Notice of privacy practices
Dear CliniSanitas Patient:
CliniSanitas is committed to protect our patients' medical information. Controlled use of medical information by staff at CliniSanitas is essential to our mission.
The United States government created rules for the use and protection of medical and health information by hospitals, clinics and other medical practices. The rules are a result of the 1996 Health Insurance Portability and Accountability Act (HIPAA). They are meant to provide all patients in the United States with standard privacy protections. One rule requires hospitals and clinics to provide all patients with a Notice of Privacy Practices to explain how patient medical information is used. The same rule requires hospitals and clinics to keep records showing that patients have received the notice.
If you have questions about anything contained in this notice, please feel free to contact the site privacy manager. Contact information is provided in the final section of this notice.
Thank you for placing your care, and your trust, in CliniSanitas.
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.
By law, CliniSanitas must keep protected health information private. The federal government defines protected health information as any information, whether oral, electronic or paper, which is created or received by CliniSanitas and relates to a patient's physical or mental health or condition, or payment for the provision of medical services.
This includes not only the results of tests and notes written by doctors, nurses and other clinical personnel, but also certain demographic information (such as your name, address and telephone number) that is related to your health records.
CliniSanitas is required by law to give you this notice and to follow the terms and conditions of the notice that is currently in effect. CliniSanitas will report breaches of your unsecured protected health information as required by law.
How CliniSanitas fulfills these duties:
- CliniSanitas considers patient privacy as part of its mission to serve the needs of the patient first.
- CliniSanitas takes necessary precautions against inappropriate use or disclosure of protected health information.
- CliniSanitas employees are expected to access protected health information only as necessary to perform their jobs.
- CliniSanitas employees who violate these rules and policies are subject to sanctions, including discipline and termination.
The Health Care Providers Covered By This Notice
This notice covers CliniSanitas and CliniSanitas personnel, volunteers, students, and trainees. The notice also covers other health care providers that come to CliniSanitas's facilities to care for patients (such as physicians, physician assistants, therapists, and other health care providers not employed by CliniSanitas), unless these other health care providers give you their own notice of privacy practices that describes how they will protect your protected health information. CliniSanitas may share your protected health information with other health care providers for their treatment, payment and health care operations. This arrangement is only for sharing information and not for any other purpose.
Part I — Most Common Uses and Disclosures
This section describes the most common circumstances in which CliniSanitas may use or disclose protected health information.
- Treatment: CliniSanitas will use and disclose protected health information to provide, coordinate or manage your care. This includes communication and consultation between health care providers — doctors, nurses, technicians and other members of your medical team. This applies to disclosures for treatment purposes to health care providers both within and outside of CliniSanitas.
- Payment: CliniSanitas will use and disclose protected health information to create bills and collect payment from insurance companies, Medicare and other payers. This may include providing information such as dates of service, symptoms, and diagnosis to your insurance company to show that CliniSanitas provided medical services to you. CliniSanitas also may disclose protected health information to another health care provider if such information is needed by the other health care provider to obtain payment for medical services provided to you.
- Health care operations: CliniSanitas will use and disclose protected health information if it is necessary to improve the quality of care we provide to patients or to run our health care facilities. These include activities to monitor and improve patient care, license staff to care for patients, prepare for state and federal regulatory reviews, train health care and non health care professionals, manage health care operations, and improve health care services. For example: A Federal Drug Administration inspector may review patient records in a laboratory to ensure that accurate and complete records are maintained for patient safety. CliniSanitas may also disclose protected health information to another health care provider who has treated you, or to your insurance company, if such information is needed for certain health care operations of the health care provider or insurance company, such as quality improvement activities, evaluations of health care professionals, and state and federal regulatory reviews.
- Patient contacts: At times, CliniSanitas may access information, such as your name, address and general medical condition to contact you to:
- Set up or remind you about future appointments; provide information about treatment alternatives or other information that may be of interest to you; or
- Disclose health-related benefits or services that may be of interest to you.
- Additional Applicable State Law Requirements. Florida law generally requires patient consent for CliniSanitas in Florida entities to contact their patients for purposes of providing information regarding treatment alternatives, services, or goods.
- Philanthropy: CliniSanitas may contact you to raise funds to sustain the CliniSanitas mission. For example, you may receive letters or other publications asking you to consider making a tax-deductible contribution to CliniSanitas. When conducting fundraising activities, CliniSanitas may access only your basic demographic information (such as name and contact information), the dates that you were treated at CliniSanitas, information about the department of service that provided treatment and the treating physician, information about your outcome, and your health insurance status. You may contact us and request to not receive any fundraising communications. CliniSanitas does not sell or rent patients' names or addresses to any organization outside of CliniSanitas.
