Notice of Privacy Practices
Effective Date: September 1, 2003
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.
If you have any questions about this notice, please contact the Renown Health System Privacy Office at (775) 982-8300 or Hometown Health Customer Service at 775-982-3232 or 800-336-0123.
WHO WILL FOLLOW THIS NOTICE.
This notice describes the practices of the Renown Health and Hometown Health Plan entities, including but not limited to:
HHP Management Corporation, Inc., (collectively referred to as “Hometown Health”) healthcare operations including:
- Hometown Health Plan, Inc.
- Hometown Health Providers Insurance Company
- Senior Care Plus
- Renown Medical Group (at Ryland, South Meadows, and Vista)
- The Healthcare Center Clinic (professional services)
- Renown Medical Group Seniors (professional services)
Renown Regional Medical Center
Renown South Meadows Medical Center healthcare operations including:
- Renown South Meadows Medical Center
- Renown Rehabilitation Hospital
- Renown Rehabilitation Therapy
- Renown Skilled Nursing
Renown Health healthcare operation including:
- The Pregnancy Center
- X-Ray and Imaging
- Breast Health Center
Renown Professional Center, Inc., healthcare operations including:
- Professional Center Pharmacy
- HealthWear Plus
- Northern Sierra Dialysis Center, LLC
Provider Network, Inc., healthcare operations including:
- Renown Medical Group (at Fernley)
- Renown Medical Group Pediatrics
- Community Care Services, LLC
Urgent Care, LLC
- Urgent care (at Fernley, Ryland, South Meadows, and Vista)
Carson Valley Medical Center, a partnership with Barton Health.
And those of:
- Any health care professional authorized to enter information into your medical chart at one of the above-referenced entities.
- All departments and units of the above-referenced entities.
- Any member of a volunteer group, including the Renown Medical Auxiliary, that we allow to help you while you are in any of the above-referenced facilities.
- All employees, staff and other personnel of the above-described entities.
For purposes of this notice, the above-referenced Hometown Health entities, sites and locations will be referred to in this notice as “Hometown Health.” For purposes of this notice, the above-referenced Renown entities, sites and locations will be referred to in this notice as the “health network.” The Renown Health and Hometown Health entities follow the terms of this notice. In addition, Hometown Health and the health network may share medical information with each other for treatment, payment or hospital operations purposes described in this notice.
OUR PLEDGE REGARDING MEDICAL INFORMATION:
We understand that medical information about you and your health is personal. We are committed to protecting medical information about you. We create a record of your benefits and eligibility status and claims history at Hometown Health and the care and services you receive at the Renown Health entities. We need this record to provide you with quality care and healthcare benefits to comply with certain legal requirements. This notice applies to all of the records of your healthcare benefits and care generated by Hometown Health and the Renown Health entities, whether made by the Hometown Health or Renown entity personnel or your personal doctor. Hospitals, physicians and other healthcare providers providing healthcare services to
Hometown Health members may have different policies or notices regarding their uses and disclosures of your medical information.
This notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.
We are required by law to:
- make sure that medical information that identifies you is kept private;
- give you this notice of our legal duties and privacy practices with respect to medical information about you; and
- follow the terms of the notice that is currently in effect.
INFORMATION ABOUT OUR MEMBERS
In the course of providing healthcare benefits, we may receive the following information about you:
- Information provided by you on applications, forms, surveys and our Web site, such as your name, address, date of birth, Social Security number, gender, marital status and dependents.
- Information provided by your employer, benefits plan sponsor or association regarding any group product you may have.
- Information about your transactions and experiences with our health plan and our affiliates, such as: services purchased, account balances, payment history, claims history, policy coverage and premiums.
- Information from consumer or medical reporting agencies, medical providers or third parties, such as medical information and demographic information.
HOW WE PROTECT YOUR MEDICAL INFORMATION
At Hometown Health, we restrict access to your medical information to those employees who need it to provide services to you and your dependents. We maintain physical, electronic and procedural safeguards to protect your medical information against unauthorized access and use.
