Please contact our Privacy Officer at (315) 488-2951 if you have any questions regarding this notice.

A.     PURPOSE OF NOTICE

This notice describes how St. Camillus uses and discloses information about you.  It also describes your rights and our responsibilities concerning information about you.

In this notice, the name “St. Camillus” means all of the following health care providers:

• St. Camillus Health and Rehabilitation Center
• St. Camillus Adult Day Health
• St. Camillus Certified Home Health Agency
• Integrity Home Care Services, Inc.
• St. Camillus Diagnostic and Treatment Center
• St. Camillus Comprehensive Outpatient Rehabilitation Facility
• Physical Medicine and Rehabilitation MSG LLC practice at St. Camillus facilities

The St. Camillus health care providers share information with each other as necessary to carry out treatment, payment, and health care operations.

This notice applies to all people who work at St. Camillus, including:

• Employees, staff members, and health care professionals who are authorized to enter information in your medical record, or who need to review your record in order to provide services to you;
• Trainees that we allow to participate in your care; and
• Volunteers that work for us and with whom you may interact.

This notice applies to all protected health information created or maintained concerning you at St. Camillus, including any protected health information that we receive from other health care providers.

B.     OUR COMMITMENT TO THE PRIVACY OF YOUR HEALTH INFORMATION

We are committed to preserving the privacy and confidentiality of health information created or maintained by St. Camillus concerning you.  Certain state and federal laws and regulations require us to have policies and procedures to safeguard the privacy of your health information.

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.  A copy of this notice will be posted in a visible location at each St. Camillus service delivery facility.

We reserve the right to change this notice.  Any changes to this notice will apply to all the records that St. Camillus has created or maintained in the past, and to any records that we may create or maintain in the future.  If we make any changes to this notice, the revised notice will be available to you on request, and will be posted on our website, www.st-camillus.org.  If we make a major change in this notice that affects the use and disclosure of your protected health information, your rights, our duties, or our privacy practices, you will be informed in accordance with law.

C.     USES OR DISCLOSURES OF YOUR HEALTH INFORMATION

We may use or disclose your health information in the following ways:

• For purposes of treatment, payment or health care operations
• For other purposes, with your written authorization
• As required or permitted by law

In this notice, we describe each of the ways that we may use or disclose your health information.  We have included examples of the different types of uses or disclosures.  We have not listed every possible use or disclosure, but we have included all of the ways in which we may use or disclose your protected heath information.

1. Uses and disclosures of your health information for treatment, payment, or health care operations

We may use and disclose your protected health information for purposes of treatment, payment, or health care operations, without the need for your written authorization.

a.     Treatment.  St. Camillus uses protected health information in order to provide you with health care treatment and services.  We may disclose your health information to doctors, nurses, aides, technicians, health care profession trainees, therapists, and other personnel who are involved in your health care.  For example, if your physician orders physical therapy services to improve your strength and walking abilities, our staff will need to communicate with the physical therapist so that we can coordinate services and develop a plan of care.

1. Other health care providers.  We may disclose your health information to health care facilities and professionals outside of our facilities who are involved in your health care, such as doctors, clinical laboratories, pharmacies, or home health agencies.
2. Family members.  Health care professionals at St. Camillus, using their professional judgment, may disclose your protected health information to a family member, a close personal friend, or another individual who is involved in your care or in payment for your care.
3. Appointment reminders and follow-up calls.   We may use or disclose your health information to contact you with a reminder that you have an appointment for treatment or medical care.  We may also call to follow up on care you received from us, or to tell you of test results, or to confirm an appointment with us or with another health care provider.
4. Treatment alternatives, health-related benefits and services.  We may use or disclose your health information to tell you about possible treatment alternatives or health-related benefits and services that may be of interest to you.

b.     Payment.  We may use or disclose your health information so that St. Camillus or another health care provider may bill and collect payment from you, an insurance company, Medicare, Medicaid, or another third party for the health care services you receive at St. Camillus.  For example, we may need to give information to your health insurer regarding the services you received from St. Camillus so that your insurer will pay for the services and we may give information to a doctor who is treating you so that the doctor can bill your health insurer.  We also may tell your health insurer about a treatment you are going to receive in order to obtain prior approval or determine whether your health insurer will cover the treatment.

c.     Health care operations.  We may use or disclose your health information to perform health care business operations within our facilities.  These uses or disclosures are necessary to operate our facilities and to make sure that our residents receive quality care.  For example, we may use your health information to review our treatment and services and to evaluate the performance of our staff in caring for you.  We may disclose your health information to health care profession trainees working at St. Camillus for professional education purposes.  We may combine health information with information from other health care providers or facilities to compare how we are doing and see where we can make improvements in the care and services offered to our residents.