- Facility Directory/Patient Census: CliniSanitas may include your name, location in a facility, health condition (in general terms, such as "good," "fair") and religious affiliation (should you choose to provide one) in current patient lists for our facilities. This information is maintained for CliniSanitas personnel to assist family members and other visitors or persons in locating you while you are in CliniSanitas's facilities. For example, a relative may wish to visit you in the urgent care or a family member meeting you for an appointment may have forgotten which floor your appointment is on. This information is only shared with people who ask for you by name or with members of the clergy. If you indicate a religious affiliation, it will be shared only with members of the clergy. You can choose not to have such information released from the facility directory/patient census. If you do not want CliniSanitas to release such information, please inform the person assisting you during registration and/or admission.
- Family Members and Others Involved in Your Care: CliniSanitas may disclose relevant protected health information to a family member or friend who is involved with your care. We find that many patients want us to discuss their care with their family members and others to keep them up-to-date on your care, to help you understand your care, to help in handling your bills, or to help in the scheduling of your appointments. In a disaster situation, we also may disclose relevant protected health information to disaster relief organizations to help locate your family members or friends or to inform them of your location, condition or death. If family members or friends are present while care is being provided, CliniSanitas will assume your companions may hear the discussion, unless you state otherwise. If you do not want CliniSanitas to disclose your protected health information to your family members or others who are involved with your care or handling your bills, please inform the person assisting you during registration and/or admission. CliniSanitas may also disclose your protected health information to a personal representative who has authority to make health care decisions on your behalf.
- Medical Research: Medical research is vital to the advancement of medical science. Federal regulations permit use of protected health information in medical research, either with your authorization, when your name and most other identifiers have been removed and the recipient of the information signs a data use agreement, or when the research study at CliniSanitas is reviewed and approved by an Institutional Review Board before any medical research study begins. In some situations, limited information may be used before approval of the research study to allow a researcher to determine whether enough patients exist to make a study scientifically valid.
Part II Other Potential Uses and Disclosures
This section describes the less common circumstances in which CliniSanitas may use or disclose protected health information.
- To Avert a Serious Threat of Harm: CliniSanitas may use and disclose protected health information to alert those able to prevent or lessen a serious and immediate threat to the health or safety of a patient, another person or the public.
- Organ and Tissue Donation: If CliniSanitas professionals determine that a patient might be a candidate for organ or tissue donation, CliniSanitas may release protected health information to organizations that handle organ procurement, or organ, eye, tissue donation banks, or other health care organizations as needed to make organ or tissue donation and transplantation possible.
- Military Personnel: If a patient is a member of the United States Armed Forces, CliniSanitas may release protected health information as required by military authorities. CliniSanitas also may release protected health information about foreign military personnel to the appropriate foreign military authority. When the military organization is sponsoring the medical evaluation, the patient's protected health information is shared with both the patient and the sponsoring organization. Patients being evaluated on behalf of the military should be aware of these arrangements.
- Workers' Compensation: CliniSanitas may disclose protected health information for workers' compensation or similar programs as authorized or required by law. These programs provide benefits for work-related injuries or illness.
- Public Health Purposes: CliniSanitas may disclose protected health information for public health purposes. The following are some examples of releases that are allowed for public health purposes:
- To report vital statistics (e.g., births, deaths).
- To report to the federal government adverse reactions to medication or safety problems with FDA-regulated products.
- To notify people of product recalls; and to report communicable diseases to local, county, state, and federal health officials.
- Additional Applicable State Law Requirements
- Health Oversight Activities: CliniSanitas may disclose protected health information to health oversight agencies that oversee our operations or personnel. For example, CliniSanitas may need to disclose protected health information to the state agencies that oversee our health care facilities or licensed health care personnel (e.g., Department of Health, Medical Board, Nursing< Board), or the federal agencies that oversee Medicare. These agencies need such information to monitor our compliance with state and federal laws.
- Lawsuits and Other Judicial Proceedings: CliniSanitas may disclose protected health information in response to a valid court or administrative order. CliniSanitas also may disclose protected health information in response to certain types of subpoenas, discovery requests or other lawful process.
