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.
You are receiving health care at a facility that
is part of Munson Healthcare. We at Munson Medical Center are
required by law to maintain the privacy of individually identifiable
patient health information (this information is "protected
health information" and is referred to herein as "PHI").
We are also required to provide patients with a Notice of Privacy
Practices regarding PHI. We are required to post this Notice in
a prominent place within our facility. We will only use or disclose
your PHI as permitted or required by applicable state law. This
Notice applies to your PHI in our possession including the medical
records generated by us.
Munson Medical Center understands that your health
information is highly personal, and we are committed to safeguarding
your privacy. Please read this Notice of Privacy Practices thoroughly.
It describes how Munson Medical Center will use and disclose your
PHI.
This Notice applies to the delivery of health care
by Munson Medical Center and its medical staff in the main hospital,
outpatient departments and clinics. This Notice also applies to
the utilization review and quality assessment activities of Munson
Healthcare and Munson Medical Center as a member of Munson Healthcare.
I. Permitted Use or Disclosure
A. Treatment: Munson Medical Center will
use and disclose your PHI in the provision and coordination of
health care to carry out treatment functions.
Munson Medical Center will disclose all or any portion
of your patient medical record information to your attending physician,
consulting physician(s), nurses, pharmacists, technicians, medical
students, dieticians, spiritual/ethical care providers, and other
health care providers who have a legitimate need for such information
in your care and continued treatment.
Different departments will share medical information
about you in order to coordinate specific services, such as lab
work, x-rays and prescriptions.
Munson Medical Center also will disclose your medical
information to people or entities outside Munson Medical Center
who will be involved in your medical care after you leave Munson
Medical Center, such as other care providers and family who will
provide services that are part of your care.
We will share certain information such as your name,
address, employment, insurance carrier, emergency contact information
and appointment scheduling information in an effort to coordinate
your treatment with us and with other health care providers.
Munson Medical Center will use and disclose your
PHI to inform you of, or recommend possible treatment options
or alternatives that will be of interest to you.
Munson Medical Center will use and disclose PHI
to contact you as a reminder that you have an appointment for
treatment or medical care at Munson Medical Center.
If you are an inmate of a correctional institution
or under the custody of a law enforcement officer, Munson Medical
Center will disclose your PHI to the correctional institution
or law enforcement official.
B. Payment: Munson Medical Center will disclose
PHI about you for the purposes of determining coverage, eligibility,
funding, billing, claims management, medical data processing,
stop loss/reinsurance and reimbursement.
The medical information will be disclosed to an
insurance company, third party payer, third party administrator,
health plan or other health care provider (or their duly authorized
representatives) involved in the payment of your medical bill
and will include copies or excerpts of your medical records which
are necessary for payment of your account. It will also include
sharing the necessary information to obtain pre-approval for payment
for treatment from your health plan.
The medical information may also be released to
independent health care providers who were involved in your treatment
(for example, Emergency Room physicians and Radiologists who are
not employed by Munson Medical Center) or emergency delivery (via
ambulance service) to Munson Medical Center so that they may seek
payment for caring for you.
Munson Medical Center will disclose PHI to collection
agencies and other subcontractors engaged in obtaining payment
for care.
C. Health Care Operations: Munson Medical
Center will use and disclose your PHI during routine health care
operations including quality review, utilization review, medical
review, internal auditing, accreditation, certification, licensing
or credentialing activities of Munson Medical Center, and for
educational purposes.
For instance, we will need to share your demographic
information, diagnosis, treatment plan and health status for population
based activities relating to improving health or reducing health
care costs, protocol development, case management and care coordination,
and contacting health care providers and patients with information
about treatment alternatives, in order for us to operate our business
in an efficient, safe and legal manner.
Munson Medical Center may also use and disclose
your PHI to support the sale, transfer, or other corporate restructuring
of Munson Medical Center's assets.
