NEIGHBORHOOD HEALTH SERVICES CORPORATION (THE "CENTER")

Notice of Privacy Practices
Effective April 14, 2003

THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION

PLEASE REVIEW THIS NOTICE CAREFULLY
This Notice of Privacy Practices (Notice) describes how the Neighborhood Health Services Corporation (Center) may use and disclose your protected health information. Protected Health Information ("Health Information") is information about you, including demographic information, that may identify you and that relates to your past, present or future physical or mental health, and the provision of health care and payment for health care. The Center may use and disclose this information 1) to carry out treatment payment or health care operations, 2) for other purposes that are permitted or required by law and 3) for other purposes only with your written authorization.
This Notice also describes your rights to access and to control your protected health information and the Center’s duties to maintain the privacy of your protected health information. If you are legally or otherwise incapable of exercising your rights, you may have a person who is authorized under State law (for example power of attorney) to act on your behalf. In the case of a minor child, the parent or guardian can exercise the child’s rights with respect to protected health information.

How the Center Uses and Discloses Protected Health Information for Treatment, Payment and Health Care Operations

Your Health Information may be used by the Center, to provide health care services to you, to submit claims for reimbursement and to support the operations of the Center. The following are some but not all of the ways in which we may use your Health Information.
Examples:
1. Treatment. Health Information may be used for the provision of health care, coordination or management of your treatment or the provision of related services to you by one or more health care providers. For example the Center may consult with another health care provider. The Center may send a copy of your medical record to a specialist who needs the information to treat you or to a hospital to which you are admitted.
2. Payment. The Center may use and disclose Health Information to so that the Center may obtain payment for the services provided to you. For example the Center may disclose Health Information to determine your eligibility for payment; to bill third party insurance companies or Medicaid or Medicare; or to attempt to collect payment from you and for other related activities. Health Information may be disclosed to consumer reporting agencies relating to our collection efforts. The Center may disclose Health Information to make sure that the insurance or Medicaid or Medicare will cover the service or to obtain pre authorizations or for quality evaluations by your health plan. For example Health Information could be disclosed to obtain approval from your health plan for treatment or hospital admission.

3. Healthcare Operations. The Center may use your Health Information 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 of the healthcare the Center provides; reduce costs; and evaluate the performance of our staff. The Center may also use your Health Information for training health care professionals, accreditation and other administrative activities of the Center. The Center may use your Health Information to evaluate the Center contracts with insurance companies or to audit compliance with the law. The Center may disclose your Health Information to legal counsel or other persons who are performing services for us. To protect your health information, however, we require these persons to appropriately safeguard your Health Information.

The Center may ask you to sign a consent form to use and disclose your Health Information for treatment, payment and health care operations although we are not obligated to do so.

The Center may also use a sign-in sheet at the registration desk, where you will be asked to sign your name and indicate your physician. You may be called by name in the waiting room when the physician is ready to see you. The Center may send you appointment reminders.

The Center may use or disclose your Health Information, as necessary, to provide you with information about treatment alternatives or other health-related benefits and services that may be of interest to you. The Center may send you a newsletter.

The Center may disclose to a business associate or a foundation Health Information in an effort to raise money for the Center. Please let us know if you do not want us to contact you about fundraising. Our fundraising materials will tell you how to tell us that you do not want to receive information about fundraising.

When the Use and Disclosure of Protected Health Information by the Center Requires An Opportunity for You to Agree or Object

The Center may use and disclose your Health Information under circumstances in which you have the opportunity to agree or object to all or part of the use or disclosure. If you are not able to agree or object, then the Center may determine whether the use and disclosure is in your best interest.
Examples:
1. Communication with family. The Center may disclose to a family member, other relative, close personal friend or any other person you identify Health Information relevant to that person’s involvement in your care or payment related to your care.
2. Facility Directories. The Center may use Health Information to maintain a directory of individuals in its facility. The Center will advise you of the Health Information contained in the directory and to whom it may be disclosed.

