Your protected health information may be used and disclosed by OHA, our office staff and others outside of our office that are involved in your care and treatment for the purpose of providing health care services to you.  Your protected health information may also be used and disclosed to pay your health care bills and to support the operation of our practice.  Following are examples of the types of uses and disclosures of your protected health care information that OHA is permitted to make without your prior authorization.

Appointment Reminders: We may use and disclose health information to contact you to remind you that you have an appointment with us.

Treatment: We may use and disclose your protected health information to provide, coordinate, or manage your health care and any related services.  This includes the coordination or management of your health care with a third party that has already obtained your permission to have access to your protected health care information. For example, as necessary, we would disclose your protected health information for treatment purposes to a home health agency that provides care to you.  We may also disclose protected health information to other healthcare providers who may be treating you after we have obtained the necessary authorization from you to disclose your protected health information.  For example, your protected health information might be provided to a physician to whom you have been referred by this office to ensure that the physician has all the necessary information to diagnose or treat you.

In addition, from time to time we may disclose your protected health information to another physician or health care provider (specialist or laboratory) who, at the request of your OHA provider, becomes involved in your care by providing assistance with your health care diagnosis or/or treatment.

Payment: Your protected health care information may be used, as needed, to obtain payment for your health care services.  This may include working with a billing service to obtain payment for services or certain activities that your health insurance plan may undertake before it approves or pays for the health care services, we recommended for you such as: making a determination of eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity, and undertaking utilization review activities.  For example, obtaining approval for PT, MRI, or a hospital stay may require that your relevant protected health information be disclosed to the health plan in order to obtain approval for the hospital admission.

Healthcare Operations: We may use or disclose, as needed, your protected health information in order to support the business activities of OHA.  For example, we may use medical information in connection with conducting quality assessment, training, and improvement activities; conducting or arranging for medical review, legal services, and audit services, along with fraud and abuse detection programs; organizational planning and development such as cost management; and business management and general administrative activities.

“Minimum-Necessary” Standard:  HIPAA requires that when protected health information is used, disclosed, or requested, the amount disclosed generally must be limited to the “minimum necessary” to accomplish the purpose.  This does not apply to –uses or disclosures made to the individual, disclosures pursuant to a valid authorization, disclosures made to HHS, disclosures required by law, and required to comply with HIPAA.

Business Associates: We may share information with third parties that perform various activities (billing, transcription, and some treatment) for the practice.   We will always have a written contract in place with our business associates that contains terms that will protect the privacy of your protected health information.

Individuals Involved In Your Care or Payment for Your Care: Unless you object, we may disclose to a member of your family, a relative, a close friend or any other person you identify, your protected health information that directly relates to that person’s involvement in your health care or payment for your care.  If you are unable to agree or object to such disclosure, we may disclose such information as necessary if we determine that it is in your best interest based on our professional judgement.  We may use or disclose protected health information to notify or assist in notifying a family member, personal representative or any other person that is responsible for your care of your location, general condition or death.  Finally, we may use or disclose your protected health information to an authorized public or private entity to assist in disaster relief efforts and to coordinate uses and disclosures to family or other individuals involved in your care.

Emergencies: We may use or disclose your protected health information in an emergency treatment situation.  If this happens, your healthcare provider shall try to obtain your consent as soon as it is reasonably practical after delivery of treatment.  If your provider is required by law to treat you but is unable to obtain your consent, he or she may still use or disclose your protected health information to treat you.

Communication Barriers:  We may use or disclose your protected health information if your provider attempts to obtain consent from you but is unable to do so due to a communication barrier and the provider determines, using professional judgment, that you intend to consent to use or disclosure under the circumstances.

· Other Permitted and Required Uses and Disclosures That May Be Made Without Your Consent, Authorization or Opportunity to Object.

We may use or disclose your protected health information in the following situations without your consent or authorization.  These include:

Required by Law:  We may use or disclose your protected health information to the extent that the use or disclosure is required by law.  The use or disclosure will be made in compliance with the law and will be limited to relevant requirement of the law. You will be notified if required by law of any such uses or disclosures.

