Project Open Hand Atlanta. Health Insurance Portability and Accountability Act (HIPAA) NOTICE OF PRIVACY PRACTICES

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1 Prject Open Hand Atlanta Effective Date: April 14, 2003 Health Insurance Prtability and Accuntability Act (HIPAA) The Health Insurance Prtability and Accuntability Act f 1996 (HIPAA) directs health care prviders, payers and ther health care entities t develp a cmprehensive regulatry structure, including cmprehensive privacy standards t safeguard access t and disclsure f prtected health infrmatin (PHI). While Prject Open Hand Atlanta has always maintained plicies that prtect the privacy f ur client s persnal health infrmatin, the federal gvernment has enacted a new set f rules in assciatin with HIPAA that frmalizes the ntificatin f privacy practices fr all clients served by Prject Open Hand Atlanta. NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSES AND HOW YOU MAY GAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW CAREFULLY. Prtected Health Infrmatin (PHI) is any infrmatin that identifies the past, present r future physical r mental health f an individual and includes electrnic, written r verbal cmmunicatins. Wh Will Fllw This Ntice This ntice describes Prject Open Hand Atlanta s privacy practices and that f: All departments and units f Prject Open Hand and any member f a vlunteer grup we allw t help yu while yu are a client f Prject Open Hand. All emplyees, staff, and ther Prject Open Hand persnnel authrized t enter infrmatin int yur patient chart r medical recrd, including independent and third-party utside cntractrs. All Prject Open Hand entities, sites and lcatins fllw the terms f this ntice. In additin, these entities, sites and lcatins may share prtected health infrmatin with each ther fr the purpse f prviding fd r nutritin services. Our Prmise Regarding Medical Infrmatin We understand that medical infrmatin abut yu and yur health is persnal. We are cmmitted t prtecting health infrmatin abut yu. In certain specific circumstances, pursuant t either client authrizatin r applicable laws and regulatins, PHI can be disclsed t ther parties. Belw are the categries describing these uses and disclsures, alng with sme examples t help yu better understand each categry. In additin, we als describe yur rights and certain bligatins we have regarding the use and disclsure f PHI.

2 We are required by law t: Make sure that PHI that identifies yu is kept private; Give yu this ntice f ur legal duties and privacy practices with respect t PHI abut yu ; and Fllw the terms f the ntice that are currently in effect. HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMAITION ABOUT YOU. The fllwing infrmatin describes different ways that we may use and disclse PHI. Nt every use r disclsure in a categry will be listed; hwever, all f the ways we are permitted t use and disclse infrmatin will fall with in ne f the categries. Fr nutritin assessment and cunseling purpses. We may use PHI abut yu t prvide yu with an apprpriate nutritin assessment and cunseling sessins relevant t yur needs. Staff dietitians may need t knw if yu have diabetes befre beginning a nutritin cunseling sessin Staff dietitians may need t knw if yu have diabetes r ther nutritin related diseases befre determining apprpriate diet type. Fr Delivery and distributin purpses. We may use PHI abut yu t ensure that the apprpriate meal type is delivered. Distributin staff may need t knw what therapeutic diet type yu receive when encding the rute fr vlunteers t deliver Fr Health Care Operatins. We may use and disclse PHI abut yu fr Prject Open Hand Operatins. These uses and disclsures are necessary t the peratin f the rganizatin and t make sure that all f ur clients receive quality care. T review ur services and t evaluate the perfrmance f ur staff in caring fr yu; T decide what additinal services shuld be ffered, what services are nt needed and whether certain new services are effective, we may cmbine PHI abut ur Prject Open Hand Clients. We may remve infrmatin that identifies yu frm this set f PHI s thers may use it t study meal and nutritin service with ut learning wh the specific clients are; r T disclse infrmatin t dctrs, nurses, dietitians, r ther persnnel fr review and learning purpses Appintment Reminders and Fllw-up Calls. We may use yur PHI t cntact yu as a reminder that yu have an appintment with the dietitian in yur hme r ther service. If yu have an answering machine we may leave a message. Treatment Alternatives. We may use and disclse PHI t tell yu abut r recmmend pssible treatment ptins r alternatives that may be f interest t yu. Health Related Benefits and Services. We may use and disclse PHI t tell yu abut healthrelated benefits r services that may be f interest t yu.

