Six County, Inc.
Privacy Notice

Effective April 1, 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 it carefully.

This Privacy Notice has been prepared by Six County, Inc.(SCI) according to the Health Information Portability and Accountability Act of 1996 (HIPAA – Public Law 104-191.) The Privacy Notice tells you how Protected Health Information (PHI) about you can be created, shared, protected and maintained.

What is my Protected Health Information?

• Anything from the past, present or future about your mental or physical health or condition that is spoken, written, or electronically recorded and is;
• Created by or given to anyone providing care to you; a health plan; a public authority; your employer; your insurance company; your school or university; or anyone who processes health information about you.

What Rights Do I Have About My Protected Health Information?

• You have the right to consent to the use and disclosure of your PHI for the limited purpose of diagnoses, payment and administrative operations for your treatment.
• You have the right to authorize the sharing of your PHI for other purposes such as disability claims or forwarding to other treatment providers.
• You have the right to see and request a copy of your PHI for a nominal fee per SCI’s policy. An exception to this would be court-ordered evaluations or if your access is restricted for clear and documented treatment reasons.
• The specific PHI documented in the chart belongs to you but the clinical record itself is the sole property of SCI.
• You have the right to make a written request that SCI amend or correct your PHI. However, SCI is not required to agree with your amendments.
• You have the right to request restrictions on how SCI uses and discloses your PHI. SCI is not, however, required to agree with your requested restrictions.
• You have the right to receive an accounting of disclosures of your PHI made by SCI, including disclosures by or to a Business Associate, for purposes other than treatment, payment, and health care operations, subject to certain exceptions. This accounting obligation begins April 14, 2003 and applies prospectively.
• You have the right to request confidential communications of PHI by alternative means or at alternative locations. SCI is required to accommodate reasonable requests.
• You have the right to have a copy of this Privacy Notice. SCI may change the terms of this Privacy Notice from time to time. You can always get a copy of SCI’s current Privacy Notice by requesting it from your clinical service provider or SCI’s Privacy Officer.

What can be done with my Protected Health Information if I consent to disclose it for diagnosis or to administer and pay for my treatment?

For treatment: With your consent, SCI can share your PHI with other SCI staff as needed so that you can receive the most appropriate treatment. (For example, your counselor could share with your treating psychiatrist/nurse practitioner that you are experiencing an increase in depressive symptoms. The doctor/nurse practitioner could then prescribe a medication to help you feel better.) Your PHI may also be shared with outside entities performing ancillary services related to your treatment such as lab work or ordering prescriptions.

To obtain payment: With your consent, SCI can share information about when and for what purpose you were treated so that SCI can be paid for treating you. (For example, SCI could send any required forms to your insurance company stating when and for what condition you were treated at our office for payment of services. SCI may contact your employer to verify employment status and/or release PHI to the Medicaid program, or the Mental Health & Recovery Services Board if your care is publicly subsidized.

For health care operations: With your consent, SCI may use/disclose your PHI for evaluating the quality of services provided or disclose your PHI to our accountant or attorney for audit purposes. Release of your PHI to the Multi-Agency Community Services Information System (MACSIS) and/or State agencies might also be necessary to determine your eligibility for publicly subsidized services.

Appointment Reminders: Unless you provide us with alternative instructions, we may make telephone calls to confirm appointments, leave messages on answering machines or mail billing statements or similar materials to your home.

Can I revoke my consent to use or disclose PHI for treatment; to obtain payment or for health care operations?

Yes, you can revoke your consent. However, you must do this in writing in order to stop the use and/or disclosure of your PHI. We are permitted to use and/or disclose your PHI based on your consent until we receive your revocation in writing. However, if you revoke your consent, we reserve the right to refuse to provide further services to you, on the basis of your refusal to allow us to share your information for purposes of treatment, payment, and health care operations.

What can be done with my Protected Health Information if I authorize its disclosure for other purposes?

With your specific authorization, SCI can share your PHI for reasons other than treatment, payment, or administrative operations. (For example, you might agree to allow SCI to share your PHI with Jobs and Family Services to obtain benefits.) Note that information used and/or disclosed pursuant to the authorization may be subject to re-disclosure by the recipient, thus SCI cannot be held responsible for the protection of this information.

Can I revoke my authorization for release of Protected Health Information?

 Yes, you can revoke your authorization; however, it must be in writing so that SCI can stop sharing your PHI. We are permitted to share  your PHI based on your authorization until you revoke this consent or the Authorization for Release of Information expires.

Are there any circumstances when my information can be shared without my consent or authorization?

Yes, the minimum necessary of your PHI can be shared without your prior consent or authorization on a “need to know” basis:

1. In a psychiatric emergency if you present with imminent risk of harm to self or others;
2. In a life threatening medical emergency and the purpose of treating is an imminent threat to your health and/or safety;
3. When required by law:
   
   Court order
   
   
• Suspicion/ knowledge that a child (less than 18 years of age) is the victim of neglect, abuse or sexual molestation
• Suspicion/knowledge that an elderly person (usually over the age of 65 years) is the victim of neglect or abuse
• Suspicion/knowledge that a capital crime (murder or treason) is intended or has been committed
• Ohio Legal Rights activities
• Workers Compensation
  
• Coroner/Medical Examiner
  
  
4. When there are substantial communication barriers and it is reasonable to believe that you are giving your consent or authorization.
   
   Exceptions to the minimum necessary requirement include:
   
   
• disclosures to the individual who is the subject of the information
• disclosures made pursuant to an authorization
• disclosures to or requests by healthcare providers for treatment purposes
• disclosures required for compliance with the standardized HIPAA transactions
• disclosures made to Health & Human Services (HHS) pursuant to a privacy investigation
• disclosures otherwise required by HIPAA regulations or other State law

What about other uses of my Protected Health Information?

Other uses and/or disclosures of PHI not covered by this Privacy Notice or the Federal and State laws that apply to SCI will be made only with your written permission.

What will SCI do to protect my Protected Health Information?

SCI will maintain the privacy of your PHI as required by Federal and State law. SCI is providing you with this Privacy Notice which contains our legal responsibilities and privacy practices regarding PHI.

All SCI employees are bound to follow the terms of the Privacy Notice currently in effect as well as SCI’s Corporate Policies & Procedures concerning the use, disclosure ad protection of your PHI. All employees sign a Confidentiality Agreement which requires them to protect your PHI even in the event that they leave our employment.

SCI employees will have access to the minimum necessary PHI on a “need to know” basis in order to perform their job functions as outlined in their job descriptions.

SCI is obligated to monitor information flow to third parties as outlined in Business Associate Agreements or Trading Partner Agreements and will terminate these relationships if SCI becomes aware of intentional violations of the protection of your PHI by others. No disclosure of your PHI will be made without explicit and valid authorization from you other than the aforementioned exceptions outlined in this Privacy Notice.

SCI reserves the right to change the terms of this Privacy Notice. Updated Privacy Notices will be available upon request and posted in all program facilities.

What can I do if I have questions or want to complain about the use and/or disclosure of my Protected Health Information?

All questions and complaints about the use and/or disclosure of your PHI may be sent to:

Privacy Officer/Vice-President of Quality Improvement
740/588-6427
Six County, Inc.’s Administrative Offices
2845 Bell Street, Zanesville, Ohio 43701

You also may file a written complaint with the Secretary of the U. S. Department of Health & Human Services at 200 Independence Avenue SW, Washington D.C., 20201 or call 1-877-696-6775. SCI will take no retaliatory action against you if you make such complaints.