Public Health:  We may use or disclose your protected health information for public health activities and purposes to a public health authority that is permitted by law to collect or receive the information.  The disclosure will be made for the purpose of controlling disease, injury or disability.  We may use or disclose your protected health information, if directed by the public health authority, to a foreign government agency that is collaborating with the public health authority.

Communicable Diseases:  We may use or disclose your protected health information, if authorized by law, 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.

Health Oversight:  We may disclose protected 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.

Abuse or Neglect:  We may use or disclose your protected health information to a public health authority that is authorized by law to receive reports of child abuse or neglect.  In addition, we may use or disclose your protected health information if we believe that you have been a victim of abuse, neglect or domestic violence to a governmental entity or agency authorized to receive such information.  In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.

Food and Drug Administration:  We may use or disclose your protected health information to a person or company required by the Food and Drug Administration to report adverse events, product defects or problems, biologic, product deviations, track products, to enable product recalls, to make repairs or replacements, or to conduct post marketing surveillance, as required.

Legal Proceedings:  We may disclose protected 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 such disclosure is expressly authorized), in certain conditions in response to a subpoena, discovery request or other lawful process.

Law Enforcement:  We may also disclose protected 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 a victim of 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 practice, and (6) Medical emergency (not on premises) and it is likely that a crime has occurred.

Coroners, Funeral Directors, and Organ Donation:  We disclose protected health information to a coroner or medical examiner for identification purposes, determining cause of death, or for the coroner or medical examiner to other duties authorized by law.  We may also disclose protected health information to a funeral director, as authorized by law, in order to permit the funeral director to carry out their duties.  We may disclose such information in reasonable anticipation of death.  Protected health information may be used and disclosed for cadaveric organ, eye or tissue donation purposes.

Research:  We may disclose your protected health information to researches when their research has been approved by an institutional review board that has reviewed the research project and established protocols to ensure the privacy of your protected health information.

· You have the right to inspect and copy your protected health information.

This means that you may inspect and obtain a copy of protected health information about you.  This is contained in a designated record set for as long as we maintain the protected health information.  A “designated record set” contains medical and billing records and any other records that OHA uses for making decisions about you.  If the information you request is maintained electronically, and you request an electronic copy, we will provide a copy in the electronic form and format you request, if the information can be readily produced in that form and format; if the information cannot be readily produced in that form or format, we will work with you to come to an agreement on form and format.  If we cannot agree on an electronic form and format, we will provide you with a paper copy.

Under Federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or 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.  Depending on the circumstances, a decision to deny access may be reviewable.  Please contact our Privacy Officer if you have any questions about access to your medical record.

·   You have the right to request a restriction of your protected health information.

This means you may ask us, in writing, not to disclose or use any part of your protected health information for the purpose of treatment, payment for healthcare operations.  You may also request that any part of your protected health information not be disclosed to family members or friends who may be involved in your care or for notification purposes as described in this Notice of Privacy Practices.  Your written request must state the specific restriction requested and to whom you want the restriction to apply.

OHA is not required to agree to a restriction that you may request.  If the Physician believes it is in your best interest to permit use and disclosure or your protected health information, your protected health information will not be restricted.  If your Physician does agree to the requested restriction, we may not use or disclose your protected health information in violation of that restriction unless it is needed to provide emergency treatment.  With this in mind, please discuss any restriction you wish to request with your Physician.  We will comply with any restriction request if (1) except as otherwise required by law, the disclosure is to a health plan for purposes of carrying out payment or health care operations (and is not for purposes of carrying out treatment) and (2) the protected health information pertains solely to a health care item or service for which the health care provider involved has been paid in full by you or another person.  You may request a restriction by contacting our Privacy Officer.

· You have the right to request to receive confidential communications from us by alternative means or at an alternative location.

We will accommodate reasonable requests.  We may also condition this accommodation by asking you for information as to how payment will be handled or specification of an alternative address or other method of contact.  We will not request an explanation from you as to the basis of the request.   Please make this request in writing to our Privacy Officer.

· You may have the right to have OHA amend your protected health information.