Privacy Policy

NOTICE OF PRIVACY PRACTICES

Effective Date: July 7, 2003

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.

If you have any questions about this notice or for further information regarding this notice, please contact Compass Health Care, Inc.'s Privacy Officer at 520-628-3373. All requests to the CHCPO must be submitted to the following address:

Compass Health Care, Inc.
Privacy Officer
2475 N. Jackrabbit Ave.
Tucson, AZ 85745

WHO WILL FOLLOW THIS NOTICE:

This notice describes Compass Health Care, Inc.’s practices and that of:

• any health care professional authorized to enter information into your client chart
• all departments and facilities of Compass Health Care, Inc.
• any volunteer, student or intern we allow to help you while you are a client in our facilities
• all employees, staff and other Compass Health Care, Inc. personnel
  

In addition, these entities, sites and locations may share medical information with each other for treatment, payment or Compass operations purposes described in this notice.

OUR PLEDGE REGARDING PROTECTED INFORMATION:

We understand that information about you and your health is personal. We are committed to protecting this information about you. We create a record of the care and services you receive at Compass Health Care, Inc. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all records of your care generated and/or held by Compass Health Care, Inc. whether made by Compass Health Care Inc. personnel or another care provider.

This notice will tell you about the ways in which we may use and disclose protected information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of protected information.

We are required by law to:

• make sure that protected information that identifies you is kept private;
• give you this notice of our legal duties and privacy practices with respect to protected information about you; and
• follow the terms of the notice that is currently in effect

HOW WE MAY USE AND DISCLOSE PROTECTED INFORMATION ABOUT YOU:

The following categories describe different ways that we use and disclose protected 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 protected information about you to provide you with medical treatment or services. We may disclose protected information about you to doctors, nurses, client care specialists, case managers, counselors or other Compass Health Care, Inc. personnel who are involved in taking care of you while a client of Compass Health Care, Inc. For example, a doctor treating you in the detoxification program will need to know if you have diabetes because diabetes is something that needs to be monitored while you are in that program. In addition, the doctor may need to tell the kitchen staff if you have diabetes so that we can arrange for appropriate meals. Different departments of Compass Health Care, Inc. also may share protected information about you in order to coordinate the different things you may need, such as medications, case management, counseling, etc.

For Payment: We may use and disclose protected information about you so that the treatment and services you receive at Compass Health Care, Inc. may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan protected information for the services you received at Compass Health Care, Inc. so your health plan will pay us or reimburse you for the services you paid for up front. We may also tell your health plan or network about treatment services you are going to receive in order to obtain prior authorization or to determine whether your plan will cover the treatment.

For Compass Health Care Inc. Healthcare Operations: We may use and disclose protected information about you for Compass Health Care, Inc. healthcare operations. These uses and disclosures are necessary to run the organization and make sure that all of our clients receive quality care. For example, we may use protected information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine protected information about many Compass clients to decide what additional services Compass should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, client care specialists, case managers, counselors and other Compass personnel for review and learning purposes. We may also combine the protected information Compass collects with medical information we have from other organizations 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 information so others may use it to study health care and health care delivery without learning who the specific clients are.

Appointment Reminders: We may use and disclose protected information to contact you as a reminder that you have an appointment for treatment or care at Compass Health Care, Inc.

Treatment Alternatives and Follow-up Information: We may use and disclose protected information to tell you about or recommend possible treatment options, alternatives that may be of interest to you, to follow-up with you to determine the effectiveness of the treatment you received or to determine additional services that may be of interest to you.

Facility Census: We may include certain limited information about you on a facility census while you are a client at that facility. This information may include your name, location in the facility, admission date, network provider or health plan. However, the information included on the facility census is for internal use only and will not be disclosed to anyone outside Compass Health Care, Inc. without your prior written authorization to do so.

Research: All research projects are subject to a special approval process. This process evaluates a proposed research project and its use of medical and treatment information, trying to balance the research needs with clients’ need for privacy of their medical and treatment information. Before we use or disclose any protected information for research, the project will have been approved through this research approval process and your prior written authorization will have been obtained.

As Required By Law: We will disclose protected information about you when required to do so by federal, state or local law. Any disclosure in this category will be documented in your client chart.

To Avert a Serious Threat to Health or Safety: We may use and disclose protected information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat and will be documented in your client chart.

SPECIAL SITUATIONS

Public Health: We may disclose protected information about you for public health activities. These activities generally include the following:

• to prevent or control disease, injury or disability;
• to report child abuse or neglect;
• to report reactions to medications or problems with products;
• to notify people of recalls of products they may be using;
• to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
• to notify the appropriate government authority if we believe a client has been the victim of abuse, neglect or domestic violence.