1. Business associates.  We may disclose health information to outside companies that perform business services for us, such as billing companies, software vendors, attorneys, or external auditors.  In those situations, we will have a written agreement with those other companies to ensure that they safeguard the privacy of your protected health information.
2. Fundraising activities.  We may use your name, address, phone number, and the dates that you received treatment at St. Camillus in order to contact you as part of our fund-raising efforts.  We may also share this limited amount of information with a charitable foundation that would contact you to raise money on behalf of St. Camillus.  If you do not want to be contacted for these fundraising efforts, please write to:  St. Camillus Foundation, 813 Fay Road, Syracuse, New York 13219.
3. Directory information.  Unless you tell us that you object, we will use your name and location in the facility for purposes of the facility directory.  This information may be provided to people who ask for you by name.  Also, information concerning your religious affiliation may be provided to members of the clergy.  If you object, you may tell the Admissions staff person when you are first admitted to St. Camillus or you may write to the Director of Communications, St. Camillus Health and Rehabilitation Center, 813 Fay Road, Syracuse, New York 13219.

2. Uses and disclosures that require your written authorization

We may use or disclose your health information with your written authorization for certain purposes other than treatment, payment or health care operations.  When you have given us a written authorization for use or disclosure of your health information, you have the right to revoke that authorization at any time, but your revocation must be given to us in writing.  If you revoke your written authorization, we will no longer use or disclose your health information for the purposes identified in the authorization.  However, we cannot take back any disclosures that were made while your authorization was in effect.

Some examples of uses or disclosures that would require your written authorization are providing health information to a pharmaceutical company for purposes of marketing, or providing copies of your medical records to your attorney.

3. Uses and disclosures required or permitted by law

Certain state and federal laws and regulations may either require or permit us to use or disclose your health information without your permission.  The uses or disclosures that we may make in accordance with these laws and regulations include the following:

a.      Public health activities.  We may use or disclose your health information to public health authorities so that they may carry out public health activities.  For example, we may use or disclose your health information for the following purposes, in accordance with law:

1. To report births and deaths
2. To prevent or control disease, injury or disability
3. To report adverse reactions to medications or problems with health care products
4. To notify individuals of product recalls

b.    Health oversight activities.  We may use or disclose your health information to a health oversight agency that is authorized by law to conduct health oversight activities.  These oversight activities may include audits, investigations, inspections, or licensure and certification surveys.  These activities are necessary to monitor the operation of the health care system and ensure compliance with laws and regulations.  They include the use or disclosure of your health information to the long-term care ombudsman program.

c.      Lawsuits and legal proceedings.  We may disclose your health information in response to a court order or administrative agency order, in connection with a lawsuit or similar proceeding.  We also may disclose your protected health information in response to a subpoena or other legal process by another party involved in a legal dispute, but only if we have received satisfactory assurances from the party seeking the information that reasonable efforts have been made to inform you of the request, or an appropriate protective order has been issued by a court.

d.     Worker’s Compensation.  We may disclose your health information for worker’s compensation or other similar programs that provide benefits for work-related injuries or illnesses, if a claim for benefits is filed.

e.     Law enforcement.  In accordance with law, we may disclose your health information to law enforcement officials for reasons such as the following:

1. In compliance with a court order, subpoena, warrant, summons or other lawful process
2. To identify or locate a suspect, fugitive, material witness, or missing person
3. If you have been or suspected of being a victim of crime and you agree to the disclosure, or if we are unable to obtain your agreement because of your incapacity or another emergency
4. To report a death that we believe may be the result of criminal conduct
5. To report evidence of criminal conduct that occurred on St. Camillus premises
6. To report a crime, including the location or victims of the crime, or the identity, description, or location of the individual who committed the crime

f.     Coroners, medical examiners, or funeral directors.  We may use or disclose your health information to a coroner or medical examiner for the purpose of identifying a deceased individual or to determine the cause of death.  We also may use or disclose your health information to a funeral director, in the event of your death.

g.    Organ procurement organizations or tissue banks.  If you are an organ donor, we may use or disclose your health information to organizations that handle organ procurement, transplantation, or tissue banking for the purpose of facilitating organ or tissue donation or transplantation.

h.     Research.  In most cases, we will not disclose your health information for research purposes without your written authorization.  However, in limited circumstances we may use or disclose protected health information without your written authorization if:

