Notice of Privacy Practices
Effective Date: March 11, 2019
This Notice of Privacy Practices describes how information about you may be used and disclosed by Neurotech and how you can gain access to this information. Please review it carefully.
This Notice of Privacy Practices describes the privacy practices of Neurotech, LLC, Neurotech Northwest, LLC and Neurotech CEEG Partners, LLC, three separate entities that have designated themselves as an affiliated covered entity (referred to herein as “Neurotech” or the “Neurotech ACE”). An affiliated covered entity (“ACE”) is a group of covered entities under common ownership and control that designate themselves as a single entity for purposes of complying with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). The members of the Neurotech ACE will share information with each other for treatment, payment and health care operations of the Neurotech ACE and as permitted by HIPAA and this Notice of Privacy Practices.
OUR PLEDGE REGARDING YOUR HEALTH INFORMATION
We understand that information about you and your health is personal. We are required by law and committed to maintaining the privacy and security of this information. Each time we provide services, we create a record of the care and services you receive. We need this record to provide quality care and to comply with certain legal requirements. This notice applies to all of your information and the records of your health care generated by us or received by us from you or others.
Along with safeguarding your personal health information, we must also make available a copy of this notice of our legal duties and privacy practices, and we must follow the terms of the notice currently in effect. We will let you know if a breach occurs that may have compromised the privacy or security of your health information. This notice will tell you about the ways in which we may use and disclose health information about you. We also describe your rights of access, amendment, control, and other rights concerning the use and disclosure of your health information. Neurotech is also required to notify you if your health information is breached.
If you are the parent, legal guardian, or personal representative of the patient, the references herein such as “…your personal health information…” shall be understood to refer to that patient.
Complaints: If you believe your privacy rights have been violated, you may file a complaint with us, directly to our Privacy Officer: Kelly Grissman, Neurotech, LLC, 626 W. Moreland Blvd., Waukesha, WI 53188. Phone number: (262) 875-6555. You can also file a complaint with the Secretary of the Department of Health and Human Services at www.hhs.gov or in writing to any regional HHS office. There will be no retaliation for filing a complaint.
HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION
The following categories describe different ways that we may USE your health information within Neurotech and DISCLOSE your health information to persons and entities outside of Neurotech. We have not listed every use or disclosure within the categories, but give some examples for understanding.
COMMON USES AND DISCLOSURES ALLOWED BY LAW
Treatment: We may use your health information to provide you treatment and health care services. We may disclose health information about you to other health care providers who are involved in your care.
Payment: We may use and disclose your health information so the treatment and services you receive at Neurotech may be billed to and payment collected from you, an insurance company or other third party. We may also disclose health information to your insurance plan to obtain prior authorization for treatment and procedures.
Health Care Operations: We may use and disclose your health information for health care operations activities such as: quality assurance; administration; the financial and business planning and development of Neurotech; and customer service (including investigation of complaints). These uses and disclosures are necessary to operate our health care practice and make sure patients receive quality care.
Business Associates: Some services may be provided to our organization through contracts with business associates, such as: accountants; consultants; quality assurance reviewers; billing and transcription services. We may disclose your health information to our business associates so that they can perform the job we’ve asked them to do. Business associates are required to sign a contract that states they will appropriately safeguard your information.
Contacting You About Your Health: We may use and disclose health information to contact you, such as a reminder about an appointment or other treatment options at Neurotech.
Individuals Involved in Your Care: We may disclose health information about you to a friend or family member who is involved in your care, unless you tell us in advance not to do so.
Other Laws: At times there may be federal, state or local laws that require us to use or disclose health information in other ways, or give you additional privacy protections. We will comply with those laws.
SPECIAL SITUATIONS WHICH DO NOT REQUIRE YOUR AUTHORIZATION
The following disclosures of your health information are permitted by law without any oral or written permission from you:
Public Health Activities: We may disclose health information about you for public health activities, including:
* 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 avert a serious threat to you or others. These disclosures would be made only to someone able to intervene.