When the Center May Use and Disclose Protected Health Information Based Upon Your Written Authorization
Certain other uses and disclosures of your Health Information will be made only with your written Authorization, as described below unless otherwise permitted or required by law without authorization. You may revoke this Authorization at any time in writing, except to the extent that the Center or your physician or has taken an action in reliance on your signing the Authorization.
Examples:
1. Psychotherapy Notes. In most instances, the Center must obtain an Authorization from you for use and disclosure of psychotherapy notes. “Psychotherapy notes” are notes by a mental health professional documenting or analyzing the contents of conversation during a private counseling or group session that are separated from the rest of your medical records. They do not include symptoms, diagnosis or a treatment plan.
2. Marketing. Except in certain circumstances the Center must obtain your authorization for any use of Health Information for marketing. If the Center receives compensation from a third party for the marketing, the authorization will disclose this. For example, the Center may not provide a patient list to a pharmaceutical company for drug promotions without an Authorization.


When the Center May Use and Disclose Protected Health Information without Your Consent or Authorization or Opportunity to Object
Your Protected Health Information may be used or disclosed by the Center without your consent or authorization or opportunity to object. The following are some examples.
Examples:
1. Required by Law. The Center may disclose your Health Information to the extent that the use or disclosure is required by Federal, State or local law.
2. Public Health. We may disclose your Health Information to public health or legal authorities charged with preventing or controlling disease, injury or disability.
3. Food and Drug Administration (FDA). The Center may disclose to the FDA health information relative to adverse events with respect to food, supplements, product and product defects or post marketing surveillance information to enable product recalls, repairs or replacement.
4. Communicable Diseases. The Center may disclose your Health Information, to a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading the disease or condition.
5. Abuse or Neglect. The Center may disclose your Health Information to a public health authority that is authorized by law to receive reports of child abuse or neglect. In addition, we may disclose your protected health information if we believe that you have been a victim of abuse, neglect or domestic violence to the governmental entity or agency authorized to receive such information.
6. Health Oversight. The Center may disclose Health Information to a health oversight agency for activities authorized by law, such as audits, investigations and inspections. Oversight agencies seeking this information include government agencies that oversee the health care system, government benefit programs, other government regulatory programs and civil rights laws.
7. Judicial and Administrative Proceedings. The Center may disclose your Health Information in the course of any judicial or administrative proceeding, in response to an order of a court or administrative tribunal, to the extent that such disclosure is expressly authorized and in certain conditions in response to a subpoena, discovery request or other lawful process.
8. Law Enforcement. The Center may disclose Health Information so long as applicable legal requirements are met, for law enforcement purposes. These law enforcement purposes include (1) legal processes and otherwise required by law; (2) limited information requests for identification and location purposes; (3) pertaining to victims of a crime; (4) suspicion that death has occurred as a result of criminal conduct; (5) in the event that a crime occurs on the premises of the Center; and (6) medical emergency (not on the Center’s premises) and it is likely that a crime has occurred.
9. Funeral Directors and Coroners. The Center may disclose Health Information to funeral directors consistent with applicable law to permit them to carry out their duties. Health Information may be disclosed to a coroner or medical examiner for identification purposes, determining the cause of death or for the coroner or medical examiner to perform other duties authorized by law.
10. Organ procurement organizations. The Center may disclose information consistent with applicable health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of organ, eye or tissue donation and transplant.
11. Research. The Center may disclose information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your protected health information or with an authorization from you.
12. Military Activity and National Security. When appropriate conditions apply, the Center may use or disclose Health Information of individuals who are Armed Forces personnel for activities deemed necessary by appropriate military command authorities; or who are foreign military personnel to a foreign military authority. We may also disclose your Health Information to authorized federal officials conducting national security and intelligence activities including the provision of protective services to the President or others legally authorized.
13. Correctional Institution. If you are an inmate of a correctional institution or in the custody of a law enforcement officer the Center may disclose to the institution or agents thereof Health Information necessary for your health and the health and safety of other individuals and other purposes.
14. Workers Compensation. The Center may disclose Health Information related to workers compensation or other similar programs dealing with work-related illnesses or injuries.

