HILLTOP COMMUNITY RESOURCES, INC.

Health Information Portability and Accountability Act (HIPAA)

Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GETACCESS TO THIS INFORMATION.

PLEASE REVIEW IT CAREFULLY.

To print a copy of Hilltop’s Privacy Practices, click here

UNDERSTANDING YOUR HEALTH RECORD/INFORMATION:

When you receive treatment as a Hilltop client or resident a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care and treatment. This information, often referred to as your health or medical record, serves as a:

  • Basis for planning your care and treatment.
  • Means of communication among the many health professionals who contribute to your care.
  • Legal document describing the care you received.
  • Means by which you or a third-party payer can verify that services billed were actually provided.
  • A tool in educating health professionals.
  • A source of data for medical research.
  • A source of information for public health officials who oversee the delivery of health care in the United States.
  • A source of data for organizational planning and marketing.
  • A tool with which we can assess and continually work to improve the care we render and the outcomes achieve.

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, and make more informed decisions when authorizing disclosure to others.

WHO WILL FOLLOW THIS NOTICE?

This notice describes our organizations practices and that of:

  • Any health care professional authorized to enter information into your health record.
  • All departments and units of the organization
  • Any home care agency or professional who contracts with Hilltop to provide direct care services.
  • Any member of a volunteer group we allow to help you while you are a part of our organizations programs.
  • All employees, staff and other organizational personnel.

Hilltop community partners who treat and serve program clients. These entities follow the terms of this notice. In addition, these entities may share medical information with each other for treatment, payment, or corporate operations purposes as described in this notice.
OUR RESPONSIBILITIES REGARDING HEALTH INFORMATION:

We understand that medical information about you and your health is personal. We are committed to protecting medical information about you. We create a record of the care and services you receive in our organizations programs. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by this organization, whether made by the organizations personnel, or your personal doctor. Your personal doctor may have different policies or notices regarding the doctors use and disclosure of your medical information created in the doctors office or clinic.

This notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.
We are required by law to:

  • Maintain the privacy of your health information;
  • Give you notice of our legal duties and privacy practices with respect to medical information about you; and,
  • Follow the terms of the notice that is currently in effect.

HOW WE MAY USE AND/OR DISCLOSE YOUR HEALTH INFORMATION:
The following categories describe different ways that we may use and disclose health information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use of disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

  • For Treatment. We may use health information about you to provide you with medical treatment or services. We may disclose health information about you to doctors, nurses, technicians, medical students, or other organization personnel who are involved in taking care of you at the program. For example, 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 dietician if you have diabetes so that we can arrange for appropriate meals. Different programs of Hilltop may also share medical information about you in order to coordinate you treatment and other things you may need, such as prescriptions, lab work, and x-rays. We may also disclose medical information about you to people outside Hilltop who may be involved in your medical care after you leave the organizations program, such as subsequent healthcare providers, family members, clergy or others who may provide services that are part of your care.
  • For Payment. We may use and disclose health information about you so that the treatment and services you receive from Hilltop programs may be billed to and payment may be collected from you, an insurance company, or a third party including Medicare or Medicaid. For example, we may need to give your health plan information about treatment you received so the health plan will pay us or reimburse you for the treatment. We may also tell your health plan about treatment you are going to receive to obtain prior approval or to determine whether you plan will cover the treatment. The information on or accompanying a bill or request for prior approval may include information that identifies you, as well as your diagnosis, procedures, and supplies used.
  • For Health Care Operations. We may use and disclose health information about you for the organizations operations. These uses and disclosures are necessary to run Hilltops programs and make sure that all of our patients/residents receive quality care. For example, members of the medical staff, the risk manager, or members of a quality improvement team may use information in your health record 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 health care and service we provide. We may also disclose information to doctors, nurses, students, direct care staff, and other Hilltop personnel for review and learning purposes.
  • Business Associates. There are some services provided at Hilltop through contacts with business associates. Examples include our community partners, accountants, consultants and attorneys. When these services are contracted, we may disclose your health information, however, we require the business associates to appropriately safeguard your information.
  • 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.
  • Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
  • 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.
  • Fundraising Activities. We may use medical information about you to contact you as part of a fund-raising effort.
  • Facility Directory. We may include certain limited information about you, at Hilltop, while you are client/resident at the facility. This information may include your name, location in the organization, and your religious affiliation. This 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 priest or rabbi, even if they dont ask for you by name. This is so your family, friends, and clergy can visit you and generally know how you are doing.
  • Notification. We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, of your location, and general condition. If we are unable to reach your family member or personal representative, then we may leave a message for them at the phone number that they have provided us.
  • Communication with Family. We may release medical information about you to a family member, other relative, friend or any other person you identify who is involved in your medical care. We may also give information to someone who helps pay for your care.
  • Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. However, all research projects are subject to a special approval process and protocols to ensure the privacy of your health information.
  • As Required by Law. We will disclose medical information about you when required to do so by federal, state or local law.
  • To Avert a Serious Threat to Health or Safety. We may use and disclose medical 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 the threat.

