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 REVIEW IT CAREFULLY.

We are required by law to:

  • Maintain the privacy of our patients' protected health information (Protected Health Information, or "PHI," is information about you, our patient, that relates to your health, condition, health care provided to you, and payment for health care services. Your protected health information includes any of this information that identifies you or could be used to identify you.)
  • Provide patients with this notice of our legal duties and privacy practices with respect to their protected health information.
  • Follow the terms of the notice currently in effect.

Who will follow this notice

This notice applies to McCullough-Hyde Memorial Hospital (MHMH), operating as a clinically integrated health care arrangement.

This clinically integrated health care arrangement is composed of McCullough-Hyde Memorial Hospital workforce, members of the medical staff and other licensed medical professionals with privileges to see and treat patients at McCullough-Hyde Memorial Hospital.

The terms "we" or "McCullough Hyde Memorial Hospital (MHMH)," when used in this notice, refer to this clinically integrated health care arrangement.

The members of this clinically integrated health care arrangement work and practice at McCullough-Hyde Memorial Hospital (MHMH), including the McCullough-Hyde Memorial Hospital Medical Buildings located in Oxford, Ross, Camden, and Hamilton, Ohio and Brookville, Indiana.

These entities, sites, and locations may share protected health information with each other for treatment, payment or health care operations as described in this notice.

Your physician and other health care providers may have a different notice of privacy practices and policy regarding the use and disclosure of your protected health information in their offices.

Uses and disclosures of your protected health information

We may use and disclose protected health information as described below.

Treatment. We may use and disclose your protected health information for your treatment or services, such as:

  • The provision, coordination, or management of health care services for you.
  • Consultation between health care providers regarding your treatment or services.
  • Referral from MHMH to another health care provider regarding your treatment or services.

For example, we may disclose protected health information about you to physicians, nurses, technicians, and other personnel involved in your treatment or services. Departments may share your protected health information to coordinate your care, such as ordering tests or lab work. If you need to be transferred from our facility, for example, to another hospital or nursing home, we may share your protected health information with that facility. We may share your protected health information with others involved in your care or treatment after you leave MHMH, such as your family physician, pharmacy, or home health care agency who may or may not be associated with MHMH.

Payment. We may use and disclose your protected health information for payment of treatment and services, such as:

  • Billing for treatment and services provided.
  • Collecting payment for treatment and services provided.
  • Review of health care services for medical necessity or health plan coverage.
  • Precertification and preauthorization of treatment and services.
  • Concurrent and retrospective review of treatment and services provided.

For example, we may provide protected health information to your insurance company about a treatment or service you received so that the insurer will pay for services. We may also inform your insurance company about a planned treatment or service so that prior approval may be obtained, or to determine if your insurance plan covers the planned treatment or service.

Health care operations. We may use and disclose your protected health information for MHMH health care operations, such as:

  • Quality improvement activities.
  • Reviewing the competence or qualifications of health care professionals.
  • Conducting medical education programs.
  • Compliance with credentialing, licensure, accreditation or certification requirements.
  • Activities related to health insurance or underwriting, premium rating.
  • Conducting or arranging for medical review, legal services, audit functions.
  • Business planning and development.
  • Business management and general administrative activities.

For example, we may disclose your protected health information to physicians, nurses, and therapists on our staff for teaching and medical education. We may also disclose information to other health care providers involved in your care or treatment for their health care operations. For example, we may disclose your protected health information to an ambulance company that transported you to MHMH in order for the ambulance company to bill for its services.

Health services, treatment alternatives and health-related benefits. We may use and disclose your protected health information to tell you about:

  • Health-related products or services that we offer.
  • Possible treatment options or alternatives.
  • Health-related benefits or services that may be of interest to you.

We may also use your protected health information to communicate with you and coordinate your care.

Appointments. We may use and disclose your protected health information to contact you as a reminder that you have an appointment or to reschedule a missed appointment for treatment or services.

Fundraising. We, or a foundation associated with MHMH, may contact you to donate to a fundraising effort for us or on our behalf. You may elect not to receive further fundraising materials/communications by sending your name and address to:

Development Office
McCullough-Hyde Memorial Hospital Trust
110 North Poplar Street
Oxford, Ohio 45056

You should enclose a statement that you do not wish to receive further fundraising materials or communications from us or a foundation associated with MHMH.

Patient (facility) directory. We may include certain information about you in the MHMH patient directory while you are a patient. This assists your family, friends and/or clergy in contacting you. This information may include your name, room number and religious affiliation. Directory information, except for your religious affiliation, may be released to people who ask for you by name. (Your religious affiliation may be given to a member of the clergy, such as a minister or pastor, even if they don't ask for you by name.) If you do not want to be included in this directory, inform Patient Registration, Nursing, or Case Management staff.

Other individuals involved in your care or treatment: notification and communication. We may disclose your protected health information to the person you named in your Durable Power of Attorney for Health Care (if you have one), or to a friend or family member who is your personal representative (i.e., empowered under state or other law to make health-related decisions for you).

