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Notice of Privacy Practices
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.
The following Notice contains description of the privacy practices of:
- Michigan Orthopedic Services.
- Its physicians, practitioners and other health care professionals who enter health information into your medical record.
- All departments including, e.g., medical records and billing departments.
- All our healthcare sites.
- All our employees, staff, volunteers and other personnel who work on our behalf.
- Michigan Orthopedic Services is committed to the provision of high quality and clinically effective orthotic & prosthetic care. We evaluate, cast, fabricate, modify, adjust, fit and deliver custom Orthotic & Prosthetic devices for patients with various diseases disorders, neuropathies and conditions.
Policy on Health Information
Although your health information in designated record sets is our property we understand that it is to be kept confidential. You have the right to access, amend and receive an accounting of disclosures of your health information for 6 years since its creation. You may obtain a copy of your requested health information and Michigan Orthopedic Services may charge a cost-based fee for this purpose.
This notice applies to the health information in our records made by our health care professionals.
Responsibilities of Michigan Orthopedic Services
We are required to:
- Ensure the confidentiality and privacy of your health information.
- Provide you with this notice of our legal duties and privacy practices regarding your personal health information.
- Abide by the terms of this notice of the followed privacy practices.
- Respond to your reasonable requests to communicate your health information by alternative means or at alternative locations.
We may disclose your health information for:
Treatment
We may use the personal health information to provide health care treatment or services. We may disclose health information to the physicians, practitioners and all others involved in your health care. They may be working at one our centers or at our labs, fabrication center or other places rendering our health care services to whom we may refer you for lab tests, x-rays prescriptions and/or other health care services. We may also use your information to send reminders for treatment or consultation appointments.
For example we may consult with our specialist orthotic care physician for providing health care services to your broken leg or fractured knee or other prosthetic or orthotic care you need.
Payment
We may use and disclose your personal health information to obtain and process a payment from either you or your insurance company like Medicare, Medicaid, BCBS, Aetna and other insurance or any other third parties capable of reimbursing the health care provided to you.
Your health information may also be disclosed to other health care providers or health plans that can arrange for the payment for your health care.
For example we may share the information with a health plan about your visit to our center to enquire on a payment status.
Health Care Operations
We may use your personal health information for internal use to provide appropriate healthcare services. The uses and disclosures made are required for providing the necessary health care such that all the patients get quality healthcare from our highly qualified healthcare professionals.
For example, we may use health information to review our services provided and to evaluate performance of the staff involved in your health care.
Other Uses or Disclosures
Business Associates
Some of the services offered by our center are through contacts with business associates. Examples are custom orders of knee, ankle, foot moulds. When these services are contracted, we may disclose your health information to our business associate so that they can perform the job we've asked them to do. We appropriately safeguard your information by implementing a business associate agreement that contains the conditions for sharing information.
Notification
We may use or disclose your information to your family members, personal representative or any other person identified by you, responsible for your healthcare and your general medical condition. In case of an emergency or when the patient is not capable of making that decision, Michigan Orthopedic Services employee may use professional judgment and disclose relevant health information to the person involved in your healthcare.
Communication with Family
We use professional judgment in disclosing your protected health information to your family member or your personal representative who is responsible for taking health care decisions on your behalf.
Research
We do not currently share information with Researchers, Research teams or firms. But, we may disclose your personal health information to a research team or a researcher involved in study of health care if that person or team gets an approval from an Institutional Review Board or Privacy Board or when authorized by you.
Funeral Directors
We may disclose personal health information to funeral directors consistent with applicable federal or state laws to carry out their duties, in a specific case. This may be necessary, in a case where a deceased person needs to be identified or the cause of death needs to be determined.
Organ Procurement Organizations
We do not currently share information with organ procurement agency. But, if you are an organ or tissue donor, we may disclose health information to organizations, entities and organ donation banks engaged in the procurement and transplantation of organs for the purpose of tissue donation and transplant.
Marketing
We do not currently share information with any marketing firms. But, we may contact you to provide information about treatment alternatives or other health related benefits and services that may be of interest to you, face to face, while you are at one of our sites.
Fund Raising
We do not currently use your information for fund-raising purposes. But, we may contact you as part of a fund-raising effort when we raise funds for our own benefit.
Workers Compensation
We may disclose your personal health information pursuant with workers compensation laws. These programs provide benefits for work-related injuries and illness.
Public Health
We may disclose your personal health information without your authorization to:
- A public health or legal authority charged with preventing or controlling disease, injury or disability.
- An official of a foreign government agency, acting in collaboration with a public health authority.
- A public health/government authority authorized by law to receive reports of child abuse or neglect.
- A person subject to the jurisdiction of the FDA.
Health Oversight Activities
We may disclose your personal health information without your authorization to a health oversight agency for oversight activities authorized by law, including audits, civil, administrative, or criminal investigations, inspections and licensure. Any of these activities may be deemed necessary by the government to monitor the health care system, government programs and compliance with federal and civil right laws.
Correctional Institution
If your are an inmate of a correctional institution, we may disclose your personal health information without your authorization to institutions or agents involved in your healthcare for your treatment, for health and safety of other individuals and safety and security of the correctional institution.