For example, access to our facilities is limited to authorized personnel, and we protect information we maintain electronically through the use of a variety of technical tools. We have also established a Privacy Office, which has overall responsibility for developing, educating company personnel about, and overseeing the implementation of policies and procedures to safeguard medical information against inappropriate access, use and disclosure, consistent with applicable law.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU.
The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways that we are permitted to use and disclose information will fall within one of the categories.
Hometown Health will not disclose your medical information to anyone, except with your authorization or otherwise as permitted by law. For some activities, we must have your written authorization to use or disclose your medical information. The law, however, permits Hometown Health to use or disclose your medical information for the following purposes without your authorization:
- For Payment. Hometown Health may use and disclose your medical information in order to pay for your medical benefits under our health plan. These activities may include making benefit determinations and paying claims. Renown Health may use and disclose medical information about you so that the treatment and services you receive at the Renown Health entities may be billed to, and payment may be collected from, you, an insurance company or a third party. For example, Renown Health may need to give your health plan information about surgery you received at Renown Regional Medical Center so that Hometown Health will pay or reimburse you for the surgery. Renown Health may also tell Hometown Health about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
- For Health Care Operations. Hometown Health may use and disclose medical information about you for health plan operations. These uses and disclosures are necessary to run the health plan and make sure that all of our members receive quality benefits and customer service. Here are some examples of the ways that we use your medical information for our healthcare operations:
- Quarterly newsletters that offer members information on various healthcare issues such as asthma, diabetes, and breast cancer.
- Administration of Hometown Health health plans or contracts, which, where applicable, may involve claims management; utilization review and management; data and information systems management; medical necessity review; coordination of care, benefits and services; response to member inquiries or requests for services; conduct of grievances, appeals and external review programs; benefits and program analysis and reporting; risk management; detection and investigation of fraud and other unlawful conduct; auditing; underwriting and ratemaking; and other activities described below.
- Operation of disease and case management programs in plans that offer these programs, through which we or our contractors perform risk and health assessments; identify and contact members who may benefit from participation in disease or case management programs; and send relevant information to those members who enroll in the programs and their providers.
- Quality assessment and improvement activities, such as peer review and credentialing of participating providers; program development; and accreditation by independent organizations, where applicable.
- If we are providing health benefits to you as a beneficiary of an employer-sponsored group health plan, we may disclose your Protected Health Information to the sponsor of the plan.
- Transitioning of policies or contracts from and to other health plans.
- Hometown Health may disclose your medical information to another entity that has a relationship with you and is subject to the federal privacy laws, for their healthcare operations relating to quality assessment and improvement activities, reviewing the competence and qualifications of healthcare professionals, or detecting or preventing healthcare fraud and abuse.
- Renown Health may use and disclose medical information about you for health care operations. These uses and disclosures are necessary to run the Renown Health entities and make sure that all of their patients receive quality care. For example, Renown Health may use medical information to review their treatment and services and to evaluate the performance of their staff in caring for you. Renown Health may also combine medical information about many hospital patients to decide what additional services the hospital should offer, what services are not needed, and whether certain new treatments are effective. Renown Health may also disclose information to doctors, nurses, technicians, medical students and other hospital personnel for review and learning purposes. Renown Health may also combine the medical information they have with medical information from other hospitals to compare how they are doing and see where they can make improvements in the care and services they offer. Renown Health may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.
- To Your Family and Friends. Hometown Health may disclose your medical information to a family member, friend or other person to the extent necessary to help with your healthcare or payment for your healthcare. Before we disclose your medical information to a person involved in your healthcare or payment for your healthcare, we will provide you with an opportunity to object to such uses and disclosures. If you are not present, or in the event of your incapacity or an emergency, we will disclose your medical information based on our professional judgment of whether the disclosure would be in your best interest.