1. The use or disclosure was approved by an Institutional Review Board or a Privacy Board; or
2. The use or disclosure is necessary for purposes preparatory to research, and no protected health information will be removed from St. Camillus; or
3. The protected health information sought by the researcher relates only to decedents, and the disclosure is necessary for the purpose of research.

i.       To avert a serious threat to health or safety.  We may use or disclose your health information if, in good faith, we believe that it is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.  Any such use or disclosure would be made solely to a person or persons reasonably able to prevent or lessen the threat, including the target of the threat, or to law enforcement authorities for the purpose of identifying or apprehending an individual.

j.       Military and veterans.  If you are or were a member of the armed forces, we may use or disclose your health information as required by military authorities.

k.      National security and intelligence activities.  We may disclose your health information to authorized federal officials for purposes of intelligence, counterintelligence, and other national security activities, as authorized by law.

D.    YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION

You have the following rights regarding health information, which we create or maintain:

1. Right to inspect and copy.  You have the right to inspect and obtain a copy of your health information, including information maintained in our medical and billing records.  To inspect and obtain a copy your health information, you must submit your request in writing* to the Director of Medical Records.  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.

*If you are a St. Camillus resident you have the right to make a verbal request to inspect and obtain a copy of your health information. Rev. 6/16/03

Under certain circumstances, we may deny your request to inspect and obtain a copy your health information.  If you are denied access to your health information, we will provide you with a written notice explaining our reasons for the denial, and will include a description of how you may exercise your right to have the decision reviewed.

2. Right to request an amendment.  If you feel that the health information we have about you is incorrect or incomplete, you may ask us to amend the information. To request an amendment, your request must be submitted in writing to the Director of Medical Records.  In addition, you must provide us with a reason that supports your request.  We will respond to your request within 60 days.

If we deny your request for an amendment, we will provide you with a written notice that explains our reasons.  You will have the right to submit a written statement disagreeing with our denial.  You will also be informed of how to file a complaint with St. Camillus or with the Secretary of the United States Department of Health and Human Services.

3. Right to an accounting of disclosures.  You have the right to request a list of certain disclosures, which we have made of your health information.  This accounting of disclosures will not include:

1. Disclosures we made to carry out treatment, payment, and health care operations;
2. Disclosures we made to you;
3. Disclosures we made in accordance with an authorization you signed;
4. Disclosures we made in a facility directory or to persons involved in your care;
5. Disclosures we made for national security or intelligence purposes;
6. Disclosures to correctional institutions or law enforcement officials; or
7. Disclosures we made before April 14, 2003.

To request an accounting of disclosures, you must submit your request in writing to the Director of Medical Records.  We will respond to your request for an accounting of disclosures within 60 days.  Your request must state a time period covered by your request, which may not be longer than six years prior to the date of your request and may not include dates before April 14, 2003.

The first accounting you request will be free.  If you request additional accountings within a 12-month period, we may charge you for the costs of providing the accounting.  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 health information we use or disclose about you for purposes of treatment, payment, or health care operations.  We are not required to agree to your request.  If we do agree, we will limit the disclosure of your protected health information in accordance with that restriction, unless the information is needed to provide you with emergency treatment or to comply with law.

You also have the right to request a limit on the health information we disclose about you to someone, such as a family member or friend, who is involved in your care or in the payment of your care.  For example, you could ask that we not disclose information regarding a particular treatment that you received.

To request restrictions, you must put your request in writing.  You may do this at the time of admission on a form provided by St. Camillus or any time thereafter by writing to our Director of Medical Records.  In your request, you must tell us:

1. What information you want to limit;
2. Whether you want to limit our use, disclosure or both; and
3. To whom you want the limits to apply (for example, disclosures to a family member).

5. Right to request confidential communications.  You have the right to request that we communicate with you about your health care in a certain way or at a certain location.  For example, you can ask that we only contact you at home or by mail.

To request confidential communications, you must put your request in writing.  You may do this at the time of admission on a form provided by St. Camillus or any time thereafter by writing to our Director of Medical Records. 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, and how payment for your health care will be handled if we communicate with you through this designated method or location.

6. Right to a paper copy of this notice.  You have the right to receive 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.

You may obtain a copy of this notice at our web site, www.st-camillus.org.  To obtain a paper copy of this notice, contact the Director of Admissions.

E.     COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with St. Camillus or with the secretary of the U.S. Department of Health and Human Services. To file a complaint with St. Camillus, contact the Privacy Officer.  All complaints must be submitted in writing.

You will NOT be penalized for filing a complaint.