Abramson Senior Care Privacy Practices
NOTICE OF PRIVACY PRACTICES Effective Date: November 1, 2020
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.
PURPOSE OF THE NOTICE.
Abramson Senior Care (“ASC”) is committed to preserving the privacy and confidentiality of your health information that is created and/or maintained at our Office. 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 at our Office, including any information that we receive from other health care providers or facilities. This Notice describes the ways in which we may use or disclose your health information and also describes your rights and our obligations concerning such uses or disclosures. It is being delivered in connection with the privacy regulations under the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”).
Your Rights
You have the right to:
• Get a copy of your paper or electronic medical record
• Correct your paper or electronic medical record
• Request confidential communication
• Ask us to limit the information we share
• Get a list of those with whom we’ve shared your information
• Get a copy of this privacy notice
• Choose someone to act for you
• File a complaint if you believe your privacy rights have been violated
Your Choices
You have some choices in the way that we use and share information as we:
• Tell family and friends about your condition
• Provide disaster relief
• Include you in a directory
• Provide mental health care
• Market our services and sell your information
• Raise funds
Our Uses and Disclosures
We may use and share your information as we:
• Care for you
• Run our organization
• Bill for your services
• Help with public health and safety issues
• Do research
• Comply with the law
• Respond to organ and tissue donation requests
• Work with a medical examiner or funeral director
• Address workers’ compensation, law enforcement, and other
Government requests
• Respond to lawsuits and legal actions
Your Rights
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
Get an electronic or paper copy of your medical record
• You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
• We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
Ask us to correct your medical record
• You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
• We may say “no” to your request, but we’ll tell you why in writing within 60 days.
Request confidential communications
• You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
• We will say “yes” to all reasonable requests.
Ask us to limit what we use or share
• You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
• If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.
Get a list of those with whom we have shared information
• You can ask for a list (accounting) of the times we have shared your health information for six years prior to the date you ask, who we shared it with, and why.
• We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
Get a copy of this privacy notice
You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
Choose someone to act for you
• If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
• We will make sure the person has this authority and can act for you before we take any action.
File a complaint if you feel your rights are violated
• You can complain if you feel we have violated your rights by contacting us using the information below.
• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
• We will not retaliate against you for filing a complaint.
Your Choices - For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions. In these cases, you have both the right and choice to tell us to:
• Share information with your family, close friends, or others involved in your care
• We may disclose your health information to individuals, such as family members, clergy, and people who identify themselves as close personal friends, who are involved in your care or who help pay for your care if the personal health information is relevant to that person’s involvement. We may make such disclosures when: (a) we have your verbal agreement to do so; (b) we make such disclosures when you are also present and you do not object; or (c) we can infer from the circumstances that you would not object to such disclosures. For example, if your friend comes into the Office with you, we will assume that you agree to our disclosure of your information while your friend is present in the Office. Also, we may make disclosure when called by a close family member or friend, to review your condition, status, laboratory results or medications.
• We also may disclose your health information to family members or people who identify themselves as close personal friends in instances when you are unable to agree or object to such disclosures, provided that we feel it is in your best interests to make such disclosures and the disclosures relate to that family member or friend’s involvement in your care. For example, if you are incapacitated, we may share information with the family member or friend that comes with you to our Office or who calls about your care.
• Share information in a disaster relief situation
• Include your information in a directory
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
- Appointment Reminders. We may use or disclose your health information for purposes of contacting you to remind you of a health care appointment. Message reminders confirming appointments for health care services may be left on your or your personal representative’s Voice mail.
In these cases, we never share your information unless you give us written permission:
• Marketing purposes
• We never market or sell personal information.
• Most sharing of psychotherapy notes
In the case of fundraising:
• We may contact you for fundraising efforts, but you can tell us not to contact you again.
Our Uses and Disclosures
We typically use or share your health information in the following three ways.
- Treat you - We can use your health information and share it with other professionals who are treating you.
Example: A doctor treating you for an injury asks another doctor about your overall health condition.
- Run our organization We can use and share your health information to run our Office, improve your care, and contact you when necessary.
Example: We use health information about you to manage your treatment and services.
- Bill for your services We can use and share your health information to bill and get payment from health plans or other entities.
Example: We give information about you to your health insurance plan so it will pay for your services.
How else can we use or share your health information?
We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We must meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.