D. Other Uses and Disclosures: As part of
treatment, payment and health care operations, we may also use
your PHI for the following purposes:
Fundraising Activities: with the exception
of mental health and substance abuse PHI, Munson Medical Center
will use and may also disclose some of your PHI to a related foundation
for certain fund raising activities. For example, Munson Medical
Center will use your demographic information (e.g., name, address
and other contact information, age, gender, and insurance status)
and the dates Munson Medical Center provided service to you. Any
communication sent to you will let you know how you may opt out
of receiving similar communications in the future. Munson Medical
Center may disclose limited PHI to a company contracted to conduct
fundraising for Munson Medical Center. This company will use your
PHI only for the purposes of fundraising for Munson Medical Center.
(If you wish to opt-out, you may do so by contacting the Privacy
Official.)
Medical Research: Munson Medical Center may
disclose your PHI without your Authorization to medical researchers
who request it for approved medical research projects; however,
with very limited exceptions such disclosures must be cleared
through a special approval process before any PHI is disclosed
to the researchers. Researchers will be required to safeguard
the PHI they receive.
Information and Health Promotion Activities:
with the exception of mental health and substance abuse PHI, Munson
Medical Center will use and disclose some of your PHI for certain
health promotion activities. For example, your name and address
will be used to send you newsletters or general communications.
We may send you cards for relevant events such as the birth of
your child. We will also send you information based on your own
health concerns. We may send you this information if we have determined
that a product or service may help you. The communication will
explain how the product or service relates to your well being
and can improve your health.
E. More Stringent State and Federal Laws:
The State law of Michigan is more stringent than HIPAA in several
areas. State law is more stringent when the individual is entitled
to greater access to records than under HIPAA and when under state
law the records are more protected from disclosure than under
HIPAA. Certain federal laws also are more stringent than HIPAA.
Munson Medical Center will continue to abide by these more stringent
state and federal laws. The federal laws include applicable internet
privacy laws, such as the Children's Online Privacy Protection
Act and the federal laws and regulations governing the confidentiality
of health information regarding substance abuse treatment.
In Michigan patients have more rights of access
to behavioral health information under Michigan law than under
HIPAA and the state law defines a minimum necessary standard for
release of mental health information.
Disclosure is permitted with consent and for treatment
without consent but only in an emergency. Minors in Michigan have
more rights to confidentiality and protection of certain information
(reproductive health, behavioral health and substance abuse) than
under HIPAA. State law requires facilities to adopt policies regarding
release of information outside the facility. If the facility policy
requires consent for release, then consent will be required. State
law genetic and HIV testing and disclosure consents remain in
place.
II. Permitted Use or Disclosure with an Opportunity
for You to Agree or Object
A. Family/Friends: Munson Medical Center
will disclose PHI about you to a friend or family member who is
involved in your medical care. We will also give information to
someone who helps you pay for your care. In addition, we will
disclose PHI about you to an agency assisting in a disaster relief
effort so that your family can be notified about your condition,
status and location. You have a right to request that your PHI
not be shared with some or all of your family or friends.
B. Facility Directory: Munson Medical Center
will list certain limited information about you in its Facility
Directory if you are a hospital patient at Munson Medical Center1.
This information will include your name, location in Munson Medical
Center, and your general condition (e.g., fair, stable, critical,
etc.). This directory information will also be disclosed to people
who ask for you by name, including your family members, friends,
or other visitors. You have the right to request that your name
not be included in Facility Directory. If you request to opt out
of Munson Medical Center Directory, we cannot inform visitors
of your presence, location, or general condition.
C. Spiritual Care: A spiritual care provider
may be called in to consult regarding your care1. With your permission,
Directory information including your name, location in Munson
Medical Center, general condition, and religious affiliation will
be given to a member of the community clergy from your denomination,
such as a priest or rabbi, even if they don't ask for you by name.
You have a right to request that your name not be given to any
community member of the clergy.
