within 12 months.

Paper Copy:  You have a right to receive a paper copy of this Notice at any time by contacting our Privacy Officer, even if you agreed to receive this Notice electronically.

Revocation of Authorizations:  You have the right to cancel prior authorizations to use or disclose PHI by giving us a written revocation.  Your revocation does not affect information that has already been used or disclosed.  It also does not affect any action taken before we receive the revocation.  Sometimes, you cannot cancel an authorization if its purpose was to obtain insurance.

CHANGE TO THIS NOTICE

We reserve the right to change our privacy practices and the terms of this Notice.  We reserve the right to make the changed or new privacy practices and Notice provisions effective for all PHI we maintain as well as for any PHI we create or receive in the future.   If we make material changes, we will update this Notice and make it available to you upon request.   You may receive the most recent copy of this Notice by calling our Privacy Officer at (206) 625-0578.  In addition, a copy of our current Notice is posted on our website at www.pasanes.com.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with us or the Secretary of the United States Department of Health and Human Services Office of Civil Rights (OCR).   We will not retaliate against you for filing a complaint.

To file a complaint with our office, please contact our Privacy Officer at the address below.   All complaints must be made in writing.

Physicians Anesthesia Service
Attn: Privacy Officer
1229 Madison, Suite 1440
Seattle, WA  98104

To file a complaint with OCR, send a letter to 200 Independence Avenue, S.W., Washington D.C. 20201, call 1-877-696-6775, or visit www.hhs.gov/ocr/privacy/hipaa/complaints/.

FOR MORE INFORMATION

If you have questions or would like more information, you may contact our Privacy Officer at (206) 625-0578.

EFFECTIVE DATE

This Notice is effective as of April 2014.

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Contact Us

1229 Madison Street,
Suite 1440
Seattle, WA 98104

Email: info@pasanes.com

Phone: (206) 625-0578
Fax: (206) 625-9184
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