Patient Privacy

St. Clair Health Corporation

1000 Bower Hill Road

Pittsburgh, PA 15243-1899

(412)344-6600

NOTICE OF PRIVACY PRACTICES

Effective Date: April 14, 2003

Revision Date: March 1, 2006

 

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.

 

Contact - If you have any questions about this notice, please contact our Privacy Officer at 1-866-248-4500,

extension 1101 and/or visit our web site at www.stclair.org for any updated information.

 

OUR PLEDGE REGARDING YOUR HEALTH INFORMATION

We understand that information about you and your health is personal. We are committed to protecting the

privacy and security of this information. All St. Clair Health Corporation facilities, entities, sites, and locations

will follow the terms of this notice. A list of such entities, sites and locations as of the revision date of this notice

are set forth below. We reserve the right to modify this list from time to time and a current list of such facilities,

entities, sites and locations (collectively referred to as, “St. Clair”) can be obtained by calling our Privacy Officer

or may be found on our website. Each time you visit a St. Clair facility we create a record of the care and services

you receive. We need this record to provide you with quality care and to comply with certain legal requirements.

This notice applies to all of the records of your care generated by any of the St. Clair facilities. This notice may

also cover physicians who have chosen to be bound by our Notice of Privacy Practices, and independent

contractors who treat you while you are at our facilities. This may include hospital based entities as well as

physicians who have offices outside of our facilities. In addition, all such entities, sites, locations and physicians

may share medical information with each other for treatment, payment, or health care operation purposes described

in this notice. If your physician treats you outside of our facilities, your physician is responsible for providing their

Notice of Privacy Practices to you, if their notice is different. Patients can receive a copy of their physician’s

Notice of Privacy Practices by contacting their office directly. The St. Clair facilities, entities, sites and locations

as of this revision date include: St. Clair Hospital; St. Clair Health Ventures; St. Clair Management Resources; St.

Clair Anesthesia Associates; St. Clair Outpatient Center – Bethel Park; St. Clair Outpatient Center – South Pointe;

St. Clair Outpatient Center – Bridgeville; Goodwill Manor; St. Clair Hospital/UPMC Cancer Centers PET/CT;

South Hills Magnetic Imaging (SHMI), and St. Clair Medical Services, Inc.

 

OUR RESPONSIBILITIES

It is our responsibility to safeguard your personal health information. We are required by state and federal law to

maintain the privacy of your health information. We must also give you this notice of our legal duties and our

privacy practices, and we must follow the terms of the notice that is currently in effect.

 

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 health 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 our facilities, and it will also be posted on our web site at

www.stclair.org. A copy of the current notice in effect will be available at the registration area of each facility.

 

Complaints - If you believe your privacy rights have been violated, you may file a complaint with any of our

facilities. This complaint must be in writing to: St. Clair Hospital 1000 Bower Hill Road, Pittsburgh, PA 15243-

1899, Attn: Privacy Officer. There will be no retaliation for filing a complaint. You also have the right to complain

to the Secretary of the Department of Health and Human Services. More information about how to file a complaint

is available at http://www.hhs.gov/ocr/hipaa/.

.

 

 

 

 

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU

The following categories describe different ways that we use your health information within St. Clair and disclose

your health information to persons and entities outside of St. Clair. Each description is of a category of uses or

disclosures. We have not listed every use or disclosure within the categories, but describe the types of uses and

disclosures that we may make.

 

TREATMENT, PAYMENT, OR HEALTH CARE OPERATIONS:

Except for uses or disclosures that require an authorization (as described below) under federal law or your consent

under state law, St. Clair may use and disclose your health information for treatment, payment, or health care

operations.

 

Treatment - We may use health information about you to provide you with medical treatment and services. We

may disclose health information about you to doctors, nurses, technicians, medical students, interns, or other

personnel who are involved in taking care of you during your visit with us. We may also disclose health information

about you between St. Clair entities and to other health care providers for your medical treatment. For example,

your health information may be provided to a doctor to whom you have been referred to ensure that the doctor has

the necessary information to diagnose or treat you.

 

Payment - We may use and disclose health information about you so the treatment and services you receive at

our health care facilities may be billed to and payment collected from you, an insurance company, or a third party.

This may also include the disclosure of health information to obtain prior authorization for treatment and procedures

from your insurance plan. For example, we may provide your health information to your health plan to obtain

approval for your hospital admission. We may also disclose health information about you to other entities that are

covered by federal privacy regulations or to other health care providers in order to allow such other entities or health

care providers to bill and collect payment for the treatment and services you receive from them. For example, we

may provide your health information to your ambulance service provider in order to allow your ambulance service

provider to obtain payment for your health care services.