D. Promotional Communications: Munson Medical
Center does not share or sell your PHI to companies that market
health care products or services directly to consumers for use
by those companies to contact you, such as drug companies. Munson
Medical Center does maintain a database of individuals for promotional
communications, disease management, health promotion, and fundraising
purposes1. This database includes
individuals to whom we may have sent health improvement materials
and news about Munson Medical Center previously and also individuals
who have donated to Munson Medical Center or who have expressed
an interest in donating to Munson Medical Center or other health-related
activities. You may be included in this database. Munson Medical
Center sends information to the individuals in this database about
the programs and services of Munson Medical Center. If you wish
to be deleted from this database, you may notify the Privacy Official.
E. Media Conditions Reports: Munson Medical
Center may release information for an update to the media if the
media requests information about you using your full name and
after we have given you an opportunity to agree or object. The
following information may then be disclosed: your condition described
in general terms that do not communicate specific medical information,
such as "good", "fair", "serious",
or "critical".
III. Use or Disclosure Requiring Your Authorization
A. Marketing: Munson Medical Center is not
permitted to provide your PHI to any other person or company for
marketing to you of any products or services other than Munson
Medical Center's products or services unless you have signed an
authorization.
B. Research: Munson Medical Center will use
or disclose your PHI as part of research that includes providing
you with treatment. For example, if you are part of a research
study that includes treatment, we may require that you sign an
authorization to allow the researchers to use or disclose your
PHI for this research.
C. Other Uses: Any uses or disclosures that
are not for treatment, payment or operations and that are not
permitted or required for public policy purposes or by law will
be made only with your written authorization. Written authorizations
will let you know why we are using your PHI. You have the right
to revoke an authorization at any time, except to the extent that
Munson Medical Center has taken action in reliance on the authorization.
IV. Use or Disclosure Permitted by Public Policy
or Law without your Authorization
A. Law Enforcement Purposes: Munson Medical
Center will disclose your PHI for law enforcement purposes as
required by law, such as responding to a court order or subpoena,
identifying a criminal suspect or a missing person, or providing
information about a crime victim or possible criminal conduct
as part of a criminal investigation1.
Required by Law: Munson Medical Center will
disclose PHI about you when required by federal, state or local
law to make reports or other disclosures1.
Munson Medical Center also will make disclosures for judicial
and administrative proceedings such as lawsuits or other disputes
in response to a court order or subpoena. Munson Medical Center
will disclose your medical information to government agencies
concerning victims of abuse, neglect or domestic violence. Munson
Medical Center will report drug diversion and information related
to fraudulent prescription activity to law enforcement and regulatory
agencies. Specialized government functions will warrant the use
and disclosure of PHI. These government functions will include
military and veteran's activities, national security and intelligence
activities, and protective services for the President and others.
Munson Medical Center will make certain disclosures that are required
in order to comply with workers' compensation or similar programs.
B. Coroners, Medical Examiners, Funeral Directors:
Munson Medical Center will disclose your PHI to a coroner or medical
examiner. For example, this will be necessary to identify a deceased
person or to determine a cause of death. We will also disclose
your medical information to funeral directors as necessary to
carry out their duties.
C. Organ Procurement: Munson Medical Center
will disclose PHI to an organ procurement organization or entity
for organ, eye or tissue donation purposes when donation has been
authorized or to verify that appropriate organ procurement procedures
were followed.
D. Health or Safety: Following the requirements
of the Michigan Department of Commerce, Munson Medical Center
will use and disclose PHI to avert a serious threat to health
and safety of a person or the public1. Munson Medical Center will
use and disclose PHI to Public Health Agencies for immunizations,
communicable diseases, etc. Munson Medical Center will use and
disclose PHI for activities related to the quality, safety or
effectiveness of FDA-regulated products or activities, including
collecting and reporting adverse events, tracking and facilitating
product recalls, etc. and post marketing surveillance. Any patient
receiving a medical device subject to FDA tracking requirements
may refuse to disclose, or refuse permission to disclose, their
name, address, telephone number and social security number, or
other identifying information for the purpose of tracking.
