KAPLAN CENTER FOR INTEGRATIVE MEDICINE
NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN ACCESS THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
During your first appointment at the Kaplan Center for Integrative Medicine a medical record was created that contains critical information such as your name, address, age, insurance coverage and medical condition. As you are aware, this record is updated each time you visit or contact the Kaplan Center for Integrative Medicine. Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), this information is referred to as your Individual Identifiable Health Information (IIHI) or Protected Health Information (PHI).
The terms of this Notice of Privacy Practices (Notice) apply to all records containing your PHI that are created or retained by the Kaplan Center for Integrative Medicine. We reserve the right to revise or amend this Notice of Privacy Practices (such as, if the Privacy Officer changes or there is a change in the law). Any revision or amendment to this Notice will be effective for all of your records that our practice has created or maintained in the past and for any of your records that we may create in the future. The Kaplan Center for Integrative Medicine will post a copy of the current Notice in our offices in a visible location at all times, and you may request a copy of our most current Notice at any time.
THE KAPLAN CENTER FOR INTEGRATIVE MEDICINE’S OBLIGATIONS:
We are required by law to:
- Maintain the privacy of Protected Health Information (PHI),
- Give you this notice of our legal duties and privacy practices regarding health information about you, and
- Follow the terms of our notice that are currently in effect.
HOW THE KAPLAN CENTER FOR INTEGRATIVE MEDICINE MAY USE AND DISCLOSE HEALTH INFORMATION:
We may use and disclose your Protected Health Information (PHI) without your authorization under the following circumstances:
- Treatment: The Kaplan Center for Integrative Medicine may use your PHI to treat you. For example, we might use your PHI to contact a pharmacy when we order a prescription for you. We may disclose your PHI to others who assist in your care, such as a consulting physician.
- Payment: The Kaplan Center for Integrative Medicine may use and disclose your PHI to bill and collect payment for the services and items you receive from us. For example, we may contact your health insurance company to preauthorize treatment or to obtain payment. We may use your
PHI to bill you directly for services rendered, and in the event of non-payment, we may forward selective information (such as your name, address, phone number, and amount due) to other entities to assist us with billing and collections.
- Healthcare Operations: The Kaplan Center for Integrative Medicine may use and disclose your PHI to operate our business. For example, we may use your IIHI to evaluate the quality of care you receive from us.
- In Response to a Public Health Risk: The Kaplan Center for Integrative Medicine may disclose your PHI to public health agencies that are authorized by law to collect it. For example, personal health information may be disclosed for the purpose of maintaining vital records (such as a birth or death); reporting child abuse or neglect; preventing or controlling disease, injury, or disability; notifying a person regarding a potential exposure to a communicable disease; notifying a person regarding a potential risk for spreading or contracting a disease or condition; reporting reactions to drugs or problems with products or devices; notifying individuals if a product or device they may be using has been recalled; and notifying appropriate government agencies and authorities regarding potential abuse or neglect of an adult (including domestic violence). Please note that we will report potential domestic violence or the neglect of an adult only when the patient agrees or when we are legally mandated to disclose the information.
- Health Oversight Activities: The Kaplan Center for Integrative Medicine may disclose your PHI to a health oversight agency for activities required or authorized by law (such as activities necessary to monitor government programs, for example: a Medicare audit).
- Lawsuits and Similar Proceedings: The Kaplan Center for Integrative Medicine may disclose your PHI in response to a Court or Administrative Order. For example, if you are involved in a lawsuit or similar proceeding. We also may disclose your PHI in response to a subpoena or other lawful process initiated by a party involved in the dispute, but only when the request is accompanied by a signed release from you.
- Workers’ Compensation: The Kaplan Center for Integrative Medicine may disclose your PHI for workers’ compensation and similar programs.
- Law Enforcement: The Kaplan Center for Integrative Medicine may release PHI if asked to do so by a law enforcement official.
- Military: The Kaplan Center for Integrative Medicine may disclose your PHI if you are a member of the United States military forces and, the request is made by the proper authorities.