 

Health Care Operations - We may use and disclose health information about you for our health care

operations, including, for example, quality assurance (including peer review) activities; granting medical staff

credentials to physicians; administrative activities, including St. Clair’s financial and business planning and

development; and customer service activities, including investigation of complaints, etc. These uses and disclosures

are necessary to operate our health care facility and make sure all of our patients receive quality care. In some cases,

we may also disclose health information about you to other entities that are covered by federal privacy regulations

for their own health care operations so long as: 1) the other entity also has or had a relationship with you; 2) the

health information that is disclosed pertains to such relationship; and 3) the disclosure is for the purpose of certain

health care operations or for health care fraud and abuse detection or compliance. We also may disclose health

information about you to other entities covered by federal privacy regulations that participate in organized health

care arrangements with St. Clair.

 

Business Associates - There are some services provided in our facilities through contracts with business

associates. Examples of business associates include accreditation agencies, management consultants, quality

assurance reviewers, etc. We may disclose your health information to our business associates so that they can

perform the job we’ve asked them to do. To protect your health information, we require our business associates to

sign a contract that states they will appropriately safeguard your information.

 

Appointment Reminders - We may use and disclose health information to contact you as a reminder that you

have an appointment for treatment or medical care at our health care facilities.

 

Alternative Treatments – We may use and disclose health information to inform you about treatment

alternatives and other health related benefits that we believe might be of interest to you.

 

Fundraising – We may contact you as part of a fundraising effort. If you receive a communication from us for

fundraising purposes, you will be told how you can opt out of any further fundraising communications and we will

make reasonable efforts to comply with your request.

 

WITH YOUR VERBAL AGREEMENT

We may use and/or disclose your health information in the following instances. You have the opportunity to agree

or object to the use or disclosure of all or part of your health information. If you are not present or if you are unable

to agree or object to the use and/or disclosure of your health information, then St. Clair may, using professional

judgment, determine whether the disclosure is in your best interest. In this case, only the health information that is

relevant to your health care will be disclosed.

 

Directory Information – St. Clair has a “directory” of information about hospitalized patients available to

anyone who asks for a patient by name. The directory information may include four items: 1) your name; 2) your

location (e.g. room number); 3) your general condition (e.g. serious, fair, good, etc.); and 4) available to

clergypersons only, your religious affiliation. This directory information allows visitors to find your room and

florists to deliver flowers to you. It also allows us to contact you after discharge for certain follow-up reasons. You

have the right to refuse to have all or part of your information disclosed for such purposes. If you do so, we will not

be able to tell your family or friends your room number or that you are in the hospital.

 

Individuals Involved in Your Care or Payment for Your Care - We may disclose health information about

you to a friend, family member, other relative, or any person you identify, information that is relevant to your

medical care or payment for your medical care, unless you tell us in advance not to do so. We may also use or

disclose your health information to notify (or assist in notifying) your family members, personal representatives, or

another person involved in your care, of your condition, status, or location. In addition, we may disclose health

information about you to an entity assisting in a disaster relief effort (such as the Red Cross) so that your family

members, personal representatives, or another person involved in your care can be notified about your condition,

status, or location.

 

WITH YOUR SPECIFIC WRITTEN AUTHORIZATION

Other uses and disclosures of health information not covered by this notice or the laws that apply to us will be made

only with your written permission (called an “authorization”) under federal law or your consent under state law.

You may always refuse to sign an authorization or a consent for these types of uses or disclosures and neither

treatment, payment, enrollment, nor eligibility for benefits will be conditioned upon you providing or refusing to

provide such an authorization or consent. If you authorize us to use or disclose health information about you, you

may revoke that authorization or consent in writing at any time. If you revoke your authorization or consent, we

will no longer use or disclose health information about you for the reasons covered by your written authorization or

consent. You understand that we are unable to take back 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. Some typical

disclosures that require your authorization or consent are as follows:

 

Research – Unless we receive specific approval from an Institutional Review Board (IRB) or Privacy Board, we

may disclose your health information to researchers only after you have signed a specific written authorization. You

do not have to sign the authorization in order to get treatment from St. Clair, but if you do refuse to sign the

authorization, you cannot be part of the research study.

 

Disclosure of Drug & Alcohol Abuse and Dependence - We will disclose drug and alcohol abuse or

dependence information about you only in accordance with your written consent for such disclosures and only to

medical personnel for your diagnosis and treatment or to government or other officials exclusively for the purposes

of obtaining benefits for you. However, in emergency medical situations, we may release drug and alcohol abuse or

dependence information about you without your consent to medical personnel to provide you with medical

treatment.