Law Enforcement
We may disclose your health information without your authorization for law enforcement purposes, when asked by law enforcement official:
- In response to a court order, subpoena, warrant, summons or similar process.
- To identify or to locate a suspect, fugitive, material witness or a missing person.
- Under certain limited circumstances, about the victim of a crime.
- About an individual who is or is suspected to be a victim of a crime.
- About criminal conduct at our center or our other centers.
- To report a crime, location of the crime or victims, or the identity, description or location of the person who committed the crime.
- Specialized government purposes: We may disclose your health information without your authorization if you are a member of the Armed Forces personnel for activities deemed necessary by appropriate military command authorities for proper execution of the military mission.
We may release your health information to authorized federal officials for intelligence, counter-intelligence and other national security activities authorized by law.
We may disclose your health information to authorized federal officials so that they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
Your Rights
You have the following rights regarding your personal protected health information.
Right to Inspect and Copy
You have the right to inspect and copy your personal health information in medical, billing or other records. For this purpose, you must submit the request form in writing to the privacy official identified on the first page of this notice. We may charge a cost based fee for the copying and mailing costs if applicable.
We may deny your request to inspect and copy under the following circumstances:
- An individual's access to PHI contained in records subject to the Privacy Act (5 U.S.C. 552a) may be denied in accordance with the requirements of the Act;
- The health information was obtained from someone other than a health care provider under a promise of confidentiality and the access requested would be reasonably likely to reveal the source of the information;
- A licensed health care professional has determined, in the exercise of professional judgment, that the access requested is reasonably likely to endanger the life or physical safety of the individual or another person;
- The health information makes reference to another person (not a health care provider) and a licensed health care professional has determined, in the exercise of professional judgment, that the access requested is reasonably likely to cause substantial harm to such other person;
- The request for access is made by the individual's personal representative and the protected health information makes reference to another person (not a health care provider) and a licensed health care professional has determined, in the exercise of professional judgment, that the access requested is reasonably likely to cause substantial harm to the individual or another person.
- If access is denied based on one of the grounds set forth in (2), (3) and (4) above, the individual has the right to have the denial reviewed by a licensed health care professional, designated by Michigan Orthopedic Services to act as a reviewing official, who did not participate in the original decision to deny. Michigan Orthopedic Services shall promptly refer a request for review to the reviewing official, who must then determine, within a reasonable period of time, whether or not to deny the access requested based on the grounds set forth above. Michigan Orthopedic Services shall promptly provide written notice to the individual of the reviewing official's determination, and shall provide or deny access in accordance with the determination.
Right to Amend
Your may ask us to amend your health information if you think that it is incorrect or incomplete. Your request for the amendment must be in writing and submitted to our privacy official identified on the first page of this notice. You must provide a reason supporting your request for amendment.
We may deny your request if it is not in writing or if it does not include a reason to support it or if you ask us to amend information that:
- Is not a part of your health information kept by or for our health center(s).
- Is not part of your information that is permitted to be inspected and copied by you.
- Is accurate and complete.
Right to Receive Accounting of Disclosures
You have the right to receive an accounting of the disclosures of your health information made by us. You must submit a request in writing for this purpose to our privacy official identified on the first page of this notice. Your request must state a time period not more than six years, prior to the date of request, and should not include dates before April 14, 2003. The first list you request within a 12-month period will be free. We may charge you for the cost of providing any additional lists.
We will mail you list of disclosures in paper within 30 days of your request. If we are unable to supply the list we will notify you what date we can supply the list within 60 days from the date of your request.
Right to Receive Confidential Communications
Michigan Orthopedic Services permits you to request and shall accommodate reasonable requests by individuals to receive communications of protected health information by alternative means or at alternative locations.
For example you may ask us to contact you at your personal mobile phone or by mail at a specific PO Box. You must submit a request in writing for this purpose to our privacy official identified on the first page of this notice.
Changes to This Notice
We have the right to change the contents of this notice and make the changed notice effective for all your health information we already maintain or which we will receive in the future. We will communicate the changes in the notice and specify the notice effective date on the last page of this notice. We will provide you with the most current notice at your request.
Complaints
You may file a complaint regarding privacy of your health information, with us or with the Secretary of Department of Health and Human Services (DHHS) (please visit OCR web site on how to file a complaint with the secretary (www.hhs.gov/ocr/hipaa/)), in writing within 180 days of the occurrence of the act or omission. You will not be discriminated against for the exercise of your right to file a complaint with the secretary of DHHS.
You may mail a written description, list of person(s) involved and the circumstances to file a complaint. Please include your contact information along with the complaint.
Pete Seilo
Privacy Officer, Michigan Orthopedic Services
13450 Farmington Rd.
Livonia, MI 48150
Telephone: (734) 513-8205
Fax: (734) 513-8219
Hours of Operation: Monday through Friday, 8:30 a.m. - 5:00 p.m.
Toll Free: (800) 592-2929
E-mail: pseilo@michortho.com
According to Federal law, your health information may be released to appropriate health oversight agency, public health authority or attorney if a workforce member or business associate believes that we have engaged in unlawful conduct or have violated professional or clinical standards and are potentially endangering patients, workers or the public.
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