V. Your Health Information Rights
Although we at Munson Medical Center must maintain
all records concerning your hospitalization and treatment by Munson
Medical Center, you have the following rights concerning your
PHI:
A. Right to Inspect and Copy: You have the
right to access your PHI and to inspect and have a copy made of
your PHI as long as we maintain it except for: psychotherapy notes,
information that may be used in anticipation of, or that will
be used in a civil, criminal or administrative action or proceeding,
and where prohibited or protected by law.
Munson Medical Center will deny your request for
access to your PHI without giving you an opportunity to review
that decision if:
You don't have the right to inspect the information;
or it is otherwise prohibited or protected by law;
You are an inmate at a correctional institution
and obtaining a copy of the information would risk the health,
safety, security, custody or rehabilitation of you or other
inmates;
The disclosure of the information would threaten
the safety of any officer, employee or other person at the correctional
institution or who is responsible for transporting you;
You are involved in a clinical research project
and Munson Medical Center created or obtained the PHI during
that research. Your access to the information will be temporarily
suspended for as long as the research is in progress;
Munson Medical Center obtained the information
that you seek access to from someone other than the health care
provider under a promise of confidentiality and your access
request is likely to reveal the source of the information; or
Under other limited circumstances. In these instances,
however, Munson Medical Center will allow the review of its
decision by a health care professional that Munson Medical Center
has chosen. This person will not have been involved in the original
decision to deny your request.
You agree to pay a reasonable copying charge. You
must make your requests to access and copy your PHI in writing
to Munson Medical Center. We will respond to your request within
30 days of its receipt. If we cannot, we will notify you in writing
to explain the delay and the date by which we will act on your
request. In any event, we will act on your request within 60 days
of its receipt.
B. Right to Amend: You have the right to
amend your PHI for as long as Munson Medical Center maintains
it. However, we will deny your request for amendment if:
Munson Medical Center did not create the information;
The information is not part of the designated
record set;
The information would not be available for your
inspection (due to its condition or nature); or
The information is accurate and complete.
If Munson Medical Center denies your request for
changes in your PHI, we will notify you in writing with the reason
for the denial. We will also inform you of your right to submit
a written statement disagreeing with the denial. You may ask that
we include your request for amendment and the denial any time
that Munson Medical Center discloses the information that you
wanted changed. Munson Medical Center may prepare a rebuttal to
your statement of disagreement and will provide you with a copy
of that rebuttal.
You must make your request for amendment of your
PHI in writing to Munson Medical Center, including your reason
to support the requested amendment. We will respond to your request
within 60 days of its receipt. If we cannot, we will notify you
in writing to explain the delay and the date by which we will
act on your request. In any event, we will act on your request
within 90 days of its receipt.
C. Right to an Accounting: You have a right
to receive an accounting of the disclosures of your PHI that Munson
Medical Center made, except for the following disclosures:
To carry out treatment, payment or health care
operations;
To you;
To persons involved in your care;
For national security or intelligence purposes;
To correctional institutions or law enforcement
officials in custodial situations; or
That occurred prior to April 14, 2003.
For each disclosure, you will receive: the date
of the disclosure, the name of the receiving organization and
address if known, a brief description of the PHI disclosed and
a brief statement of the purpose of the disclosure or a copy of
the written request for the information, if there was one.
You must make your request for an accounting of
disclosures of your PHI in writing to Munson Medical Center. You
must include the time period of the accounting, which may not
be longer than 6 years. We will respond to your request within
60 days from its receipt. If we cannot, we will notify you in
writing to explain the delay and the date by which we will act
on your request. In any event, we will act on your request within
90 days of its receipt.
In any given 12-month period, Munson Medical Center
will provide you with an accounting of the disclosures of your
PHI at no charge. Any additional requests for an accounting within
that time period will be subject to a reasonable fee for preparing
the accounting.
D. Right to Request Restrictions: You have
the right to request restrictions on certain uses and disclosures
of your PHI:
To carry out treatment, payment or health care
operations functions;
Restricting specific information to only specified
family members, relatives, close personal friends or other individuals
involved in your care; or
Limited information in the facility directory.