- National Security: The Kaplan Center for Integrative Medicine may disclose your PHI to federal officials to cooperate with intelligence and national security
activities authorized by law.
- Data Breach Notification Purposes: The Kaplan Center for Integrative Medicine may use or disclose your PHI to provide legally required notices of unauthorized access to or disclosure of your health information.
USES AND DISCLOSURES THAT REQUIRE US TO GIVE YOU AN OPPORTUNITY TO OBJECT AND OPT
- Individuals Involved in Your Care or Payment for Your Care: Unless you object, the Kaplan Center for Integrative Medicine may disclose to a member of your family, a relative, a close friend or any other person you identify, your PHI that directly relates to that person’s involvement in your health care. If you are unable to agree or object to such a disclosure, we may disclose such information as necessary if we determine that it is in your best interest based on our professional judgment.
- Disaster Relief: The Kaplan Center for Integrative Medicine may disclose your Protected Health Information to disaster-relief organizations that seek your Protected Health Information to coordinate your care or notify family and friends of your location or condition in a disaster. We will provide you with an opportunity to agree or object to such a disclosure whenever we practically can do so.
YOUR WRITTEN AUTHORIZATION IS REQUIRED FOR OTHER USES AND DISCLOSURES
The following uses and disclosures of your PHI will be made only with your written authorization:
- Uses and disclosures of PHI for marketing purposes,
- Disclosures that constitute a sale of your PHI; and
- Uses and disclosures of psychotherapy notes about you.
Other uses and disclosures of PHI not covered by this Notice or the laws that apply to us will be made only with your written authorization. If you do give us an authorization, you may revoke it at any time by submitting a written revocation to our Privacy Officer, and we will no longer disclose PHI
under the authorization. But disclosure that we made in reliance on your authorization before you revoked it will not be affected by the revocation.
You have the following rights regarding your PHI maintained by the Kaplan Center for Integrative Medicine:
- Confidential Communications: You have the right to request that the Kaplan Center for Integrative Medicine communicate with you about your health and health-related issues in a particular way to protect your privacy. To do so, you must send your request in writing to: Office Manager/ Privacy Officer at the Kaplan Center for Integrative Medicine. Your letter must specify the method of confidential communication/contact you want the Kaplan Center for Integrative Medicine to employ. We will accommodate reasonable requests.
- Requesting Restrictions: You have a right to request a restriction in the Kaplan Center for Integrative Medicine’s use or disclosure of your PHI; however, the Kaplan Center for Integrative Medicine is not required to accommodate your request. (For example, there may be circumstances where the Kaplan Center for Integrative Medicine is legally required to disclose medical records, such as when responding to a Court Order or during a public health emergency). To request that the Kaplan Center for Integrative Medicine restrict its use of your PHI, you must write to: Office Manager/ Privacy Officer at the Kaplan Center for Integrative Medicine. Your request must include both the information you want restricted and a list of the persons/entities to whom the restrictions should apply.
- Inspection and Copies: You have the right to inspect and obtain a copy of your PHI (excluding psychotherapy notes). To do so, you must submit a request in writing to Office Manager/Privacy Officer at the Kaplan Center for Integrative Medicine. The Kaplan Center for Integrative Medicine has up to 30 days to make your PHI available to you and may charge a fee to cover the costs associated with your request, such as supplies, copying, postage and labor. The Kaplan Center for Integrative Medicine may not charge you a fee if you need the information for a claim for benefits under the Social Security Act or any other state of federal needs-based benefit program. The Kaplan Center for Integrative Medicine may deny your request in certain limited circumstances. If we do deny your request, you have the right to have the denial reviewed by a licensed healthcare professional who was not directly involved in the denial of your request, and we will comply with the outcome of the review.
- Right to an Electronic Copy of Electronic Medical Records: If your PHI is maintained in an electronic format (known as an electronic medical record or an electronic health record), you have the right to request that an electronic copy of your record be given to you or transmitted to another individual or entity. We will make every effort to provide access to your PHI in the form or format you request, if it is readily producible in such form or format. If the PHI is not readily producible in the form or format you request your record will be provided in either our standard electronic format, or if you do not want this form or format, a readable hard copy form. The Kaplan Center for Integrative Medicine may charge you a reasonable, cost-based fee for the labor associated with transmitting the electronic medical record.