* To notify the appropriate government authority if we believe a patient has been the victim of abuse (including child abuse), neglect or domestic violence.
* Immunization records to a school requiring such for entry, provided informal approval is given by a parent, guardian, or the patient if the patient is an adult or emancipated minor
* To Disaster Relief agencies (such as the Red Cross) for notification as to your location and condition (unless you request otherwise in advance).
* If you are an organ donor, we may release health information to the organizations that handle the process, as necessary to facilitate the donation.
Research: We may disclose your PHI for the purpose of research in certain circumstances. We will only disclose your PHI for research purposes in accordance with an authorization that you provide unless (i) the research protocol has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your health information; or (ii) where we have received assurances from a researcher that the health information is sought solely for review as necessary to prepare a research protocol or for similar purposes preparatory to research and no health information will be removed from our premises in the course of the review.
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.
Worker’s Compensation: We may release health information about you for worker’s compensation or similar programs if you have a work related injury.
Health Oversight Activities: Neurotech, LLC may disclose health information to a health oversight agency for activities authorized by law. These 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 be required to disclose your health information in response to a court order, administrative order, subpoena, discovery request or other lawful process by someone involved in the dispute.
Law Enforcement: We may disclose health information to law enforcement officials for reasons such as:
* 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 criminal conduct.
* About criminal conduct on our premises.
* 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.
Health Records of Deceased Patients: We may disclose health information to a coroner or medical examiner, to identify a deceased person or determine the cause of death. We may also release health information about patients to funeral home directors as necessary to carry out their duties. We may disclose to relatives or close personal friends who were involved with the patient’s care prior to death, health information relevant to their involvement. HIPAA privacy protections continue until 50 years after the patient’s death.
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.
Legal Requirements: We will disclose health information about you without your permission when required to do so by federal, state or local law.
OTHER USES AND DISCLOSURES REQUIRE YOUR AUTHORIZATION
Other uses and disclosures of health information not covered by this notice or applicable laws will be made only with your written permission (called “authorization”). These uses and disclosures specifically include, but are not limited to, (1) uses and disclosures of your health information for marketing purposes; (2) disclosures of your health information that constitutes a sale; (3) to the extent that we have such information in our medical records, most disclosures of psychotherapy notes, disclosures of records related to HIV/AIDS (however, we may notify health care providers at our practice on a need-to-know basis or responding emergency providers and law enforcement, if necessary), disclosures of genetic testing results, and disclosures of mental health and developmental disabilities records, unless allowed under state law.
If you do give authorization to disclose your health information, you may revoke that authorization in writing at any time.
YOUR HEALTH INFORMATION RIGHTS
You have the following rights concerning your health information:
- Request a restriction on certain uses and disclosures of your information. We may agree to your request but are not required by law to do so, with the one following exception…
- Restricting disclosures to health plan or insurance for treatment you pay for in full. If you pay in full at the time of service and request we not disclose the information to your health plan or insurer, we must and will comply.
- Obtain a copy of this Notice of Privacy Practices upon request.
- Inspect and/or request a copy of your health record. You must make the request in writing, and we have 30 days to comply.
- Request an amendment to your health record if you feel the information is incorrect or incomplete. Neurotech may deny your request if, for instance, we believe it is accurate and complete as it stands.
- Obtain an accounting of disclosures of your health information. This will include the times when someone used or disclosed your health information other than the allowed common uses and disclosures, or uses and disclosures that you authorized.
- Request communication of your health information by alternative means or locations. For instance: an address or phone number other than your home.
- Revoke a previously agreed upon authorization except to the extent that action has already been taken.
For more information contact our privacy officer: Kelly Grissman, Neurotech, LLC, 626 W. Moreland Blvd., Waukesha, WI 53188. Phone number: (262) 875-6555.
We reserve the right to change this notice, and 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. A copy of the current notice in effect will be available at Neurotech.