Privacy Policy

We maintain protocols to ensure the security and confidentiality of your personal information. We have physical security in our building, passwords to protect databases, compliance audits and virus/intrusion detection software. Within our practice, access to your information is limited to those who need it to perform their jobs.

Community Health Center of Snohomish County is committed to treating and using protected health information about you responsibly. This Notice of Privacy Policies describes the personal information we collect, and how and when we use or disclose that information. It also describes your rights as they relate to your protected health information. This Notice is effective May 23, 2013, and applies to all protected health information as defined by federal regulations.

Notice of Privacy Practices – Effective May 23, 2013

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.

Our Promise To You, Our Patients: Your information is important and confidential. Our ethics and policies require that your information be held in strict confidence.

Introduction

We are required by law to maintain the privacy of your health information.  We are also required to give you this Notice about our privacy practices, legal obligations, and your rights concerning your health information (“Protected Health Information” or “PHI”).  We must follow the privacy practices that are described in this Notice (which may be amended from time to time).

For more information about our privacy practices, or for additional copies of this Notice, please contact us using the information listed at the end of this Notice.

Permissible Uses and Disclosures Without Your Written Authorization

We may use and disclose PHI without your written authorization for certain purposes as described below.  The examples provided in each category are not meant to be exhaustive, but instead are meant to describe the types of uses and disclosures that are legally permissible.

Treatment:  We may use and disclose PHI in order to provide treatment to you.  For example, we may review and use your medication history to diagnose, treat, and provide medical services to you.  In addition, we may disclose PHI to other health care providers in order to provide you with appropriate care and continued treatment.

Payment:  We may use or disclose PHI for the purposes of determining coverage, billing, claims management, and reimbursement. For example, a bill sent to your health insurer may include information about a surgery you received so that the insurer will pay us for the surgery.  We may also inform your health plan about a treatment you are going to receive in order to determine whether the plan will cover the treatment.

Health Care Operations:  We may use and disclose PHI in connection with our health care operations, including quality improvement activities, training programs, accreditation, certification, licensing or credentialing activities.  For example, we may use PHI to review our treatment and services and to evaluate the performance of our staff.  We may also disclose PHI to our health care professionals for review and learning purposes.

Required or Permitted by Law:  We may use or disclose PHI when we are required or permitted to do so by law.  For example, we may disclose PHI to appropriate authorities if we reasonably believe that you are a possible victim of abuse, neglect, or domestic violence or the possible victim of other crimes.  In addition we may disclose PHI to the extent necessary to avert a serious threat to your health or safety or the health or safety of others.

Other disclosures permitted or required by law include the following: disclosures for public health activities; health oversight activities including disclosures to state or federal agencies authorized to access PHI; disclosures to judicial and law enforcement officials in response to a court order or other lawful process; disclosures for research when approved by an institutional review board; disclosures for workers’ compensation claims, and disclosures to military or national security agencies, coroners, medical examiners, and correctional institutions as authorized by law.

Fundraising:  We may use PHI to contact you in an effort to raise money for our operations.  We may also disclose PHI to a foundation that is related to us so that the foundation may contact you in an effort to raise money for its operations.  Any fundraising materials sent to you will include a description of how you may opt out of receiving any further fundraising communications.

Permissible Uses and Disclosures That May Be Made Without Your Authorization, But For Which You Have An Opportunity to Object

Family and Other Persons Involved in Your Care.  We may use or disclose PHI to notify, or assist in the notification of (including identifying or locating), a family member, your personal representative, or another person responsible for your care, of your location, your general condition, or death.  If you are present, then we will provide you with an opportunity to object prior to such uses or disclosures.  In the event of your incapacity or emergency circumstances, we will disclose PHI consistent with your prior expressed preference that is known to us, and in your best interest as determined by our professional judgment. We will also use our professional judgment and our experience to make reasonable inferences of your best interest in allowing a person to pick up filled prescriptions, medical supplies, x-rays, or other similar forms of PHI.

Disaster Relief Efforts.  We may use or disclose protected PHI to a public or private entity authorized by law or its charter to assist in disaster relief efforts for the purpose of coordinating notification of family members of your location, general condition, or death.