- Right to Get Notice of a Breach: You have the right to be notified upon a breach of any of your unsecured PHI.
- Amendment: You may ask us to amend your PHI if you believe it is incorrect or incomplete. You can obtain a “Request for Correction/Amendment of Protected Health Information” form at the Kaplan Center for Integrative Medicine or by calling or writing to us. The form requires you to provide reasons supporting your request for amendment/correction. The completed form should be sent to the attention of Office Manager/Privacy Officer, at the Kaplan Center for Integrative Medicine. It is the responsibility of the Kaplan Center for Integrative Medicine to review, and either approve or deny your request to amend your PHI. When a request for amendment is denied, the Kaplan Center for Integrative Medicine will provide an explanation in writing.
- Accounting for Disclosure: All of our patients have the right to request an accounting of disclosures. An “accounting of disclosures” is a list of certain non-routine disclosures the Kaplan Center for Integrative Medicine has made of your PHI for non-treatment, non-payment or non-operations purposes. Use of your PHI as part of the routine patient care in our practice is not required to be documented. In order to obtain an accounting of non-routine disclosures, you must submit your request in writing to Office Manager/Privacy Officer at the Kaplan Center for Integrative Medicine.
- Paper Copy of this Notice: You are entitled to receive a paper copy of the Kaplan Center for Integrative Medicine’s Notice of Privacy Practices. You may ask for a copy of this notice at any time. To obtain a paper copy of this notice, contact our HIPAA Coordinator.
- Out-of-Pocket-Payments: If you paid out-of-pocket (or in other words, you have requested that we not bill your health plan) in full for a specific item or service, you have the right to ask that your PHI with respect to that item or service not be disclosed to a health plan for purposes of payment or health care operations, and the Kaplan Center for Integrative Medicine will honor that request.
Filing a Complaint: If you believe your privacy rights have been violated, you may file a complaint with the Kaplan Center for Integrative Medicine or with the United States Secretary of the Department of Health and Human Services. To file a complaint with our office, contact the Office Manager/HIPAA Coordinator at
the Kaplan Center for Integrative Medicine. To file a complaint with the United States Secretary of Health and Human Services, you may write to: Barbara Holland, Regional Manager, Office for Civil Rights, U.S. Department of Health and Human Services, 150 S. Independence Mall West, Suite 372, Public Ledger Building, Philadelphia, PA 19106-9111. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
If you have questions about this Notice, please contact: Privacy Officer/ HIPAA Coordinator:
Title: Office Manager/Privacy Officer
Address: Kaplan Center for Integrative Medicine, 6829 Elm Street, Suite #300, McLean, VA 22101.
Telephone No.: 703-532-4892
MAINTENANCE OF RECORDS
We are happy to maintain your records while you are an active patient or to transfer your records to another practitioner or health care provider should you wish to seek care elsewhere. We consider patients inactive if they either ask to have their records transferred or they have not been seen in our office for six years. Our policy is to destroy inactive medical records in accordance with the Department of Health Professions regulations below.
Regulations of the Board (18VAC85-20-26) state that practitioners must maintain a patient record for a minimum of six years following the last patient encounter with the following exceptions:
- Records of a minor child, including immunizations, must be maintained until the child reaches the age of 18 or becomes emancipated, with a minimum time for record retention of six years from the last patient encounter regardless of the age of the child;
- Records that have previously been transferred to another practitioner or health care provider or provided to the patient or his personal representative; or
- Records that are required by contractual obligation or federal law to be maintained for a longer period of time.
After October 19, 2005, practitioners must post information or in some manner inform all patients concerning the time frame for record retention and destruction. Patient records can only be destroyed in a manner that protects patient confidentiality, such as by incineration or shredding. For more information from the Virginia Department of Health Professions, go to //www.dhp.virginia.gov/medicine/guidelines/85-5.doc.