For example, you may ask that your name not be used
in the waiting room or that information about your expected discharge
date not be shared with your family. We will consider your request
but are not required to agree to the requested restrictions.
E. Right to Confidential Communications:
You have the right to receive confidential communications of your
PHI by alternative means or at alternative locations. For example,
you may request that we only contact you at work or by mail. We
will make every attempt to honor your request, but we reserve
the right to deny unreasonable requests.
F. Right to Opt Out of the Facility Directory:
You have the right to ask that your name not be included in the
Facility Directory. If you request to opt out of the Facility
Directory, Munson Medical Center cannot inform visitors and callers
of your presence, location, or general condition.
G. Right to Receive a Copy of this Notice:
You have the right to receive a paper copy of this Notice of Privacy
Practices, upon request.
VI. Complaints
If you believe your privacy rights have been violated,
you may file a complaint with Munson Medical Center or with the
Secretary of the Department of Health and Human Services. To file
a complaint with Munson Medical Center, please contact Munson
Medical Center's Patient Liaison, at:
1105 6th Street
Traverse City, MI 49684 (231) 935-5051
All complaints must be submitted in writing directly
to Munson Medical Center's Patient Liaison. Munson Medical Center
assures you that there will be no retaliation for filing a complaint.
VII. Sharing and joint use of your Health Information
In the course of providing care to you and in furtherance
of Munson Medical Center's mission to improve the health of the
community, Munson Medical Center will share your PHI with other
organizations as described below who have agreed to abide by the
terms described below:
A. Medical Staff: The medical staff and Munson
Medical Center participate together in an organized health care
arrangement to deliver health care to you. Munson Medical Center
and its medical staff have agreed to abide by the terms of this
Notice with respect to PHI created or received as part of delivery
of health care services to you in Munson Medical Center. Physicians
and allied health care providers are members of Munson Medical
Center's medical staff and will have access to and use your PHI
for treatment, payment and health care operations purposes related
to your care within Munson Medical Center. Munson Medical Center
will disclose your PHI to the medical staff for payment, treatment
and health care operations.
B. Business Associates: Munson Medical Center
will use and disclose your PHI to business associates contracted
to perform business functions on its behalf including Munson Healthcare,
who performs certain business functions for Munson Medical Center.
Whenever an arrangement between Munson Medical Center and another
company involves the use or disclosure of your PHI, that business
associate will be required to keep your information confidential.
C. Membership in Munson Healthcare: Munson
Medical Center, members of Munson Healthcare and Munson Healthcare
participate together in an organized health care arrangement for
utilization review and quality assessment activities. We have
agreed to abide by the terms of this Notice with respect to PHI
created or received as part of utilization review and quality
assessment activities of Munson Healthcare and its members. Members
of Munson Healthcare will abide by the terms of their own Notice
of Privacy Practices in using your PHI for treatment, payment
or healthcare operations. As a part of Munson Healthcare, Munson
Medical Center and other hospitals, nursing homes, and health
care providers in Munson Healthcare share your PHI for utilization
review and quality assessment activities of Munson Healthcare,
the parent company, and its members. Members of Munson Healthcare
also use your PHI for your treatment, payment to Munson Medical
Center and/or for the health care operations permitted by HIPAA
with respect to our mutual patients.
VIII. Additional Information
For further information regarding the subjects covered
in this Notice of Privacy Practices, please contact Munson Healthcare's
Privacy Official at (231) 935-2335.
IX. Changes to this Notice
Munson Medical Center will abide by the terms of
the Notice currently in effect. Munson Medical Center reserves
the right to change the terms of its Notice and to make the new
Notice provisions effective for all PHI that it maintains. Munson
Medical Center will provide you with the revised Notice at your
first visit following the revision of the Notice.
1 State law further
protects the privacy rights of individuals seeking mental health
or substance abuse related care.
If you are a Munson Healthcare patient and have a compliment,
concern, or complaint, please contact one of our Patient
Liaisons.
