Privacy Practices

Notice of Patient 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.
Holy Spirit Health System (HSHS) is required by law to maintain the privacy of your health information and to provide you with notice of its legal duties and privacy practices with respect to your health information. If you have questions about any part of this notice or if you want more information about the privacy practices at Holy Spirit please contact our Privacy Officer:

Holy Spirit Health System Privacy Officer
503 North 21st Street

Camp Hill, PA
717-763-2100

Holy Spirit Health System includes the following companies: Holy Spirit Hospital of the Sisters of Christian Charity, Holy Spirit Ventures, Inc., Professional Pharmacy, Inc., Spirit Physician Services, Inc., and West Shore Advanced Life Support Services, Inc.
This notice describes Holy Spirit Health System's practices and that of:

• The Medical Staff of the Hospital and any other health care professionals authorized to enter information into your record.

• All departments and units of Holy Spirit Health System.

• All employees, staff, trainees, students, volunteers and contractors.

• All of Holy Spirit Health System's entities, sites and locations follow the terms of this notice. In addition, these entities, sites and locations may share medical information with each other for treatment, payment, or health operations purposes described in this notice.

Effective Date of This Notice: April 14, 2003

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I. How Holy Spirit Health System May Use or Disclose Your Health Information

Each time you visit a hospital, physician, or other healthcare provider, a record of your visit is made. Typically, this record may contain your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. This information, often referred to as your health or medical record, serves as a:

• Basis for planning your care and treatment

• Means of communication among the many health professionals who contribute to your care

• Legal document describing the care you received

• Means by which you or a third-party payer can verify that services billed were actually provided

• A tool in educating health professionals

• A source of data for medical research

• A source of information for public health officials charged with improving the health of the nation

• A source of data for facility planning and marketing

• A tool with which we can assess and continually work to improve the care we render and the outcomes we achieve

*This list includes the most likely uses of personal health information:

Understanding what is in your record and how your health information is used helps you to: ensure its accuracy, better understand who, what, when, where, and why others may access your health information, and make more informed decisions when authorizing disclosure to others. The medical record is the property of Holy Spirit Health System but the information in the medical record belongs to you. Holy Spirit Health System protects the privacy of your health information.

The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

• For Treatment. We may use medical information about you to provide you with medical treatment or services. We may disclose medical information about you to doctors, nurses, technicians, medical students, or other personnel who are involved in taking care of you in our facilities. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so we can arrange for appropriate meals. Different departments may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We also may disclose medical information about you to people outside Holy Spirit Health System who may be involved in your medical care after you leave our facilities, such as family members, clergy or others we use to provide services that are part of your care.

HSHS is required by law to protect the privacy of your medical information more strictly if the services provided are related to any of the following:

- Drug & alcohol abuse or dependence
- Mental health treatment or services
- HIV related information

• For Payment. We may use and disclose medical information about you so the treatment and services you receive at Holy Spirit Health System may be billed and payment may be collected from you, an insurance company or another third party. For example, we may need to give your health plan information about surgery you received at the hospital so your health plan will pay us or reimburse you for the surgery. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
For Health Care Operations. We may use and disclose medical information about you for health care operations. These uses and disclosures are necessary to run Holy Spirit Health System and to help ensure that our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may disclose information to doctors, nurses, technicians, medical students, and other hospital personnel for review and learning purposes. We may combine the medical information we have with medical information from other hospitals to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.

• Business Associates. We may disclose medical information to "business associates" who provide contracted services such as accounting, legal representation, claims processing, accreditation, and consulting. If we do disclose medical information to a business associate, we will do so subject to a contract that provides that the information will be kept confidential.