- For Treatment. Renown Health may use medical information about you to provide you with medical treatment or services. Renown Health may disclose medical information about you to doctors, nurses, technicians, medical students or other Renown Health entity personnel who are involved in taking care of you at the Renown Health entity. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals. Different departments of a Renown Health entity also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. Renown Health also may disclose medical information about you to people outside of the Renown Health entities who may be involved in your medical care after you leave their care, such as family members, clergy or others Renown Health use to provide services that are part of your care.
- Appointment Reminders. Renown Health may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care.
- Treatment Alternatives. Renown Health may use and disclose medical information to tell you about or recommend alternative treatments, therapies, health care providers or care settings that may be of interest to you.
- Health Care Providers and Services. Renown Health may use and disclose medical information to tell you about affiliated health care providers and health care services that they provide that may be of interest to you.
- Fundraising Activities. Renown Health may use medical information about you to contact you in an effort to raise money for the hospital and its operations. Renown Health may disclose medical information to Renown Health Foundation, a foundation related to the hospital, so that the foundation may contact you in raising money for the hospital. Renown Health only would release contact information, such as your name, address and phone number and the dates you received treatment or services at the hospital. If you do not want the hospital to contact you for fundraising efforts, you must notify the Renown Health System Privacy Officer at 1155 Mill Street, Mail Code Z-7, Reno, Nevada 89502-1474 in writing.
- Hospital Directory. Renown Health may include certain limited information about you in the hospital directory while you are a patient at the hospital. This information may include your name, location in the hospital, your general condition (for example, fair, stable, etc.) and your religious affiliation. Unless there is a specific written request from you to the contrary, this directory information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they don't ask for you by name. This information is released so your family, friends and clergy can visit you in the hospital and generally know how you are doing.
- Individuals Involved in Your Care or Payment for Your Care. Renown Health may release medical information about you to a friend or family member who is involved in your medical care. Renown Health may also give information to someone who helps pay for your care. Unless there is a specific written request from you to the contrary, Renown Health may also tell your family or friends your condition and that you are in the hospital. In addition, Renown Health may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.
- Research. Under certain circumstances, Renown Health may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with patients' need for privacy of their medical information. Before Renown Health uses or discloses medical information for research, the project will have been approved through this research approval process, but they may, however, disclose medical information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the medical information they review does not leave the hospital. Renown Health will almost always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at the hospital.
- As Required By Law. Hometown Health and Renown Health will disclose medical information about you when required to do so by federal, state or local law. We must also share your medical information with authorities that monitor our compliance with privacy laws.
- To Avert a Serious Threat to Health or Safety. Hometown Health and Renown Health may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
- Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
- Public Health Risks. Hometown Health and Renown Health may disclose medical information about you for public health activities. These activities generally include the following:
- to prevent or control disease, injury or disability;
- to report births and deaths;
- to report the abuse or neglect of children, elders and dependent adults;
- to report reactions to medications or problems with products;
- 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; and
- to notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
- Organ and Tissue Donation. If you are an organ donor, Renown Health may release medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.
- Health Oversight Activities. Hometown Health and Renown Health may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, 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, Hometown Health and Renown Health may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request (which may include written notice to you) or to obtain an order protecting the information requested.
- Law Enforcement. Hometown Health and Renown Health may release medical information if asked to do so by a law enforcement official:
- 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 limited 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 at the hospital; or
- 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.
- Disaster Relief. Hometown Health and Renown Health may use or disclose your medical information to a public or private entity authorized by law or by its charter to assist in disaster relief efforts.
- Nevada Attorney General and Grand Jury Investigations. Hometown Health and Renown Health may release medical information if asked to do so by an investigator for the Nevada Attorney General, or a grand jury, investigating an alleged violation of Nevada laws prohibiting patient neglect, elder abuse or submission of false claims to the Medicaid program. We may also release medical information to an investigator for the Nevada Attorney General investigating an alleged violation of Nevada workers’ compensation laws.
