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Confidentiality and Privacy

Notice of Privacy Practices Effective April 14, 2003
(last updated, June 23, 2003)

Indiana University of Pennsylvania
Pechan Health Center
610 Pratt Drive
Indiana, PA  15705
(724) 357-6475
www.iup.edu/healthcenter
Health-Inquiry@iup.edu

As members of both the higher education and health care communities, Pechan Health Center has a unique obligation to respect the privacy of your health care record.  Records at the Pechan Health Center (PHC) are governed by the Federal Educational Rights and Privacy Act (FERPA).  The staff at Pechan Health Center will also voluntarily use the Health Insurance Portability and Accountability Act (HIPAA) to guide the standards used regarding the privacy of your medical information.  Nothing herein contained shall be construed as an admission or representation that Pechan Health Center is a covered entity under HIPAA.

The Pechan Health Center employs physicians that are a part of an Organized Health Care Arrangement (OHCA) with the Indiana Regional Medical Center (IRMC).  An OHCA is a clinically integrated setting in which individuals typically receive health care from more than one health care provider or is an organized system of health care in which more than one health care provider participates. If a Pechan Health Center physician provides care to you at the IRMC, your protected health information will be used or disclosed according to the Medical Center’s Joint Notice of Medical Practices.  We have agreed with the IRMC, as permitted by law, to share your protected health information for purposes of treatment, payment or health care operations.  This enables us to better address your health care needs. 

This notice describes how information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Who will Follow This Notice?

• All Pechan Health Center personnel including student employees

Our Pledge Regarding Health Information

Pechan Health Center (PHC) understands that medical information about you and your health is personal. PHC is committed to protecting medical information about you. PHC creates a record of the care and services you receive. The health center needs this record to provide quality care and to comply with certain legal requirements or regulations guiding medical practice in the Commonwealth of Pennsylvania. This notice applies to all of the records of your care generated by Pechan Health Center personnel.

This notice will tell you about the ways in which the health center may use and disclose medical information about you. The health center also describes your rights and certain obligations regarding the use and disclosure of medical information.

The health center is required to:

• make sure that medical information that identifies you is kept private
• give you access to this notice of health center legal duties and privacy practices with respect to medical information about you; and
• follow the terms of this notice that is currently in effect

Understanding Your Health Record/Information

While you are a student at Indiana University of Pennsylvania, Pechan Health Center is one of your health care providers. Each time you visit Pechan Health Center, a record of your visit is made. Typically, this record contains your health history, symptoms, examination and test results, diagnoses, treatment, and a plan for future care of treatment. This information, often referred to as your health or medical record, serves as:

• a basis for planning your care and treatment
• a means of communication among the many health professionals who
  contribute to your care
• a legal document describing the care you received
• a means by which you or a third-party payer can verify that services billed
  were actually provided
• a tool for educating health professionals
• a source of data quality control
• a source of information for public health officials charged with improving
  the health of the nation
• a source of data for facility planning and marketing
• a tool with which the health center can assess and continually work to improve  the care rendered and the outcomes achieved

Understanding what is in your record and how your health information is used helps you to:

• ensure its accuracy
• better understand who, what, when, where, and why others may
  access your health information
• make more informed decisions when authorizing disclosure to others

How Pechan Health Center May Use and Disclose Medical Information About You

Pechan Health Center will use your health information for treatment.
For example: Information obtained by a nurse, clinician (a physician, nurse practitioner, registered nurse) or other member of your healthcare team will be recorded in your medical record and used to determine the course of treatment that should work best for you. Your clinician will document in your record his/her expectations of the members of your healthcare team. Members of your healthcare team will then record the actions they took and their observations. In that way, the clinician will know how you are responding to treatment.  Clinicians within Pechan Health Center also may share health information about you in order to coordinate the different things you need, such as prescriptions, lab work, and x-rays. If Pechan Health Center staff refers you to another clinician or hospital, information regarding your visit may be shared with these health care providers.

Pechan Health Center will use your health information for payment.
For example:  Pechan Health Center may bill your student account for services you receive during your visit.   You are obligated to pay for these services in accordance with policies and procedures established by Student Accounts Receivable. 

Pechan Health Center will use your health information for regular health care operations.  For example: Members of the clinical or administrative staff may use information in your health record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and service we provide. The health center may use health information to review our treatment and services and to evaluate the performance of our staff in caring for you.

Pechan Health Center may use your health information with designated business associates. There are some services provided in our organization through contracts with business associates such as laboratories.  When these services are contracted, Pechan Health Center may disclose your health information so that they can perform the job we have asked them to do. The health center asks that all of its business associates have the highest standards when protecting the privacy of your health information.

Pechan Health Center may use and disclose health information to contact you as a reminder that you have an appointment for treatment or medical care.

Pechan Health Center may use and disclose health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

Pechan Health Center may use and disclose information in life threatening/extreme emergency situations, we may use or disclose health information to notify, or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition. We may release health information about you to a friend or family member who is involved in your health care. In addition, we may disclose health information about you to an organization assisting in a disaster relief effort so that your family can be notified about your condition, status and location. You have the opportunity to agree to, prohibit or restrict the use or disclosure of health information to these individuals.

Under certain circumstances, Pechan Health Center may use and disclose health information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who receive one medication to those who receive another, for the same condition. All research projects are subject to a special approval process. This process evaluates a proposed research project and its use of health information, trying to balance the research needs with patients' needs for privacy of their health information. Before the health center uses or disclose health information for research, the project will have been approved through this research approval process.

