CARILLON ASSISTED LIVING, LLC
NOTICE OF PRIVACY PRACTICES
CARILLON AND ITS FACILITIES
Effective October 20, 2003
THIS NOTICE DESCRIBES HOW MEDICAL HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO HEALTH INFORMATION.
PLEASE REVIEW THIS NOTICE CAREFULLY
- A. We Have A Legal Duty to Protect Health Information About You
We are required by law to protect the privacy of health information about you as a resident of a Carillon facility and that can be identified with you, which we call “protected health information,” or “PHI” for short. In general, PHI is information which identifies you and that relates to your past, present, or future physical or mental health or condition; or relates to health care services provided by Carillon or other persons and organizations; or that relates to payment for any of these services. We must tell you about our legal duties and how we protect PHI:
We must protect PHI that we have created or received about you.
We must tell you how we protect PHI about you.
We must explain how, when and why we use and/or disclose PHI about you.
We may only use and/or disclose PHI as we have described in this Notice.
This Notice describes Carillon’s uses and disclosures of PHI and gives you some examples of common uses and disclosures. We may also make other uses and disclosures that occur as a byproduct of the permitted uses and disclosures described in this Notice.
We are required to follow the procedures in this Notice, or in a revised notice. We reserve the right to change the terms of this Notice and to make new notice provisions effective for all PHI that we maintain by displaying copies of the revised notice in our central office and in each facility.
- B. We May Use and Disclose PHI About You Without Getting Your Written Authorization
- We may use and disclose PHI about you to provide any service we furnish to you.
We may use and disclose PHI about you to provide, coordinate or manage your health care and related services. This may include communicating with other health care providers about your treatment and also coordinating and managing your health care with others. For example, we may use and disclose PHI about you when you need a prescription, lab work, an x-ray, or other health care services. In addition, we may use and disclose PHI about you when we refer you to another health care provider or by request of another health care provider who is providing services to you.
- We may use and disclose PHI about you to obtain payment for services we furnish you.
Generally, we may use and give PHI about you to others for billing and collecting payment for treatment and services provided to you by us or by another provider. Before you receive services, we may share PHI about these services with your health plan or other payor. Sharing PHI allows us to ask for coverage under your plan or policy and for approval of payment before we provide the services. We may also share parts of PHI about you with the following:
Collection departments or agencies, or attorneys assisting us with collections;
Insurance companies, health plans and their agents which provide you coverage;
Hospital departments that review the care you received to check that it and the costs associated with it were appropriate for your illness or injury; and
Consumer reporting agencies such as credit bureaus.
- We may use and disclose PHI about you for health care operations.
We may use and disclose PHI in performing Carillon’s business activities, which we call “health care operations”. These health care operations include reviews of the quality of services we provide by Carillon and independent organizations as well as Carillon’s analysis of the future need for services by residents of the facility and other Carillon facilities all of which allow us to improve the quality of care we provide and reduce health care costs. In addition, we may disclose PHI about you for the “health care operations” of other providers involved in your care to improve the quality, efficiency and costs of their care or to evaluate and improve the performance of their providers.
- We may use and disclose PHI under other circumstances without your authorization or give you an opportunity to agree or object.
We may use and/or disclose PHI about you for a number of circumstances in which you do not have to consent, give authorization or otherwise have an opportunity to agree or object. Those circumstances include when the use and/or disclosure is required by law, is necessary for public health activities, relates to victims of abuse, neglect or domestic violence, is for health oversight activities, is for judicial and administrative proceedings, is for law enforcement purposes, relates to decedents, relates to organ, eye or tissue donation purposes, relates to medical research, is to avert a serious threat to health or safety, relates to specialized government functions, and/or relates to correctional institutions.
- You can object to certain uses and disclosures.
Unless you object, we may use or disclose PHI about you in the following circumstances:
- We may give a family member, relative, friend or other person identified by you, the PHI directly related to that person’s involvement in your care or payment for your care. We may give a family member, personal representative or other person responsible for your care the PHI necessary to notify such individuals of your location, general condition or death.
- We may give a public or private agency (for example, American Red Cross) PHI about you for disaster relief purposes. Even if you object, we may still share the PHI about you, if necessary for the emergency circumstances.
If you would like to object to our use or disclosure of PHI about you in the above circumstances, please call or write to our contact person listed on the cover page of this Notice.
- We may contact you to provide appointment reminders.
We may use and/or disclose PHI to contact you to provide a reminder to you about an appointment you have for treatment or medical care.
- We may contact you with information about treatment, services, products or health care providers.
We may use and/or disclose PHI to manage or coordinate your healthcare. This may include telling you about treatments, services, products and/or other healthcare providers. We may also use and/or disclose PHI to give you gifts of a small value, such as observing your birthday.
- We are required to disclose PHI about you to state and federal regulatory agencies as part of their oversight of Carillon’s operations.
