NOTICE OF PRIVACY PRACTICES

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.

The terms of this Notice of Privacy Practices apply to Crystal Clinic Orthopaedic Center, Crystal Clinic Inc., any entities or facilities owned by or affiliated with Crystal Clinic Orthopaedic Center and the Medical Staff and their dependent practitioners (collectively referred to as “Crystal Clinic Orthopaedic Center”). These entities and people operate together as a clinically integrated health care arrangement. This clinically integrated health care arrangement includes our main facility and remote offices and clinics, and all of our programs, services, departments and units within our health care facilities. Crystal Clinic Orthopaedic Center is made up of many people such as our doctors, physician assistants, nurses, therapists, specialists, other health care professionals permitted by us to provide services to you, and staff, students, residents, trainees, volunteers and others involved in providing your care and services. These entities and people will share personal, protected health information of patients as necessary to carry out treatment, payments and health care operations as permitted by law.

Crystal Clinic Orthopaedic Center is required by law to maintain the privacy of our patients’ personal, protected health information and to provide patients with notice of our legal duties and privacy practices with respect to your personal, protected health information. We are required to notify you if there is a breach of your unsecured protected health information. We are required to abide by the terms of this Notice so long as it remains in effect. We reserve the right to change the terms of this Notice of Privacy Practices as necessary and to make the new Notice effective for all personal, protected health information maintained by us. You may receive a copy of any revised Notice at any Crystal Clinic Orthopaedic Center point of registration or a copy may be obtained by mailing a request to the Privacy Officer of Crystal Clinic Orthopaedic Center at 3925 Embassy Parkway, Suite 250, Akron, OH 44333.USES AND DISCLOSURES OF YOUR PERSONAL PROTECTED HEALTH INFORMATION

Your Authorization. Except as outlined below, we will not use or disclose your personal, protected health information for any purpose unless you have signed a form authorizing the use or disclosure. Most uses and disclosures of your health information for marketing purposes and disclosures that constitute a sale of your health information require your authorization. You have the right to revoke that authorization in writing unless we have taken any action in reliance on thatthe authorization.

Your Authorization. Except as outlined below, we will not use or disclose your personal, protected health information for any purpose unless you have signed a form authorizing the use or disclosure. Most uses and disclosures of your health information for marketing purposes and disclosures that constitute a sale of your health information require your authorization. You have the right to revoke that authorization in writing unless we have taken any action in reliance on the authorization.

Uses and Disclosures for Treatment. We will make uses and disclosures of your personal, protected health information as necessary for your treatment. For instance, doctors, nurses and other professionals involved in your care will use information in your medical record and information that you provide about your symptoms and reactions to plan a course of treatment for you that may include procedures, medications, tests, etc. We may also release your personal, protected health information to another health care facility or professional who is not affiliated with our organization but who is or will be providing treatment to you. For instance, if, after you leave the surgery center, you are going to receive home health care, we may release your personal, protected health information to that home health care agency so that a plan of care can be prepared for you. We may also participate in electronic health information exchanges that facilitate access to personal, protected health information by other health care providers who provide you care. For example, if you receive care from another provider that participates in the health information exchange, this exchange will allow us to make your personal protected health information available to the provider as needed for your treatment.

Uses and Disclosures for Payment. We will make uses and disclosures of your personal, protected health information as necessary for the payment purposes of those health professionals and facilities that have treated you or provided services to you. For instance, we may forward information regarding your medical procedures and treatment to your insurance company to arrange payment for the services provided to you or we may use your information to prepare a bill to send to you or to the person responsible for your payment.

Uses and Disclosures for Health Care Operations. We will use and disclose your personal protected health information as necessary and as permitted by law, for our health care operations that include clinical improvement, professional peer review, business management, accreditation and licensing, etc. For instance, we may use and disclose your personal, protected health information for purposes of improving the clinical treatment and care of our patients. We may disclose protected health information to doctors, nurses, technicians, medical students, volunteers and other persons for review and learning purposes and for the operation of educational programs. We may also disclose your personal, protected health information to another health care facility, health care professional, or health plan for such things as quality assurance and case management, but only if that facility, professional, or plan also has or had a patient relationship with you.

Our Patient Directory. Crystal Clinic Orthopaedic Center maintains a patient directory listing the name, room number, general condition and, if you wish, your religious affiliation. Unless you choose to have your personal, protected health information excluded from this directory, the information, excluding your religious affiliation, will be disclosed to anyone who requests it by asking for you by name. This information, including your religious affiliation, may be also provided to members of the clergy. You have the right during registration to have your information excluded from this directory.

Family and Friends Involved in Your Care. With your approval, we may disclose your personal, protected health information to designated family, friends, and others who are involved in your care or in payment of your care in order to facilitate that person’s involvement in caring for you or paying for your care. If you are unavailable, incapacitated, or facing an emergency medical situation, and we determine that a limited disclosure may be in your best interest, we may share limited personal, protected health information with such individuals without your approval. We may also disclose limited personal, protected health information to a public or private entity that is authorized to assist in disaster relief efforts in order for that entity to locate a family member or other persons that may be involved in some aspect of caring for you.

Business Associates. Certain aspects and components of our services are performed through contracts with outside persons or organizations such as auditing, accreditation, legal services, etc. At times it may be necessary for us to provide some of your personal, protected health information to one of or more of these outside persons or organizations who assist us with our health care operations. In all cases, we require these business associates to appropriately safeguard the privacy of your information.

Fundraising. We may contact you to donate to a fundraising effort for or on our behalf. You have the right to “opt-out” of receiving fundraising materials or communications and may do so by sending your name and address to the Privacy Officer of Crystal Clinic Orthopaedic Center at 3925 Embassy Parkway, Suite 250, Akron, OH 44333 together with a statement that you do not wish to receive fundraising materials or communications from us.