Other Disclosures That Are Permitted Without Obtaining Authorization

1. Directory: Unless you notify us that you object, we will use your name, location in the facility, general condition, and religious affiliation for directory purposes. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name.
2. Notification: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.
3. Communication with Family: Under certain circumstances, health professionals, using their best judgment, 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.
4. Fundraising Activities: We may use information about you to contact you in an effort to raise money for Holy Spirit Health System and its operations. We may disclose information to a foundation related to the hospital so the foundation may contact you in raising money for the hospital. We only would release contact information, such as your name, address, phone number and the dates you received treatment or services at the hospital. Any fundraising materials sent to you will describe how you may opt out of receiving any further fundraising communications.
5. Research: We may disclose information to researchers when an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information has approved their research.
6. Funeral Directors/ Coroners: We may disclose health information to funeral directors or coroners consistent with applicable law to carry out their duties.
7. Appointment Notification & Scheduling: We may contact you to schedule appointments, provide appointment reminders and suggest follow-up/additional treatment in our office. Appointment reminders may be provided by postcard.
8. Food and Drug Administration (FDA): We 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.
9. Workers Compensation: We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs established by law.
10. Public Health: As required by law, we may disclose health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability. For example, vaccine reactions are reported to governmental agencies as required by law.
11. Correctional Institution: If a patient is or should become an inmate of a correctional institution, we may disclose to the institution or agents thereof health information necessary for healthcare and the health and safety of other individuals.
12. Law Enforcement: We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena or search warrant. (eg. child protection, etc)
13. Change of Ownership: In the event that Holy Spirit Health System is sold or merged with another organization, your health information/record will become the property of the new owner.
14. Health Oversight: We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
15. Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, a discovery request, or other lawful process by someone else involved in the dispute.

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II. Your Health Information Rights

Although your health record is the physical property of the healthcare practitioner or facility that compiled it, the information belongs to you. You have the right to:

1. Request restrictions on certain uses and disclosures of your health information. Holy Spirit Health System is not required to agree to the restriction that you request.
2. Receive your health information through a reasonable alternative means or at an alternative location.
3. Inspect and receive copies of your health information. Please note that there may be a copying charge applied.
4. Request that Holy Spirit Health System amend your health information that is incorrect or incomplete Holy Spirit Health System is not required to change your health information. If your request is denied, we will provide you with information about the denial and how you can disagree with the denial.
5. You have a right to receive an accounting of disclosures of your health information made by Holy Spirit Health System except that Holy Spirit Health System does not have to account for the disclosures for treatment, payment, health care operations, information provided to you or with your authorization, directory listings and certain government functions.
6. You have a right to a paper copy of this Notice of Privacy Practices.

If you would like to exercise one or more of these rights, please contact the medical records department where you have received services at. All requests must be made in writing.

If you would like to have a more detailed explanation of these rights contact:

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III. Our Responsibilities

• Holy Spirit Health System is required by law to:

Maintain the privacy of your protected health information

Provide you with a notice as to our legal duties and privacy practices with respect to information we collect and maintain about you

Abide by the terms of this notice

Notify you if we are unable to agree to a requested restriction

Accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations

• We will not use or disclose health information without authorization, except as described in this notice. You may revoke an authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose information that you had given permission to use or disclose. We are not able to take back any disclosures that were already made with your permission.

• We will provide health information without authorization when necessary for treatment, payment or healthcare operations

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IV. Changes to this Notice of Privacy Practices

Holy Spirit Health System reserves the right to amend this Notice of Privacy Practices at any time in the future. Until such amendment is made, Holy Spirit Health System is required by law to comply with this Notice.

Revisions to the Notice of Privacy Practices will be made available on the Internet at http://www.hsh.org.

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V. Complaints

Complaints about this Notice of Privacy Practices or how Holy Spirit handles your health information should be directed to:

Guest Relations
503 North 21st Street
Camp Hill, PA 17011
717-763-2298

If you are not satisfied with the manner in which this office handles a complaint, you may submit a formal complaint to:

Office of Civil Rights
U.S. Department of Health and Human Services
26 Federal Plaza - Suite 3313

New York, New York 10278

You may also address your complaint to one of the regional Offices for Civil Rights. A list of these offices can be found online at www.hhs.gov/ocr/regmail.html.

There will be no retaliation for filing a complaint.

Version: NPP v01(3/03)

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