SPECIAL SITUATIONS:

  • Organ and Tissue Donation. If you are an organ donor, we may release medical information to organizations that handle organ procurement or organ, eye or tissue transplantation, or to an organ donation bank as necessary to facilitate organ or tissue donation and transplantation.
  • Military and Veterans. If you are a member of the armed forces, we may release health information about you as required by military command authorities. We may also release health information about foreign military personnel to the appropriate foreign military authority.
  • Workers Compensation. We may release medical information about you for workers compensation or similar programs. These programs provide benefits for work-related injuries or illnesses.
  • Public Health Risks. We may disclose medical 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 notify people of recalls of products they have been using.
    • To notify a person who may have been exposed to a disease or may be as risk for contracting or spreading a disease or condition.
    • To notify the appropriate government authority if we believe a client has been the victim of abuse, neglect, or domestic violence.We will only make this disclosure if you agree or when required by law.
  • Health Oversight Activities. We may disclose medical 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, governmental programs, and compliance with civil rights laws.
  • Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical 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, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
  • Law Enforcement. We may release medical 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 we are unable to obtain the persons agreement;
    • About a death we believe may be the result of criminal conduct;
    • About criminal conduct at the facility; 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.
  • Coroners, Medical Examiners and Funeral Directors. We may release medical information to a coroner, medical examiner and funeral directors as necessary to carry out their duties consistent with applicable law.
  • Correctional Institution. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the institution or official as necessary for your health and safety and for the health and safety of others.
  • National Security and Intelligence Activities. We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
  • Protective Services for the President and Others. We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.

YOUR HEALTH INFORMATION RIGHTS:

Although your health record is the physical property of the organization, you have the following rights regarding the information we maintain about you:

Right to Inspect and Copy. You have the right to inspect and copy medical information that may be used to make decisions about your care. Usually this includes medical and billing records, but does not include psychotherapy notes.

To inspect and copy this medical information, you must submit your request in writing to the Program Manager of the organizations Privacy Officer. I you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with you request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. A licensed health care professional who was not directly involved in the original denial will review your request. We will comply with the outcome of this review.

Right to Amend. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept for or by the organization.

To request an amendment, your request must be made in writing and submitted to the organizations Privacy Officer. In addition, you must provide a reason that supports your request. We ask that you use the form provided by our organization to make such requests.For a request form, please contact Hilltops Privacy Officer.

We 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, we may deny your request if you ask us to amend information that:

  • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
  • Is not part of the medical information kept by or for the facility;
  • 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 we made of medical information about you. Please note that an accounting will not apply to any of the following types of disclosures:

  • Disclosures made for reasons of treatment, payment or health care operations;
  • Disclosures made to your or your legal representatives or any other individual involved with your care;
  • Disclosures to correctional institutions or law enforcement officials;
  • Disclosures made for national security purposes.

To request this list of accounting, you must submit your request in writing to the organizations Privacy Officer. We ask that such requests be made on a form provided by Hilltop. For a request form, please contact the Privacy Officer.Your request must state a time period, which may not be longer that six years and may not include dates before April 1, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically, etc.). The first list you request within a 12 month period will be free.For additional lists, we may charge you for the costs of providing the list.We 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 medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment of your care, like a family member or friend.

We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. We ask that you use the form provided by Hilltop to make such requests. Your request must be in writing. In your request you must tell us (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, disclosures to your spouse.

Right to Request 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 can ask that we only contact you at work or by mail.

We ask that such requests be made in writing on a form provided by Hilltop.We will not ask you the reason for your request.We 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 us 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 version of the notice.

To obtain a paper copy of this notice, contact the program manager or the Privacy Officer.

OTHER USES OF HEALTH INFORMATION:
Other uses and disclosures of health information not covered by this notice or the laws that apply to us will be made only with your written permission. To obtain a form to request such authorization, please contact the Privacy Officer. If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosure we have already made with your permission, and that we are required to retain records of the care that we provided to you.

OBTAINING FORMS:
Copies of any previously mentioned forms may be obtained from the specific Program Manager, or Hilltops Privacy Officer.

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 health information we already have about you as well as any information we receive in the future.We will post a copy of the current notice.The notice will contain on the last page, at the bottom left-hand corner, the effective date.In addition, each time you enter or are admitted to a Hilltop program, we will offer you a copy of the current notice in effect.

FOR MORE INFORMATION, OR TO REPORT A PROBLEM:
If you have questions or need more information regarding this Notice of Privacy Practices or wish to file a complaint you may contact:

Lisa Martin, Privacy Officer
Hilltop Community Resources, Inc.
1331 Hermosa Avenue
Grand Junction, CO 81506
(970) 244-0404

Complaints may also be filed with Secretary of the Department of Health and Human Services.
You will not be penalized for filing a complaint.
Effective Date:3/1/2013

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