Help with public health and safety issues
We can share health information about you for certain situations such as:
• Preventing disease
• Helping with product recalls
• Reporting adverse reactions to medications
• Reporting suspected abuse, neglect, or domestic violence
• Preventing or reducing a serious threat to anyone’s health or safety
Electronic Devices
The use of electronic devices which have internet capability such as Alexa, Siri and other similar recording audio and video devices may be located in areas in which private conversations about health-related concerns may be held. While those living in care units must agree to certain restrictions on devices, and a notice shall be posted in the area of the device to notify anyone of its presence and use, there are instances where that is not possible, such as in the home of a care-receiver, or for portable devices as may be used by a visitor or guest. Both permissible and non- permissible devices pose a privacy risk, and residents, staff and visitors may be inadvertently recorded by such devices during the course of their stay, visit or encounter within the vocal or visual range of the device. Abramson Senior Care does not control the content or the storage of such content on any resident or care-receiver placed electronic device and cannot assure the security of conversations or actions within the range of the device.
Do Research
We can use or share your information for health research.
Abramson Senior Care participates in the Integrated Data Warehouse (IDW) of the Jewish Federation of Greater Philadelphia (The Jewish Federation-JFGP). The principal purpose of the IDW is to securely store personal or other health information about the clients of the agencies that are part of the Jewish Federation family and that participate in the IDW (“Participating Agencies”), and to share this information among Participating Agencies to the extent permitted by law, if and when needed to help coordinate and improve the health care and other services we provide to our clients. Certain of these agencies are legally permitted to share and use health information about their clients with other Agencies because they are both subject to the Health Insurance Portability and Accountability Act of 1966, as amended (HIPAA). The other Agencies on this list will not have access to your personal health information unless you specifically authorize them to do so. No other department or personnel of JFGP will have access to your personal and health information except to the extent needed for maintenance of the IDW by JFGP’s information technology staff and to provide statistical data that does not identify clients, for community planning purposes.
None of this information may be used for marketing or solicitation. Your personal health information will be stored in the IDW as part of our healthcare operations and for provision of social services. We will not store any psychotherapy notes or information about substance abuse, HIV status, or alcoholism and other drug treatment about you.
o Female Hebrew Benevolent Society
o Jewish Relief Agency (JRA)
o Golden Slipper Center for Seniors
o Klein JCC
o Hebrew Immigrant Aid Society (HIAS)
o JEVS Human Services
o Jewish Information and Referral Service of JFPG
o Judith Creed Homes for Adult Independence (JCHAI)
o Mitzvah Food Project of JFGP Rhawnhurst
Comply with the law
We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.
Respond to organ and tissue donation requests
We can share health information about you with organ procurement organizations.
Work with a medical examiner or funeral director
We can share health information with a coroner, medical examiner, or funeral director when an individual dies.
Address workers’ compensation, law enforcement, and other government requests
We can use or share health information about you:
• For workers’ compensation claims
• For law enforcement purposes or with a law enforcement official
• With health oversight agencies for activities authorized by law
• For special government functions such as military, national security, and presidential protective services
Respond to lawsuits and legal actions
We can share health information about you in response to a court or administrative order, or in response to a subpoena.
More Stringent Laws
Highly Confidential Information.
Federal and applicable state laws may require special privacy protections for highly confidential information about you. “Highly confidential information” may include confidential information under Federal law governing alcohol and drug abuse information as well as state laws that often protect the following types of information:
- HIV/AIDS; Mental health; and Alcohol and drug abuse.
- Release of Records.
- Written consent of the resident, or of a designated responsible agent acting on the resident’s behalf, is required for release of this type of information, except in limited circumstances.
- Other Federal law gives you the right to broader access to and right to review your clinical records.
Our Responsibilities
• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
Changes to the Terms of this Notice
We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.
QUESTIONS OR COMPLAINTS.
If you have any questions regarding this Notice or wish to receive additional information about our privacy practices, please contact our Privacy Officer who can be reached by calling 215-371-1800. If you believe your privacy rights have been violated, you may file a complaint with our Privacy Officer or with the Office of Civil Rights in the U.S. Department of Health and Human Services. To file a complaint with our Organization, contact our Privacy Officer at 215-371-1800, or by mail at Abramson Senior Care, 5 Sentry Parkway East, Suite 100, Blue Bell, PA.
We may request that complaints be submitted in writing. You will not be penalized or retaliated against for filing a complaint.