Appointments and Services. We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. You have the right to request and we will accommodate reasonable requests by you to receive communications regarding your personal, protected health information from us by alternative means or at alternative locations. For instance, if you wish appointment reminders not to be left on voice mail or sent to a particular address, we will accommodate reasonable requests. You may request such confidential communication in writing and may send your request to the Privacy Officer of Crystal Clinic Orthopaedic Center at 3925 Embassy Parkway, Suite 250, Akron, OH 44333.

Health Products and Services. We may from time to time use your personal, protected health information to communicate with you about health products and services necessary for your treatment, to advise you of new products and services we offer, and to provide general health and wellness information.

Research. In limited circumstances, we may use and disclose your personal, protected health information for research purposes. For example, a researcher may wish to compare outcomes of all patients that received a particular drug and will need to review a series of medical records. In all cases where your specific authorization is not obtained, your privacy will be protected by strict confidentiality requirements applied by an Institutional Review Board that oversees the research, or by representations of the researchers that limit their use and disclosure of patient information.

Other Uses and Disclosures. We are permitted or required by law to make certain other uses and disclosures of your personal, protected health information without your authorization. We may release your personal, protected health information:

• For any purpose required by law;

• For public health activities, such as required reporting of disease, injury, and birth and death, and for required public health investigations;

• As required by law if we suspect child abuse or neglect; we may also release your personal, protected health information as required by law if we believe you to be a victim of abuse, neglect, or domestic violence;

• To the Food and Drug Administration if necessary to report adverse events, product defects, or to participate in product recalls;

• To your employer when we have provided health care to you at the request of your employer; in most cases you will receive notice that information is disclosed to your employer;

• If required by law to a government oversight agency conducting audits, investigations, or civil or criminal proceedings;

• If required to do so by a court or administrative ordered subpoena or discovery request; in most cases you will have notice of such release;

• To law enforcement officials as required by law to report wounds and injuries and crimes;

• To coroners, medical examiners, and/or funeral directors consistent with the law;

• If necessary to arrange an organ or tissue donation from you or a transplant for you;

• If you are a member of the military as required by armed forces services; we may also release your personal, protected health information if necessary for national security or intelligence activities;

• To workers’ compensation agencies if necessary for your workers’ compensation benefit determination.RIGHTS THAT YOU HAVE

Access to Your Personal, Protected Health Information. You have the right to receive a copy and/or inspect much of the personal, protected health information that we retain on your behalf. All requests for access must be made in writing and signed by you or your representative. We will charge you a reasonable fee if you request a copy of the information. We may also charge for postage if you request a mailed copy. Patients or their legal representatives may request access to their personal, protected health information by completing the Authorization for Release of Information Form. This Form is available from Health Information Management or the Patient Accounts Department.

Amendments to Your Personal, Protected Health Information. You have the right to request in writing that personal, protected health information that we maintain about you be amended or corrected. We are not obligated to make all requested amendments but will give each request careful consideration. All amendment requests, in order to be considered by us, must be in writing, signed by your or your representative, and must state the reasons for the amendment/correction request. If we make an amendment or correction that you request, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary. Amendment request forms may be obtained from Health Information Management.

Accounting for Disclosures of Your Personal, Protected Health Information. You have the right to receive an accounting of certain disclosures made by us of your personal, protected health information after May 2009. Requests must be made in writing and signed by you or your representative. Accounting request forms are available from Health Information Management.

The first accounting in any 12-month period is free; you will be charged a reasonable fee for each subsequent accounting you request within the same 12-month period.

Restrictions on Use and Disclosure of Your Personal, Protected Health Information. You have the right to request restrictions on certain uses and disclosures of your personal, protected health information for treatment, payment, or health care operations by contacting the Privacy Officer. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate. There is one exception: We must agree to your restriction request if you ask us not to disclose information related to a health care item or service to your health plan for the purposes of payment or health care operations when you have paid for the health care item or service out of pocket in full. We retain the right to terminate an agreed-to restriction if we believe such termination is appropriate. In the event of a termination by us, we will notify you of such termination. You also have the right to terminate, in writing or orally, any agreed to restriction by sending such termination notice to the Privacy Officer of Crystal Clinic Orthopaedic Center at 3925 Embassy Parkway, Suite 250, Akron, OH 44333. Any agreed-to restriction will not limit patient directory disclosures unless you exclude yourself from the patient directory.

Complaints. If you believe your privacy rights have been violated, you can file a complaint with the Privacy Officer, Patient Liaison, or the Compliance Hotline. You may also file a complaint with the Secretary of U.S. Department of Health and Human Services in Washington, D.C. in writing within 180 days of a perceived violation of your rights. There will be no retaliation for filing a complaint.FOR FURTHER INFORMATION

If you have questions or need further assistance regarding this Notice, you may contact the Privacy Officer of Crystal Clinic Orthopaedic Center at 3925 Embassy Parkway, Suite 250, Akron, OH 44333, telephone (330) 670-6123. You may also call the Compliance Alert Line of Crystal Clinic Orthopaedic Center at (330) 670-4799.

If you have questions or need further assistance regarding this Notice, you may contact the Privacy Officer of Crystal Clinic Orthopaedic Center at 3925 Embassy Parkway, Suite 250, Akron, OH 44333, telephone (330) 670-6123. You may also call the Compliance Alert Line of Crystal Clinic Orthopaedic Center at (330) 670-4799.

As a patient you retain the right to obtain a paper copy of this Notice of Privacy Practices, even if you have requested such copy by email or other electronic means.EFFECTIVE DATE. 
This Notice of Privacy Practices is effective May 2009. 
Revised March 26, 2013.