A. GENERAL DESCRIPTION AND PURPOSE OF NOTICE.
This notice describes the privacy practices of Evangelical Homes of Michigan and its affiliated entities: Evangelical Home – Saline, Evangelical Home – Sterling Heights and their respective staff physicians under an “Organized Health Care Arrangement”. Throughout this notice, the term facility will be used to refer to any one or all of these entities.
This notice applies to:
1. Any health care professional authorized to enter information into your medical record created and/or maintained at our facility;
2. Any member of a volunteer group which we allow to assist you while receiving services at our facility; and
3. All facility employees, contracted staff, temporary staff, and other personnel.
4. All physicians and their staff participating in the “Organized Health Care Arrangement” with Evangelical Homes.
All of the individuals or entities identified above will follow the terms of this notice. These individuals or entities may share your health information with each other for purposes of treatment, payment, or health care operations, as further described in this notice.
B. OUR PLEDGE REGARDING YOUR MEDICAL INFORMATION:
We understand that medical information about you and your health is personal and we are committed to preserving the privacy and confidentiality of your health information created and/or maintained at our facility. We create a record of the care and services you receive at our facility in order to provide you with quality care and to comply with certain legal requirements. Certain state and federal laws and regulations require us to implement policies and procedures to safeguard the privacy of your health information.
This notice will provide you with information regarding our privacy practices and applies to all of your health information created and/or maintained by our facility, including any information that we receive from other health care providers or facilities. We will abide by the terms of this notice, including any future revisions that we may make to the notice as required or authorized by law. Your personal physician may have different policies or notices regarding the physician’s use and disclosure of your medical information created in the physician’s office or clinic.
This notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.
We are required by law to:
1. make sure that medical information that identifies you is kept private;
2. give you this notice of our legal duties and privacy practices with respect to medical information about you; and
3. follow the terms of the notice that is currently in effect.
C. HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
The following categories describe the different ways that we use and disclose medical 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.
1) For Treatment. We may use medical information about you to provide you with health care treatment or services. We may disclose medical information about you to doctors, nurses, aides, technicians, volunteers, or other facility personnel who are involved in taking care of you at the facility. For example, a doctor treating you for pneumonia may need to know if you have diabetes because diabetes may slow the recovery process. In addition, the doctor may need to tell the dietician if you have diabetes so that we can arrange for appropriate meals. Different departments of the facility also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work, x-rays, and oxygen. Your photograph might be used to assist in locating or identifying you, in the unlikely event that you become lost while outside the facility, or for identification during treatment. Your photograph may be placed outside the door to your room and/or maintained as part of your medical record. We may also disclose medical information about you to people outside the facility who may be involved in your medical care after you leave the facility, such as family members, clergy or others we use to provide services that are part of your care. We may use an open treatment area for physical or occupational therapy treatments where more than one individual may be receiving treatment at any given time. Additionally, involved family members or representatives may be present during treatments.
2) For Payment. We may use and disclose medical information about you so that the treatment and services you receive at the facility 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 Medicare or your Medigap insurer information about services you received at the facility so they will pay us or reimburse you for the services. We may also tell an insurer about a treatment you are going to receive in order to obtain prior approval or to determine whether your plan will cover the treatment.
3) For Health Care Operations. We may use and disclose medical information about you for facility operations. These uses and disclosures are necessary to run the facility and make sure that all of our residents receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many facility residents to decide what additional services the facility should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, aides, technicians, volunteers, and other facility personnel for review and learning purposes. We may also combine the medical information we have with medical information from other facilities 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 medical information so others may use it to study health care and health care delivery without learning who the specific residents are. In order to add to the “home” environment, which is an integral part of the quality of care of the facility, we may publish the resident’s name, picture, birthday, notice of admission or discharge, or other such notable “accomplishments” in Evangelical Homes’ newsletters or other internal announcements.
4) Appointment Reminders. We may use and disclose medical information to contact you and/or your representative as a reminder that you have an appointment for treatment or a care conference at the facility.
5) Treatment Alternatives. We may use and disclose medical information to tell you and/or your representative about, or recommend, possible treatment options or alternatives that may be of interest to you.
6) Health Related Benefits and Services. We may use and disclose medical information to tell you and/or your representative about health-related benefits or services that may be of interest to you.
7) Fundraising Activities. We may use a limited amount of medical information about you to contact you or your family members in an effort to raise money for the facility and its operations. If you do not wish to be contacted by Evangelical Homes of Michigan for fundraising efforts, you must notify in writing:
Director of Development,
Evangelical Homes of Michigan,
18000 Coyle, Detroit, MI 48235
8) Facility Directory. We may include certain limited information about you, in the facility directory while you are a resident at the facility. This information may include your name, location in the facility, your general condition (e.g., fair, stable, etc.) and your religious affiliation. The directory information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they don’t ask for you by name. This is so your family, friends and clergy can visit you in the facility and generally know how you are doing.
9) Individuals Involved in Your Care or Payment for Your Care. We may release medical information about you to a friend or family member who is involved in your medical care, such as your Resident Representative, Attorney-in-Fact, Patient Advocate or Guardian. We may also give information to someone who helps pay for your care. We may also tell your family or friends your general condition and that you are in the facility, if they ask about you by name. We may also disclose your medical information to a person or organization assisting in disaster relief efforts for the purpose of notifying family or friends involved in your care about your condition, status, and location.
10) Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all residents who received one sort of care to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with residents’ need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, we may, however, disclose medical information about you to people preparing to conduct a research project, for example, to help them look for residents with specific medical needs, so long as the medical information they review does not leave the facility. We will almost always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at the facility.
11) As Required By Law. We will disclose medical information about you when required to do so by federal, state or local law, or directed by a court subpoena or order to do so.
12) To Avert a Serious Threat to Health or Safety. We may use and disclose medical 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 with the ability or authority to help prevent the threat.
13) Organ and Tissue Donation. If you are an organ donor, we may release medical 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.
14) Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
15) Workers’ Compensation. We may release medical information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.
16) Public Health Risks. We may disclose medical information about you for public health activities. These activities generally include the following:
a) To prevent or control disease, injury or disability;
b) To report births and deaths;
c) To report reactions to medications or problems with products;
d) To notify people of recalls of products they may be using;
e) 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;
f) To notify the appropriate government authority if we believe you or another resident has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
17) Health Oversight Activities. We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure and certification surveys. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
18) Lawsuits, Administrative Proceedings and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process issued by a judge or by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
a) In response to a court order, subpoena, warrant, summons or similar process;
b) To identify or locate a suspect, fugitive, material witness, or missing person;
c) About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
d) About a death we believe may be the result of criminal conduct;
e) About criminal conduct at the facility; or
f) 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.
19) Law Enforcement. We may use or disclose your medical information if asked to do so by a law enforcement official for the following purposes:
20) Coroners, Medical Examiners and Funeral Directors. We may use or disclose medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may use or disclose medical information about residents of the facility to funeral directors as necessary to carry out their duties.
21) National Security and Intelligence Activities. We may use or disclose medical information about you to authorized federal officials for intelligence, counter-intelligence, and other national security activities authorized by law.
22) Protective Services for the President and Others. We may use or 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.
23) Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may use or disclose medical information about you to the correctional institution or law enforcement official. This release would be necessary (i) for the institution to provide you with health care; (ii) to protect your health and safety or the health and safety of others; or (iii) for the safety and security of the correctional institution.
D. YOUR RIGHTS REGARDING YOUR MEDICAL INFORMATION
You have the following rights regarding the medical information we create and/or maintain about you:
1. 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. Usually, this includes medical and billing records, but does not include psychotherapy notes. To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to the facility’s Health Information Coordinator, contact information is at the end of this notice. 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 in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by the facility will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.
2. Right to Amend. If you feel that medical 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 the facility.
To request an amendment, you must submit your request in writing to the facility’s Health Information Coordinator; contact information is at the end of this notice. 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:
a.) Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
b.) Is not a part of the medical information kept by or for the facility;
c.) Is not part of the information which you would be permitted to inspect and copy; or
d.) Is accurate and complete.
3. Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures.” This is a list of the disclosures we have made of medical information about you. This accounting will not include disclosures of medical information that we made for purposes of treatment, payment, or health care operations. To request this list or accounting of disclosures, you must submit your request in writing to the facility’s Health Information Coordinator, contact information is at the end of this notice. Your request must state a time period that may not be longer than six (6) years prior to the date of your request and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper or by electronic means). 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.
4. Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a particular medical treatment you had.
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 facility’s Health Information Coordinator, contact information is at the end of this notice. In your request, you must tell us: (a) what information you want to limit; (b) whether you want to limit the use, disclosure or both; and (c) to whom you want the limits to apply, for example, disclosures to a family member.
5. Right to Request Confidential Communications. Subject to certain State and Federal regulations concerning notifying you of certain matters, you have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. Where a State or Federal regulation requires a different mode of notification, we will follow that regulation.
To request confidential communications, you must make your request in writing to the facility’s Health Information Coordinator; contact information is at the end of this notice. 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.
6. Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.
To obtain a paper copy of this notice, contact the facility’s Admission Coordinator in person, by phone, or in writing; contact information at the end of this notice.
E. CHANGES TO THIS NOTICE
1. We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical 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 the facility and on our web site. The notice will contain on the first page, in the top right-hand comer, the effective date and any dates of revision. In addition, each time you register at or are admitted to the facility for treatment or health care services, we will offer you a copy of the notice currently in effect.
If you believe your privacy rights have been violated, you may file a complaint with the facility or with the Secretary of the Department of Health and Human Services. To file a complaint with the facility, contact:
Joanne Stutesman, Privacy Officer
Evangelical Homes of Michigan
18000 Coyle Avenue
Detroit, MI 48235
734-429-9401 x3169 or 313-836-5306
All complaints must be submitted in writing.
You will not be penalized for filing a complaint.
Use our toll free # for confidential reporting: 866-283-7736
G. OTHER USES OF MEDICAL INFORMATION
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain our records of the care that we provided to you. If your revocation makes it impossible for us to provide services to you in a professional and safe manner, we may discharge you from the facility.
H. Contact Information
Evangelical Homes of Michigan
34024 West 8 Mile Rd., Suite 101
Farmington, MI 48335
248-871-5001 (Corporate Office)
866-283-7736 (Complaint line)
Office of Community Relations and Fund Development
Evangelical Homes of Michigan
34024 West 8 Mile Rd., Suite 101
Farmington, MI 48335
Saline: Health Information Coordinator or Admissions Coordinator
440 W. Russell
Saline, MI 48176
Sterling Heights: Health Information Coordinator or Admissions Coordinator
14900 Shoreline Dr.
Sterling Heights, MI 48313