 

Disclosure of Mental Health Treatment Information - We will disclose mental health treatment information

about you only in accordance with state law. In most cases, state law requires your written consent for disclosures

of information relating to your involuntary treatment for mental illness or your voluntary inpatient treatment for

mental illness. If we are required by federal or state statutes or by an order of a court to release mental health

information after you are discharged, we will make a good faith effort to notify you by mail at your last known

address. If you designate a third party as a payor or copayor of your mental health services, such a designation

includes your implied consent to us to release your medical health information that is necessary to establish your

reimbursement eligibility. We may also release your mental health treatment information without your consent to

certain individuals as permitted by state law, such as: those engaged in providing treatment for you; certain county

administrators; courts, your attorney, or a mental health review officer for certain legal proceedings; or the State

Department of Public Welfare for data collection.

 

Disclosure of HIV-Related Information – We will disclose confidential HIV-related information about you

only in accordance with state law. Generally, state law requires that confidential HIV-related information may only

be released to whom you specify in a written consent or to those person specified by state law who may receive the

information without your consent. Persons or entities that we may disclose your confidential HIV-related

information to without your consent include: health care providers involved in your care; peer review organizations,

accrediting agencies, or other health oversight agencies; your insurer to make payment on your claims; departments

of health for data collection; a person permitted access by a court order; your funeral director; and employees of

certain county agencies and facilities who are responsible for ensuring your health care.

 

Marketing - We may ask you to sign an authorization allowing us to use or disclosure your health information

in order to contact you as part of a marketing effort. As part of our marketing, we may tell you about St. Clair’s

health-related products and services that may be of interest to you. However, we may use or disclose your health

information without your authorization for face-to-face marketing communications or to give you a promotional gift

of nominal value.

 

Disclosures Requested by St. Clair - We may ask you to sign an authorization allowing us to use or to disclose

your health information to others for specific purposes such as notifying you of future educational or social events

that you might enjoy.

 

SPECIAL SITUATIONS THAT DO NOT REQUIRE YOUR AUTHORIZATION, CONSENT OR AN

OPPORTUNITY TO AGREE OR OBJECT

The following disclosures of your health information are permitted by law without any oral or written permission

from you:

 

Department of Health and Human Services – We may disclose health information about you when required to

do so by the Secretary of the Department of Health and Human Services to investigate or determine our compliance

with federal law.

 

Public Health Activities – In accordance with applicable state and federal laws, we may disclose health

information about you for public health activities. These generally include the following:

To prevent or control disease, injury or disability.

To report births and deaths.

To report child abuse or neglect.

To report reactions to medications, problems with products or other adverse events.

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 of possible abuse (including child abuse), neglect or

domestic violence. We will only make this disclosure when required or authorized by law.

 

Health Oversight Activities - We may disclose health information to a health oversight agency for activities

authorized by law. These oversight activities include 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.

 

Lawsuits and Disputes - If you are involved in a lawsuit or a dispute, we may disclose health information about

you in response to a court or administrative order. We may disclose health information about you in response to a

subpoena, discovery request or other lawful process in accordance with applicable law.

 

Law Enforcement – In accordance with applicable law, we may disclose certain health information if asked to

do so by law enforcement officials as example, for the following reasons:

In response to a court order, subpoena, warrant, summons or similar process.

To identify or locate a suspect, fugitive, material witness or missing person.

About the victim of a crime if, under certain circumstances, we are unable to obtain the person’s

agreement.

About a death we believe may be the result of a criminal conduct.

About criminal conduct at our facility.

In emergency circumstances to report a crime, the location of the crime or victims, or the identity,

description or location of the person who committed the crime.

As required by law, including laws that require the reporting of certain types of wounds or other physical

injuries.

 

Coroners, Medical Examiners and Funeral Home Directors - We may disclose health information to a

coroner or medical examiner. This may be necessary to identify a deceased person or determine the cause of death

of a person. We may also release health information about patients at our facility to funeral home directors as

necessary to carry out their duties.

 

Organ and Tissue Donation - We may release health information to organizations that handle organ

procurement or organ, eye or tissue transplantation, or to an organ donation bank as necessary to facilitate organ or

tissue donation and transplantation.

 

Specifically Approved Research - We may disclose your health information to researchers when an Institutional

Review Board (IRB) or Privacy Board has reviewed the research proposal, has established appropriate protocols to

ensure the privacy of your health information, and has approved the research.