- Law Enforcement Activities: CliniSanitas may disclose protected health information to law enforcement officials. For example, we may release protected health information to law enforcement officials:
- In response to a valid court order, grand jury subpoena, or search warrant.
- To identify a suspect, fugitive or missing person.
- About the victim of a crime under certain limited circumstances.
- About a death believed to be a result of criminal conduct.
- About a crime committed on CliniSanitas premises.
- Additional Applicable State Law Requirements.
- Coroners, Medical Examiners and Funeral Directors: CliniSanitas may release protected health information to a coroner or medical examiner when necessary to identify the deceased, determine the cause of death or as otherwise authorized by law. CliniSanitas also may release protected health information to a funeral director as necessary to carry out the funeral director's duties, including arrangements after death.
- National Security Activities: CliniSanitas may release protected health information to authorized federal officials for intelligence, counterintelligence or other national security activities authorized by law. CliniSanitas also may disclose protected health information to authorized federal officials so they may provide protection to the President or other authorized individuals.
- Additional Applicable State Law Requirements: Florida law generally requires patient consent for disclosures of protected health information by CliniSanitas in Florida entities for national security purposes, unless the disclosure is specifically required by federal law.
- Required by Law: CliniSanitas will use or disclose protected health information when required by federal, state, or local laws. For example, CliniSanitas is required to report certain gunshot wounds and other injuries that may have resulted from an unlawful act, and abuse or neglect of a child or vulnerable adult.
- Permitted by Law: CliniSanitas may use or disclose protected health information when permitted by federal, state, or local laws. For example, some CliniSanitas entities are permitted to make a report to the Department of Transportation regarding a patient's ability to drive when the report is necessary to prevent or lessen a threat to the health or safety of a person or the public.
Uses and Disclosures Pursuant to an Authorization
Except as described in this notice or specifically required or permitted by law, CliniSanitas will not use or disclose your protected health information without your specific written authorization. At times, a CliniSanitas entity may ask you to provide specific written permission to allow the CliniSanitas entity to use or disclose protected health information about you. CliniSanitas generally will not use or disclose your protected health information for marketing purposes, in exchange for remuneration, or use or disclose any psychotherapy notes about you unless CliniSanitas receives your authorization to do so. A valid authorization may be revoked in writing at any time. Written revocation of authorization must be submitted to the applicable CliniSanitas entity and addressed to the Health Information Management Services. Once the authorization is revoked, the CliniSanitas entity will no longer be allowed to use or disclose protected health information for the purposes described in the authorization except to the extent the CliniSanitas entity has already taken action based upon the authorization.
Information with Additional Protections
Certain types of protected health information may have additional protection under federal or state law. For example, protected health information about mental health, HIV/AIDS and genetic testing results is treated differently than other types of protected health information under certain state laws. Additionally, federally assisted alcohol and drug abuse programs are subject to certain special restrictions on the use and disclosure of alcohol and drug abuse treatment information. To the extent applicable, CliniSanitas would need to get your written permission before disclosing that information to others in many circumstances.
Part III Patients' Rights with Respect to Protected Health Information
This section describes the rights of CliniSanitas patients to protected health information.
- Right to Inspect and Copy: You have the right to inspect and to request a copy of information maintained in CliniSanitas's designated medical record about you. This includes medical and billing records maintained and used by CliniSanitas to make decisions about your care.
To obtain or inspect a copy of your protected health information, submit a written request to the applicable CliniSanitas entity and address the request to the attention of the Health Information Management Services. CliniSanitas generally may charge a reasonable, cost-based fee to cover the expense of providing copies. CliniSanitas Arizona Entities are not permitted under Arizona law to charge a fee if the information is needed for treatment purposes.
Most patients have full access to inspect and receive a copy of the full medical record. On rare occasions, CliniSanitas may deny a request to inspect and receive a copy of some information in the medical record. For example, this may occur if, in the professional judgment of a patient's physician, the release of the information would be reasonably likely to endanger the life or physical safety of the patient or another person.
- Right to Request Alternate Methods of Communication: You have a right to request that CliniSanitas communicate with you in certain ways (such as a letter or by phone) or at a certain location. For example, you may ask that we contact you only at home or only at your place of business. In this situation, you may submit a written request to the applicable CliniSanitas entity specifying the communication method or alternative location being requested. The request should be addressed to the attention of the Site Privacy Officer. CliniSanitas will accommodate reasonable requests. However, if the request could result in CliniSanitas not being able to collect for services or cause significant administrative burden, CliniSanitas reserves the right to require you to provide additional information about how payment for services will be handled.