YOUR RIGHTS AND HOW TO EXERCISE THEM

Although your health record is the physical property of the Center, the information in it belongs to you. You have the following rights:
1. Restrictions. You may request restrictions on certain uses and disclosures of your Health Information such as for treatment, payment or health care operations or disclosure to family members. Your request must state the specific restriction requested and to whom you want the restriction to apply. The Center is not required to agree to a restriction that you may request. If the Center agrees to the requested restriction, we will not use or disclose your protected health information in violation of the restriction, unless it is needed to provide emergency treatment. You may request a restriction in writing on a form provided by the Center. In your request you must tell us what information you want to limit and to whom the Health Information should not be disclosed.
2. Notice. You may obtain a paper copy of this Notice of Privacy Practices upon request, even if you have received the Notice electronically.
3. Inspection and copies. You may inspect and obtain a copy of your health record. This does not include psychotherapy notes, information compiled in reasonable anticipation of or for use in a civil, criminal or administrative action or proceeding and protected health information that is subject to law that prohibits access to protected health information. To inspect or request a copy of your health record; submit your request to the Privacy Official at the Neighborhood Health Services Corporation in writing on a form for provided by the Center. We may charge a fee for the costs of locating, copying, mailing or other supplies and services associated with your request.
4. Amendments. You may request amendments to your health record if you believe that the information in inaccurate. In certain cases, the Center may deny your request for an amendment. For example the request will be denied if it is not in form provided to us; you have not provided sufficient support for the request; the Center did not create the health record; the Center does not keep that information; is information that you are not permitted to inspect or is accurate and complete. You will then have the right to file a statement of disagreement with the Center. The Center or your physician may place a counterstatement in your medical record.
5. Accounting of Disclosures. You may obtain an accounting of the disclosures of your health information by the Center by submitting your request to the Neighborhood Health Services Corporation Privacy Officer in writing on a form provided by the Center to you. This does not apply to disclosures for treatment, payment or healthcare operations as described in this Notice. It also excludes disclosures the Center may have made to you, family members or with an Authorization. The right to receive this accounting is subject to certain exceptions, restrictions and limitations.
6. Confidential Communications. You have the right to request communications of your health information by alternative means or at alternative locations. The Center will accommodate reasonable requests. We may ask you for information as to how payment will be handled or request an alternative address or other method of contact. Make your request in writing to the Privacy Officer on a form provided by the Center.

THE CENTER’S RESPONSIBILITIES

The Center has the following obligations:
1. Privacy. The Center is required by law to maintain the privacy of your Health Information.
2. Notice. The Center must provide you with this Notice as to our legal duties and privacy practices with respect to the Health Information that we collect and maintain about you and abide by the terms of the Notice currently in effect. We reserve the right to change our privacy practices and this Notice and to make the new provisions effective for all protected heath information we maintain. Should our information practices change, we will post the new Notice in the Center and on our web site and make the revised Notice available to you upon request.
3. Restrictions. The Center will notify you if we are unable to agree to a requested restriction of use and disclosure of your Health Information.
4. Confidential Communications. The Center will accommodate reasonable requests you may have to communicate heath information by alternative means or at alternative locations.

For More Information or to Report a Problem

If you have any questions about this Notice and would like additional information, you may contact the Center’s Privacy Officer at [phone number].

If you believe your privacy rights have been violated, you can file a complaint with the Center’s Privacy Officer at 1700 Myrtle Avenue, Plainfield New Jersey or with the Secretary of Health and Human Services. There will be no retaliation for filing a complaint.

Health Insurance Portability and Accountability Act (HIPAA 96, Public Law 104-191 and Regulations – Standards for Privacy of Individual Identifiable Health Information (the Privacy Rule), 45 CFR Parts 160 and 164.

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