 

Averting a Serious Threat to Health or Safety - We may use and disclose health information about you when

necessary to prevent or lessen a serious threat to your health or safety or the health and safety of another person or

the public. These disclosures would be made only to someone able to help prevent or lessen the threat.

 

Military and Veterans - If you are a member of the armed forces, we may release health information about you

as required by military command authorities.

 

National Security and Intelligence Activities - We may disclose health information about you to authorized

federal officials for intelligence, counterintelligence and other national security activities authorized by law.

 

Protective Services for the President and Others. We may disclose medical information about you to

authorized federal officials so they may provide protection to the President, other authorized persons or foreign

heads of state, or conduct special investigations.

 

Inmates - If you are an inmate of a correctional institution or under custody of a law enforcement official, we

may disclose health information about you to the correctional institution or the law enforcement official. This is

necessary for the correctional institution to provide you with health care, to protect your health and safety and the

health and safety of others, or for the safety and security of the correctional institution.

 

Worker’s Compensation - We may release health information about you for worker’s compensation or similar

programs if you have a work related injury. These programs provide benefits for work related injuries.

 

Legal Requirements - We will disclose health information about you without your permission when required to

do so by federal, state, or local law.

 

YOUR HEALTH INFORMATION RIGHTS

If you choose to exercise your rights, please make sure that you make the same requests directly to your private

physician, to the extent that such request is applicable. Please note, however, we are not responsible for the actions

of your private physician and their compliance with your request.

 

Although your health record is the physical property of the St. Clair entity that created it, the information belongs to

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

 

Right to Request Restrictions - You have the right to request a restriction on certain uses and disclosures of

your information. We are not required by law to agree to your request. If we do agree, we will comply with your

request unless the information is needed to provide you with emergency treatment.

 

Right to Inspect and Copy - You have the right to inspect and copy medical information that may be used to

make decisions about your care. Under federal law, however, you may not inspect or copy the following records:

psychotherapy notes; information compiled in reasonable anticipation of, or use in, a civil, criminal, or

administrative action or proceeding; and health information that is subject to a law that prohibits access to health

information. You must request to inspect and/or obtain a copy of your health record in writing. If you request a

copy of your health information or if you agree to a summary of such information, we will charge a fee for this

service. We may deny your request under very limited circumstances. Depending on the circumstances, a decision

to deny access may be reviewable and you may request that the denial be reviewed by another health care

professional chosen by someone on our health care team. We will abide by the outcome of that review.

 

Right to Amend – You have the right to request an amendment to your health record if you feel the information

is incorrect or incomplete. You must make a request for an amendment in writing and provide the reason(s) to

support the requested amendment. We may deny your request for an amendment if it is not in writing or does not

include a reason to support the request. Also, we may deny your request if the information was not created by our

health care team, is not part of the information kept by our facility, is not part of the information which you would

be permitted to inspect and copy, or if the information is accurate and complete. Please note that even if we accept

your request, we are not required to delete any information from your health record. If we deny your request for an

amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your

statement and will provide you with a copy of any such rebuttal.

 

Right to an Accounting of Disclosures – You have a right to obtain an accounting of disclosures of your health

information. The accounting will only provide information about disclosures made for purposes other than

treatment, payment or health care operations and is subject to other restrictions, exceptions, and limitations. You

must make a request for an accounting of disclosures in writing. Your request must state a time period which may

not be longer than six (6) years (you may request a shorter time period) and may not be for disclosures before April

14, 2003.

 

Right to Request Confidential Communications – You have the right to request that we communicate your

health information to you by alternative means or at alternative locations. We will accommodate reasonable

requests. We may condition this accommodation by asking you for information as to how payment will be handled

or specification of an alternative address or other method of contact.

 

Right to a Paper Copy of this Notice - You have the right to obtain a paper copy of this notice from us, upon

request, even if you have agreed to accept this notice electronically. You may ask us to give you a copy of this

privacy notice at any time by requesting a copy.

 

Right to Revoke Authorization – You have the right to revoke your authorization or consent to use or disclose

health information except to the extent that St. Clair or others have relied upon your prior authorization or consent.

 

Complaints - You have the right to complain about any aspect of our health information practices to us or to the

Department of Health and Human Services of the United States. More information about how to file a complaint is

available at http://www.hhs.gov/ocr/hipaa/. You can complain to us and expect an investigation and explanation by

calling 1-866-248-4500 extension 1101 or writing: St. Clair Hospital, 1000 Bower Hill Road, Pittsburgh, PA 15243-

1899, Attn: Privacy Officer. We will not retaliate against you for filing a complaint.