We will only make this type of disclosure if you agree or when required or authorized by law.

Any disclosure made will be documented in your client chart.

Health Oversight Activities: We may disclose protected 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 the civil rights laws.

Law Enforcement: We will not release protected information about you if asked to do so by a law enforcement official unless:

• You have authorized in writing the release of this information.
• The disclosure is allowed by a court order.
• A crime was committed by you either at Compass Health Care, Inc. or against any person that works for Compass Health Care, Inc. or you have threatened to commit such a crime. *
• You are suspected of child abuse or neglect. *
• You are suspected of elderly abuse or neglect. *

*Federal laws and regulations do not protect this information from being reported under state law to appropriate state or local authorities.

Coroners, Medical Examiners and Funeral Directors: We may release protected information to a coroner or medical examiner. This may be necessary, for example to identify you in the event of your death or to determine the cause of your death. We may also release protected information about you to funeral directors as necessary to carry out their duties and as allowed by federal regulations. Any disclosure made will be documented in your client chart.

Inmates: If you are an inmate of a correctional institution we will not release any information about you to the correctional institution unless we have obtained your prior written authorization or there is a bona fide medical emergency in which you are unable to speak for yourself.

YOUR RIGHTS REGARDING PROTECTED INFORMATION ABOUT YOU

You have the following rights regarding protected information we maintain about you.

Right to Inspect and Copy: You have the right to inspect and copy protected information that may be used to make decisions about your care. Usually, this includes medical and billing records, but may not necessarily include substance abuse treatment records or psychotherapy notes.

To inspect and copy protected information that may be used to make decisions about you, you must complete a "Request for Personal Chart Review" form and submit it to the CHCPO.

If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.

We may deny your request to inspect and copy protected information in your chart. If you are denied access to protected information, you may request that the denial be reviewed. Another licensed and/or certified employee chosen by Compass Health Care, Inc. will review your request and the denial. The person conducting the review will not be the person who denied your request initially. We will comply with the outcome of the review.

Right to Amend: If you feel that protected information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for Compass Health Care, Inc.

To request an amendment, your request must be made in writing and submitted to the CHCPO.

In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

• Was not created by us
• Is not part of the protected information kept by or for Compass Health Care, Inc
• Is not part of the information which you would be permitted to inspect and copy, such as, substance abuse treatment and psychotherapy notes; or
• Is accurate and complete.
  

Right to Request Restrictions: You have the right to request a restriction or limitation on the protected information we use or disclose about you for treatment, payment or health care operations.

We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.

To request restrictions, you must make your request in writing to the CHCPO.

In your request you must tell us:

• what information you want to limit;
• whether you want to limit our use, disclosure or both; and
• to whom you want the limits to apply.
  

Right to Receive Confidential Communications: You have the right to receive confidential communications and that we communicate with you in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.

To request confidential communications, you must make your request in writing to the CHCPO.

We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to an Accounting of Disclosures: You have the right to receive an "accounting of disclosures". This is a list of the disclosures we made of protected information about you.

To request this list or accounting of disclosures, you must submit your request in writing to the CHCPO.

Your request must state a time period that may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate where the list or accounting of disclosures is to be sent. The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Receive a Copy of this Notice: You may obtain a paper copy of this notice at anytime by contacting Compass Health Care, Inc.'s Privacy Officer at 327-9863.

CHANGES TO THIS NOTICE

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for protected information we already have about you, as well as, any information we receive in the future. We will post a copy of the current notice in each Compass Health Care, Inc. facility. The notice will contain on the first page, in the top right-hand corner, the effective date. In addition, each time you register at or are admitted to any Compass Health Care Inc. facilities, we will offer you a copy of the current notice in effect. At any other point you may request a paper copy of this notice by contacting Compass Health Care, Inc.'s Privacy Officer at 327-9863.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with the Privacy Officer at Compass Health Care Inc. or with the Secretary of the Department of Health and Human Services. All complaints must be submitted in writing.

You will not be penalized for filing a complaint.

OTHER USES OF PROTECTED INFORMATION

Other uses and disclosures of protected information not covered by this notice or the laws that apply to Compass Health Care, Inc. will be made only with your written authorization to do so. If you provide us permission to use or disclose protected information about you, you may revoke that permission, in writing, at any time.

If you revoke your authorization, we will no longer use or disclose protected information about you for the reasons covered by your written authorization.

You understand that we are unable to rescind any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you for seven years as mandated by state law.

Compass Behavioral Health Care | 2475 N. Jackrabbit Ave. Tucson, AZ 85745 | (520) 882-5608 | infochc@compasshc.org