If you do not object, or if we reasonably infer from the circumstances (for example, if your spouse remains present while discussing treatment options with your physician), we may also disclose relevant protected health information to a family member, other relative, close personal friend or any other person you identify who is involved with your care or payment for your care. In an emergency situation, or if you are incapacitated or not present, we may use our professional judgment to determine that it is in your best interest to disclose relevant protected health information to a family member, other relative, close personal friend or any other person you have previously identified who is involved with your care or payment for your care. We would only disclose information relevant to that person's involvement in your health care. We may also provide protected health information about you to assist in notifying those persons of your location, general condition, or death. We may also provide your protected health information to organizations assisting in disaster relief efforts so that your family may be notified about your condition.

Required by law. We will use or disclose your protected health information when that use or disclosure is permitted or required by law. Any such use or disclosure will comply with, and be limited to, the permissions or requirements of the law. Examples of instances in which we are permitted or required to disclose your protected health information includes any of the situations described in this policy under the heading special situations.

Serious threat to health or safety. In certain situations, and as allowed by law, we may use and disclose your protected health information when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. For example, we may disclose limited information to law enforcement officials to identify or apprehend an individual who appears to have escaped from a correctional institution or from lawful custody.

Business associates. At MHMH, vendors contracted with us provide some services. These vendors are known as business associates. For example, we may provide protected health information to an external company that assists us in processing electronic bills, or to physician services in our imaging department. We require our business associates to safeguard your protected health information.

Special situations

Organ and tissue donation. We may disclose your protected health information to organizations that manage organ/eye/tissue procurement/transplantation/or donation if you are an organ donor.

Military and veterans. We may disclose your protected health information to U.S. armed forces or foreign military authorities if you are or were a member of the U.S. armed forces or foreign military personnel.

Workers' Compensation. We may disclose your protected health information to workers' compensation insurers, state administrators, employers, and other persons or entities involved in the workers' compensation system as authorized by law and as applicable to your treatment and care.

Minors. We may disclose certain types of your protected health information to your parent or guardian if you are a minor (under 18 years old) and if such release is required or permitted by law.

Public health. We may disclose your protected health information for public health activities, including activities to:

  • Prevent or control disease, injury or disability.
  • Report births and deaths.
  • Report child or adult abuse, neglect or violence.
  • Report reactions to medications or problems with products.
  • Notify people of recalls of products they may be using.
  • Notify a person who may have been exposed to a disease or may be at risk for getting or spreading a disease or condition.

Health oversight activities. We may disclose your protected health information to federal or state agencies for health oversight activities such as audits, investigations, inspections, and licensure. This disclosure would be as necessary for the government to monitor the health care system, government programs, and compliance with laws.

Lawsuits and disputes. We may disclose your protected health information in response to a court or administrative order or a search warrant. We also may disclose your protected health information in response to a subpoena, discovery request, or other lawful process. During this process, efforts will be made to notify you about the request and/or provide you with an opportunity to object or to obtain an appropriate court order protecting the information requested.

Law enforcement. We may disclose your protected health information to law enforcement officials, under specific situations, and as required by law, such as:

  • Reporting of wounds or other physical injuries.
  • Information for identification/location of suspects, fugitives, material witnesses, or missing persons.
  • Information about a crime victim.
  • Suspected deaths from criminal conduct.
  • Information about a crime on premises.
  • Reporting crime in emergencies.

Coroner and funeral directors. We may disclose your protected health information to the coroner or a funeral director as necessary, and /or required by law. For example, this may be necessary to identify a deceased person or to determine the cause of death.

National security and protective services. We may disclose your protected health information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law. We may also disclose your protected health information to authorized federal officials so they may provide protection to the President and other persons. Inmates and individuals in lawful custody. We may disclose your protected health information to a correctional institution or a law enforcement officer if you are an inmate of a correctional institution or under the custody of a law enforcement officer.

Certain types of health information. State and federal laws provide protection for certain types of health information, including information about alcohol or drug abuse, mental health and AIDS/HIV, and may limit whether and how we may disclose information about you to others.

Disclaimer. MHMH may share your protected health information with members of the medical staff and other independent medical professionals in order to provide treatment and perform other activities such as professional peer review, quality improvement, and other services for MHMH. While those professionals may follow this notice and otherwise participate in the privacy program of MHMH, they are independent professionals and MHMH expressly disclaims any responsibility or liability for their acts or omissions.