Pechan Health Center will disclose health information about you when required to do so by federal, state or local law.

Pechan Health Center may use and disclose health information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent that threat.

Pechan Health Center may disclose health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or to determine the cause of death. The health center may also disclose medical information about patients of Pechan Health Center to funeral directors as necessary to carry out their duties.

Pechan Health Center may disclose health information about you for public health activities. These activities generally include the following:

·         to prevent or control disease, injury or disability

·         to report births and deaths

·         to report child abuse or neglect

·         to report reactions to medications or problems with products

·         to notify people of recalls of products they may be using

·         to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition

·         to notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law

Pechan Health Center may disclose health information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

If you are a member of the United States armed forces or foreign military personnel, the health center may disclose health information about you. If requested by military command authorities to assure the proper execution of the military mission, if the appropriate military authority has published a notice in the Federal Register with the following information, personal health information may be released:
1) appropriate military command authorities or the appropriate foreign military authority, and;
2) purposes for which the protected health information may be issued or disclosed

Pechan Health Center may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers' compensation or other similar programs established by law.

In connection with a lawsuit or a dispute, Pechan Health Center may disclose health information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute. We may use and disclose health information in defending or asserting a lawsuit involving your treatment at the health center.

We may disclose health information if asked to do so by a law enforcement official:

·         in response to a court order, subpoena, warrant, summons or similar process

·         to identify or locate a suspect, fugitive, material witness, or missing person

·         about the victim of a crime if, under certain limited circumstances, he health center is unable to obtain the person's agreement

·         about a death we believe may be the result of criminal conduct

·         about criminal conduct at Pechan Health Center, and

·         in emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.

The Health Center may disclose health information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Pechan Health Center may disclose health information about you to authorized federal officials so they may provide protection to the President of the United States, other authorized persons or foreign heads of state or conduct special investigations.

If you are an inmate of a correctional institution or under the custody of a law enforcement official, Pechan Health Center may disclose health information about you to the correctional institution or law enforcement official. This disclosure would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; (3) for the safety and security of the correctional institutions.

Your Rights Regarding Medical Information About You
You have the following rights regarding health information the health center maintains about you:

Right to Inspect and Copy. You have the right to inspect and copy health information that may be used to make decisions about your care. Usually, this includes medical and billing records (Pechan Health Center DOES NOT OFFER THIRD PARTY BILLING). To inspect and copy health information that may be used to make decisions about you, you must submit your request in writing to the Pechan Health Center Medical Records Office. If you request a copy of the information, the health center may charge a fee for the costs of copying, mailing or other supplies associated with your request.
The health center may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to health information, you may request that the denial be reviewed. Another licensed health care professional chosen by Pechan Health Center will review your request and the denial. The person conducting the review will not be the person who denied your request.

Right to Amend. If you feel that health information the health center has about you is incorrect or incomplete, you may ask to amend the information. You have the right to request an amendment for as long as the information is kept by or for Pechan Health Center. To request an amendment, your request must be made in writing and submitted to the Pechan Health Center Medical Records Office. In addition, you must provide a reason that supports your request.  The health center may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, the health center may deny your request if you ask us to amend information that:

·         was not created by the health center, unless the person or entity that created the information is no longer available to make the amendment

·         is not part of the health information kept by or for Pechan Health Center

·         is not part of the information which you would be permitted to inspect and copy or

·         is accurate and complete

Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures made of health information about you. This list will not include disclosures the health center made to you, disclosures made for the purposes of treatment, payment or our operations or those authorized by you.

To request this list or accounting of disclosures, you must submit your request in writing to the Pechan Health Center Medical Records Office. Your request must state a time period, which may not be longer than seven (7) years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). This first list you request within a (12) twelve-month period will be free. For additional lists, the health center may charge you for the cost of providing the list. The Health Center will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions. You have the right to request a restriction or limitation on the health information disclosed about you for treatment, payment or health care operations. The health center is not required to agree to your request. To request restrictions, you must make your request in writing to the Pechan Health Center Medical Records Office. In your request, you must state (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosure to your spouse.

Right to Request Confidential Communications. You have the right to request that the health center communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that the health center only contact you at work or by mail.

To request confidential communications, you must make your request in writing to the Pechan Health Center Medical Records department. The health center will not ask you the reason for your request. The health center will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice. You may ask the health center to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. To obtain a paper copy of this notice you may stop by the Pechan Health Center Medical Records Office.

Changes To This Notice
Pechan Health Center reserves the right to change this notice. The health center reserves the right to make the revised or changed notice effective for medical information we already have about you as well as any information received in the future. The health center will post a copy of the current notice on the website www.iup.edu/healthcenter. This notice will contain on the first page, in the top right-hand corner, the effective date. In addition, each time you register at the health center for treatment or health care services, a copy of this notice will be available to you.

Complaints
If you believe your privacy rights have been violated you may file a complaint with Indiana University of Pennsylvania or with the Secretary of the Department of Health and Human Services. To file a complaint with Indiana University of Pennsylvania, contact the Indiana University of Pennsylvania Privacy Officer at 724-357-6475 or by mail at: Chief Privacy Officer, Indiana University of Pennsylvania University, c/o 610 Pratt Drive, Indiana, PA 15705. All complaints must be submitted in writing. You will not be penalized for filing a complaint.

Other Uses of Health Information
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with written permission. If you provide permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, the health center will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that the health center is unable to take back any disclosures already made with your permission, and that the health center is required to retain our records of the care that was provided to you.

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