ANY OTHER USE OR DISCLOSURE OF PHI ABOUT YOU BY CARILLON REQUIRES US TO GET YOUR WRITTEN AUTHORIZATION
Under any circumstances other than those listed in Items 1-8 above, we will get your written authorization before we use or disclose PHI about you. If you sign a written authorization allowing us to disclose PHI about you, you still can cancel that authorization later in writing by contacting our Privacy Officer, at the address shown at the end of this Notice. If you cancel your authorization in writing, we will not use or disclose PHI about you after we receive your cancellation, except for uses or disclosures that were already being processed before we received your cancellation.
- You Have Several Rights Regarding PHI About You
This section of our Privacy Practices describes certain rights that you have as a resident of a Carillon facility. Any request that you may make concerning these rights should be made in writing and addressed to the administrator of the Carillon facility where you are receiving services at the time.
- You have the right to request restrictions on uses and disclosures of PHI about you.
You have the right to ask Carillon to restrict the use and disclosure of PHI about you. We are not required to agree to your requested restrictions, and even if we agree to your request, in certain situations your restrictions may not be followed. These situations include emergency treatment, disclosures to the Secretary of the Department of Health and Human Services, and uses and disclosures described in subsection B.4 of the previous section of this Notice. You can request a restriction by sending it in writing to our Privacy Officer, at the address shown at the end of this Notice.
- You have the right to request different ways to communicate with you.
You have the right to request how and where we contact you about PHI. For example, you may request that we contact you at your work address or phone number or by email. We must accommodate reasonable requests, but, when appropriate, may condition that accommodation on your providing us with information regarding how payment, if any, will be handled and your specification of an alternative address or other method of contact. You request for alternative communications must be in writing and sent to our Privacy Officer, at the address shown at the end of this Notice.
- You have the right to see and copy PHI about you.
You have the right to request to see and receive a copy of PHI contained in clinical, billing and other records used to make decisions about you. Your request must be in writing. We may charge you related fees. Instead of providing you with a full copy of the PHI, we may give you a summary or explanation of the PHI about you, if you agree in advance to the form and cost of the summary or explanation. There are certain situations in which we are not required to comply with your request. Under these circumstances, we will respond to you in writing, stating why we will not grant your request and describing any rights you may have to request a review of our denial. You may request to see and receive a copy of PHI by sending a written request to our Privacy Officer, at the address shown at the end of this Notice.
- You have the right to ask us to amend PHI about you.
You have the right to request us to amend clinical, billing and other records that we use to make decisions about the services we provide you. Your request must be in writing and must explain your reason(s) for the amendment. We may deny your request if: 1) the information was not created by us (unless you prove the creator of the information is no longer available to amend the record); 2) the information is not part of the records used to make decisions about you; 3) we believe the information is correct and complete; or 4) you would not have the right to see and copy the record as described in paragraph 3 above. We will tell you in writing the reasons for the denial and describe your rights to give us a written statement disagreeing with the denial. If we accept your request to amend the information, we will make reasonable efforts to inform others of the amendment, including persons you name who have received PHI about you and who need the amendment. You may request an amendment of PHI about you by sending it in writing to our Privacy Officer, at the address shown at the end of this Notice.
- You have the right to a list of disclosures we have made.
If you ask in writing, you have the right to receive a written list of certain of our disclosures of PHI about you. You may ask for disclosures made up to six (6) years before your request (not including disclosures made prior to April 14, 2003). We are required to provide a list of all disclosures except the following:
- For your treatment
- For billing and collection of payment for your treatment
- For health care operations
- Made to or requested by you, or that you authorized
- Occurring as a byproduct of permitted uses and disclosures
- Made to individuals involved in your care, for directory or notification purposes, or for other purposes described in subsection B.5 above
- Allowed by law when the use and/or disclosure relates to certain specialized government functions or relates to correctional institutions and in other law enforcement custodial situations (please see subsection B.4 above) and
- As part of a limited set of information which does not contain certain information which would identify you.
The list will include the date of the disclosure, the name (and address, if available) of the person or organization receiving the information, a brief description of the information disclosed, and the purpose of the disclosure. If, under permitted circumstances, PHI about you has been disclosed for certain types of research projects, the list may include different types of information.
If you request a list of disclosures more than once in 12 months, we can charge you a reasonable fee. You may request a listing of disclosures by sending it in writing to our Privacy Officer, at the address shown at the end of this Notice.
- You have the right to a copy of this Notice.
You have the right to request a paper copy of Carillon’s current Notice of Privacy Practices at any time by contacting our Privacy Officer, at the address shown at the end of this Notice. We will provide a copy of this Notice no later than the date you first receive service from us (except for emergency services, and then we will provide the Notice to you as soon as possible).
- You May File A Complaint About Our Privacy Practices
If you think we have violated your privacy rights, or you want to complain to us about our privacy practices, you can contact the person listed below:
Kenneth C. Kirkham, Chief Operating Officer and Privacy Officer
Carillon Assisted Living
4901 Waters Edge Drive, Suite 200
Raleigh, NC 27606
You may also send a written complaint to the United States Secretary of the Department of Health and Human Services at the Office of Civil Rights.
Carillon will not retaliate or penalize you if you file a complaint.