Your privacy rights: Your rights to request:

Review or copy. You have the right to request to review and/or receive a copy of your protected health information. All requests for access to your protected health information must be in writing and signed by you or your representative. "Patient's representative" is the person to whom a patient has given written authorization to act on the patient's behalf regarding the patient's medical records. If the patient is deceased, the term refers to the executor or administrator of the patient's estate or the person responsible for the patient's estate if it is not to be probated. We may charge you a fee, especially if extensive and/or non-recent personal health information is requested. We may also charge for postage if you request a mailed copy. If the information you request is maintained electronically and you request an electronic copy of such information, we will provide you with access to the information in the electronic form and format you request, if it is readily producible in such form and format; or, if not, in a readable electronic form and format as you and we agree. In some limited situations, your request to review or receive a copy may be denied. For example, when a licensed health care professional determines that access may endanger your life/physical safety or the life/physical safety of another. In some denial situations, you have the right to have the denial evaluated by a reviewing official. Based upon the determination of the reviewing official we will then provide or deny access. To request to review and/or receive a copy of your protected health information, you or your representative, as applicable, will need to complete a signed release of information authorization form that may be obtained from:

HIM/Medical Records
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056

Amendment. You have the right to request that your protected health information be amended if you think that your protected health information in our records is incorrect or incomplete. All requests for amendments must be made in writing and signed by you or your representative, (see definition of representative under Review or Copy, as applicable). All amendment requests must also state the reason(s) for the amendment/correction request, and the specific amendment/correction requested. We are not obligated to make all requested amendments but will give each request careful consideration. For example, an amendment request may be denied if the information to be amended was not created by us or is not part of our protected health information kept by our facility. If an amendment you request is made by us, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary. You may obtain an amendment request form from:

HIM/Medical Records
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056

Accounting of disclosures. You have the right to request an "accounting" or list of certain disclosures MHMH has made of your protected health information. This "accounting" or list usually includes disclosures such as those listed in special situations. This "accounting" or list is not required to include all disclosures. For example, we are not required to account for routine disclosures between MHMH staff coordinating your treatment or care. Types of disclosures not required in the "accounting" or list are:

  • Disclosures for treatment, payment, or health care operations.
  • Disclosures made before April 14, 2003.
  • Disclosures made more than six years prior to the date on which the "accounting" or list is requested.
  • Disclosures made to you or which you authorized.
  • Certain other disclosures, such as disclosures for national security or intelligence purposes.

To request this accounting of disclosures and obtain information about possible fees, contact:

Privacy Officer
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056

Restrictions on disclosures. If you request that healthcare items or services which you self-pay for in full not be disclosed to your health plan, MHMH will agree to that request. You have the right to request other restrictions or limits on your protected health information we use or disclose about you for treatment, payment or health care operations. We are not required to agree to such other requests. However, if we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment or to make a disclosure that is required under law. Restriction requests should usually be in writing and you must tell us:

  1. What information you want to limit.
  2. Whether you want to limit our use, disclosure or both.
  3. To whom you want the limits to apply.

We may terminate an agreement to a restriction if we inform you of this termination. We will notify you of such termination, if applicable. You may also request to terminate a restriction or limitation on your protected health information. To request a restriction or limit on your protected health information, contact:

Privacy Officer
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056

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. For example, you may request that we call you at your office, rather than at your home. We will not require you to explain the reason for your request. We will accommodate reasonable requests. Confidential communication requests should usually be in writing and you must specify how or where you wish to be contacted. To request an alternative communication means or location, contact:

Privacy Officer
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056

Paper copy of this notice. You have the right to receive a paper copy of this notice even if you have agreed to receive this notice electronically. You may obtain a paper copy in our main reception /registration areas.

Breach Notification. In the event of any breach of unsecured protected health information, MHMH shall fully comply with breach notification requirements mandated by law, which will include notification to you of any impact that breach may have had on you and the actions MHMH undertook to minimize any impact the breach may or could have on you.

Changes to this notice

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for protected health information we already have about you as well as for any information we receive in the future. We will post the notice in our facilities (main reception/registration areas) and on our website. You may also request a copy from staff in our main reception/registration areas.

Complaints

If you believe your privacy rights have been violated, you may file a written complaint with the Privacy Officer or with the Secretary of the Department of Health and Human Services (HHS). To file a complaint with the Privacy Officer, contact:

Privacy Officer
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056

Generally, a complaint must be filed with HHS within 180 days after the act or omission occurred, or within 180 days of when you knew or should have known of the action or omission. You will not be retaliated against or denied treatment or discriminated against for filing a complaint.

Other uses of protected health information

Other uses and disclosures of your protected health information not covered by this notice or the laws and regulations that apply to MHMH will be made only with your written authorization. MHMH requires your written authorization for most uses and disclosures of psychotherapy notes, for marketing (other than a face-to-face communication between you and a MHMH workforce member or a promotional gift of nominal value); or before selling your protected health information. If you authorize us to use or disclose protected health information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose your protected health information for the reasons listed in your written authorization. The revocation will not apply to uses or disclosures that have already occurred. Also, we will continue to comply with laws that require certain disclosures.

Further information

If you have questions or need further assistance regarding this notice, you may contact:

Privacy Officer
McCullough-Hyde Memorial Hospital
110 N. Poplar Street
Oxford, Ohio 45056
513.524.5491

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