- Right to Request Amendment: You have the right to request that your protected health information in CliniSanitas's designated medical record for you be amended. If you wish to request amendment of the information in your record, submit a written request to the applicable CliniSanitas entity and address the request to the attention of the Health Information Management Services. The request must include a reason to support the amendment. CliniSanitas may deny a request for amendment based upon any of the following circumstances:
- The request is not in writing or does not include a supporting reason.
- CliniSanitas did not create the information you want to change, and the originator of the information is available to make the amendment.
- The information is not part of the designated medical record.
- The information in the record is accurate and complete
If CliniSanitas denies your request for an amendment, CliniSanitas will give you a written explanation of the denial. If you still disagree with the explanation provided, you can submit your written disagreement to CliniSanitas as referenced above, or you can ask that your request for amendment and explanation of the denial, or an accurate summary of such information, be included in any future disclosure of the pertinent protected health information. If you submit a statement of disagreement, CliniSanitas may include a rebuttal statement addressing your statement of disagreement in the designated medical record.
- Right to a List of Certain Disclosures: You can ask CliniSanitas for a list of the persons or organizations to which CliniSanitas has disclosed your protected health information. This list would provide you with a summary of certain disclosures CliniSanitas has made that you would not otherwise be in a position to know about. The following are examples of disclosures that would not be included in the list:
- Disclosures to carry out treatment, payment and health care operations.
- Disclosures made directly to you (the patient) or disclosures that you have specifically authorized.
- Disclosures made from the facility directory/patient census.
- Disclosures to persons involved in your care.
- Disclosures incident to a use or disclosure that is otherwise permitted or required by law.
- Disclosures made for national security or intelligence purposes.
- Disclosures made to correctional institutions or law enforcement officials having custody over a patient.
- Disclosures that took place before April 14, 2003.
To obtain a copy of the list, submit a written request to the applicable CliniSanitas entity and address the request to the attention of the Site Privacy Officer. Your request must state a time period (beginning no earlier than April 14, 2003 when the federal privacy rules go into effect and for no longer than six years). The first list requested within a 12-month period shall be provided at no charge. For additional lists requested during the same 12-month period, CliniSanitas may charge for the costs of providing the list.
- Right to Request Restrictions: You can ask CliniSanitas to restrict the use or disclosure of protected health information about you for treatment, payment, or health care operations. Your request must be in writing and submitted to the applicable CliniSanitas entity. The request should also be addressed to the attention of the Site Privacy Officer. CliniSanitas will carefully consider all requests. However, because of the integrated nature of CliniSanitas's medical record, CliniSanitas is not generally able to honor most requests, nor is CliniSanitas legally required to do so. If you or someone on your behalf pays for a health care item or service in full, you can request that CliniSanitas not disclose information about the item or service to your health plan for payment or health care operations purposes, and CliniSanitas will agree to your request unless required by law to make the disclosure.
- Right to Notice of Privacy Practices: You have the right to obtain a paper copy of this notice upon request, even if you have agreed to receive the notice electronically. To obtain a paper copy of this notice, submit a written request to the any CliniSanitas entity. The request should be addressed to the attention of the Site Privacy Officer.
If you want to file a complaint or express concerns about CliniSanitas's use or disclosure of Protected Health Information, please contact:
Security and Privacy Manager
8400 NW 33rd Street
Miami, Florida 33122
You can also call the general number at 1-844-665-4827and ask for the Security and Privacy Manager.
You also may file a written complaint with the United States Department of Health and Human Services — Office for Civil Rights. CliniSanitas honors your right to express concerns regarding your privacy. CliniSanitas would not — nor could it legally or ethically — take action against you for filing a concern or complaint regarding the use, disclosure, and rights of your protected health information.
Key Information about this Notice
This is a revised notice for the CliniSanitas entities and health care practice sites referenced on the first page (collectively referred to as "CliniSanitas"). The effective date of this revised notice is August 24, 2015.
From time to time, CliniSanitas may change its practices concerning how we use or disclose protected health information, or how we will implement patient rights concerning their information. CliniSanitas reserves the right to change the terms of this notice and make the new notice provisions effective for all protected health information maintained by CliniSanitas. CliniSanitas will follow the terms and conditions of the notice that is currently in effect.
If you have any questions, or would like to discuss this notice in more detail, please contact the Security and Privacy Manager.