Uses and Disclosures Requiring Your Written Authorization

Psychotherapy Notes.  We must obtain your authorization for any use or disclosure of psychotherapy notes, except if our use or disclosure of psychotherapy notes is: (1) by the originator of the psychotherapy notes for treatment purposes, (2) for our own training programs in which mental health students, trainees or practitioners learn under supervision to practice or improve their counseling skills, (3) to defend ourselves in a legal proceeding initiated by you, (4) as required by law, (5) to a health oversight agency with respect to the oversight of the originator of the psychotherapy notes, (6) to a coroner or medical examiner; or (7) to prevent or lessen a serious and imminent threat to the health or safety of a person or the general public.

Marketing Communications; Sale of PHI.  We must obtain your written authorization prior to using PHI for marketing or the sale of PHI, consistent with the related definitions and exceptions set forth in HIPAA.

Other Uses and Disclosures.  Uses and disclosures other than those described in this Notice will only be made with your written authorization.  For example, you will need to sign an authorization form before we can send PHI to your life insurance company or to your attorney.  You may revoke any such authorization at any time by providing us with written notification of such revocation.

Your Individual Rights

Right to Inspect and Copy.  You may request access to your medical records and billing records maintained by us in order to inspect and request copies of the records.  All requests for access must be made in writing.  Under limited circumstances, we may deny access to your records.  We may charge a fee for the costs of copying and sending you any records requested.

Right to Alternative Communications.  You may request, and we will accommodate, any reasonable written request for you to receive PHI by alternative means of communication or at alternative locations.

Right to Request Restrictions.  You have the right to request a restriction on PHI we use or disclose for treatment, payment or health care operations.  You must request any such restriction in writing addressed to Compliance Office, P.O. Box 13060, Everett, WA 98206. We are not required to agree to any such restriction you may request, except if your request is to restrict disclosing PHI to a health plan for the purpose of carrying out payment or health care operations, the disclosure is not otherwise required by law, and the PHI pertains solely to a health care item or service which has been paid in full by you or another person or entity on your behalf.

Right to Accounting of Disclosures.  Upon written request, you may obtain an accounting of disclosures of PHI made by us in the last six years, subject to certain restrictions and limitations.

Right to Request Amendment.  You have the right to request that we amend your PHI.  Your request must be in writing, and it must explain why the information should be amended.  We may deny your request under certain circumstances.

Right to Obtain Notice.  You have the right to obtain a paper copy of this Notice by submitting a request to Community Health Center of Snohomish County, 8609 Evergreen Way, Everett, WA 98208 at any time.

Right to Receive Notification of a Breach.  We are required to notify you if we discover a breach of your unsecured PHI, according to requirements under federal law.

Questions or Complaints

If you desire further information about your privacy rights, or are concerned that we have violated your privacy rights, you may contact our Compliance Office Privacy line at 425-789-3774.  You may also file a written complaint with the Director, Office for Civil Rights of the U.S. Department of Health and Human Services.  We will not retaliate against you if you file a complaint with the Director or with our office.  If you believe your privacy rights have been violated, you can either file a complaint with our office, or with the Office for Civil Rights, U.S. Department of Health and Human Services (OCR).  There will be no retaliation for filing a complaint with either our practice or the OCR.  The address for the OCR regional office for Washington is as follows:

Office for Civil Rights
U.S. Department of Health and Human Services
2201 Sixth Avenue – M/S: RX-11
Seattle, WA 98121-1831

Effective Date And Changes To This Notice

Effective Date. This Notice is effective on May 23, 2013.

Changes to this Notice. We may change the terms of this Notice at any time.  If we change this Notice, we may make the new notice terms effective for all PHI that we maintain, including any information created or received prior to issuing the new notice.  If we change this Notice, we will post the revised notice in the waiting area of our office and on our web site at http://www.chcsno.org/.  You may also obtain any revised notice by contacting Community Health Center of Snohomish County, 8609 Evergreen Way, Everett, WA 98208.

webpage updated 6.10.2013