- National Security and Intelligence Activities. Hometown Health and Renown Health may release medical information about you to authorized federal officials for intelligence, counterintelligence and other national security activities authorized by law.
- Protective Services for the President and Others. Hometown Health and Renown Health may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
- Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, Hometown Health and Renown Health may release medical information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.
- Workers' Compensation. Hometown Health and Renown Health may release medical information about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.
- Coroners, Medical Examiners and Funeral Directors. Renown Health may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. Renown Health may also release medical information about patients of the hospital to funeral directors as necessary to carry out their duties.
YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU.
You have the following rights regarding medical information we maintain about you:
- Right to Inspect and Copy. You have the right to inspect and copy medical information that may be used to make decisions about your healthcare benefits and care. Usually, this includes benefits, eligibility claims, medical and billing records, but may not include some mental health information. To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to Hometown Health Customer Service, 830 Harvard Way, Reno, NV 89502 or the Renown Health System health care provider that provided the care that is the subject of your request. 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. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by the health plan or hospital will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.
- Right to Amend. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for Hometown Health or Renown Health. To request an amendment, your request must be made in writing and submitted to Hometown Health Customer Service, 830 Harvard Way, Reno, NV 89502 or the Renown Health System Privacy Officer at 1155 Mill Street, Mail Code Z-7, Reno, Nevada 89502-1474. In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
- Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
- Is not part of the medical information kept by or for Hometown Health or Renown Health;
- Is not part of the information which you would be permitted to inspect and copy; or
- Is accurate and complete.
- Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures we made of medical information about you other than our own uses for treatment, payment and health care operations, as those functions are described above, or to you based upon your authorization and for certain government functions. To request this list or accounting of disclosures, you must submit your request in writing to Hometown Health Customer Service, 830 Harvard Way, Reno, NV 89502 or the Renown Health System Privacy Officer at 1155 Mill Street, Mail Code Z-7, Reno, Nevada 89502-1474. Your request must state a time period that may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. 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.
- Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information Hometown Health or Renown Health uses or discloses about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had. Hometown Health and Renown Health are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment. To request restrictions, you must make your request in writing to Hometown Health Customer Service, 830 Harvard Way, Reno, NV 89502 or the Renown Health System Privacy Officer at 1155 Mill Street, Mail Code Z-7, Reno, Nevada 89502-1474. 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 your spouse).
- Right to Request Confidential Communications. You have the right to request that Hometown Health and Renown Health communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to Hometown Health Customer Service, 830 Harvard Way, Reno, NV 89502 or the Renown Health System Privacy Officer at 1155 Mill Street, Mail Code Z-7, Reno, Nevada 89502-1474. 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.
- Right to a Paper Copy of This Notice. You have the right to 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 website, www.hometownhealth.com or www.renown.org. To obtain a paper copy of this notice, contact Customer Service at 775-982-3232 or 800-336-0123 or your Renown Health health care provider.
CHANGES TO THIS NOTICE
Hometown Health and Renown Health reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice on the Hometown Health Website at www.hometownhealth.com and in the hospital. The notice will contain on the first page, in the top right-hand comer, the effective date. In addition, each time you enroll in a Hometown Health plan and each time you register at or are admitted to the hospital for treatment or health care services as an inpatient or outpatient, we will offer you a copy of the current notice in effect. We also may publish the current notice in the Hometown Health newsletter on at least an annual basis.
If you believe your privacy rights have been violated, you may file a complaint with Hometown Health, Renown Health or with the Secretary of the Department of Health and Human Services. To file a complaint with Hometown Health, contact Hometown Health Customer Service at 775-982- 3232 or 800-336-0123. To file a complaint with Renown Health, contact the Renown Health Privacy Officer, 1155 Mill Street, Mail Code Z-7, Reno, Nevada 89502-1474, (775) 982-8300. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
OTHER USES OF MEDICAL INFORMATION.
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us permission to use or disclose medical information about you by signing an authorization, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.