3 Individuals Invlved in Yur Care r Reimbursement fr Yur Care We may release PHI abut yu t T a friend r family member wh is invlved in yur medical care T smene wh helps with reimbursement fr yur care Research Under certain circumstances, we may use and /r disclse PHI abut yur fr medical research purpses. As Required By Law We will disclse PHI abut yu when required t d s by federal, state r lcal law. T Avert a Serius Threat t Health r Safety. We may use and disclse PHI abut yu when necessary t prevent a serius threat t yur health and safety r the health and safety f the public r anther persn. Any disclsure, hwever wuld nly be t smene able t prevent the threat SPECIAL SITUATIONS Public Health Risks. We may use r disclse PHI abut yu fr public health activities. These activities generally include the fllwing T prevent r cntrl disease, injury r disability T reprt births and deaths T reprt child abuse and r neglect T reprt reactins t medicatin r prblems with prducts T ntify peple f recalls f prducts they may be using T ntify a persn wh may have been expsed t a disease r may be at risk fr cntractin r spreading a disease r cnditin as authrized by law T ntify the apprpriate gvernment authrity if we believe a client has been the victim f abuse, neglect r dmestic vilence. Health Oversight Activities. We may disclse PHI t a health versight agency fr activities authrized by law. These versight activities include, fr example audits, investigatins, inspectins, licensure r disciplinary actins. These activities are necessary fr the gvernment t mnitr the health care systems, gvernment prgrams, and cmpliance with civil rights laws. Lawsuits and Disputes. If yu are invlved in a lawsuit r dispute, we may disclse PHI abut yu in respnse t a curt r administrative rders subpena, discvery request r ther lawful prcess. Law Enfrcement. We may release PHI abut yu if asked t d s by a law enfrcement fficial: In respnse t a curt rder, subpena, warrant, summns, r similar prcess; T identify r lcate a suspect, fugitive, material witness, r missing persn; Abut the victim f a crime if, under certain limited circumstances, we are unable t btain the persn s agreement; Abut a death we believe may be the result f criminal cnduct; Abut criminal cnduct at Prject Open Hand Atlanta; and In emergency circumstances t reprt a crime; the lcatin f the crime r victims; r the identity, descriptin r lcatin f the persn wh cmmitted the crime. Crners, Medical Examiners, and Funeral Directrs. We may release PHI t a crner r medical examiner fr the purpse f identifying a dead persn, determining a cause f death r therwise as necessary t enable these parties t carry ut their duties cnsistent with applicable law. Natinal Security and Intelligence Activities. We may release PHI abut yu t authrized federal fficials fr intelligence, cunterintelligence, and ther natinal security activities authrized by law.

4 YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION AOBUT YOU. THESE RIGHTS ARE EFFICTIVE APRIL 14, 2003 Right t Request Restrictin. Yu may request that we restrict the use and disclsure f yur PHI. We are nt required t agree t any restrictins yu request, but if we d, we will be bund by the restrictins t which we agree except in emergency situatins. Right t Inspect and Obtain a Cpy. Yu have the right t inspect and cpy PHI that may be used t make decisins abut yur care. This includes PHI that we may have fr up t 6 years prir t yur request. T inspect and cpy PHI that may be used t make decisins abut yu, yu must submit yur request in writing t Prject Open Hand Atlanta. If yu request a cpy f the infrmatin, we will charge a fee fr the csts f cpying, mailing r ther supplies assciated with yur request. Within thirty (30) days f receiving yur request we will infrm yu f the extent t which yur request has r has nt been granted. We may deny yur request t inspect and cpy in certain limited circumstances. If yu are denied access t PHI, yu may request that the denial be reviewed. Anther licensed health care prfessinal chsen by Prject Open Hand will review yur request and the denial. The persn cnducting the review will nt be the persn wh denied yur request. We will cmply with the utcme f the review. Right t Amend. If yu feel that the PHI we have abut yu is incrrect, yu may ask us t amend the infrmatin. Yu have the right t request an amendment fr as lng as the infrmatin is kept by r fr Prject Open Hand. T request and amendment, yur request must be made in writing and submitted t Prject Open Hand Cmpliance Officer 176 Ottley Drive Atlanta GA, but may nt include dates befre April In additin, yu must prvide a reasn that supprts yur request. Within sixty (60) days f receiving yur request, we will infrm yu f the extent t which yur request has r has nt been granted. We may deny yur request fr an amendment if it is nt in writing r des nt include a reasn t supprt the request. In additin, we may deny yur request if yu ask t amend infrmatin that: Was nt created by us, unless the persn r entity that created the infrmatin is n lnger available t make the amendment; Is nt part f the PHI kept by r fr Prject Open Hand Atlanta Is nt part f the infrmatin which yu wuld be permitted t inspect and cpy; r Is accurate and cmplete. If yur request is denied, we will prvide a written denial that explains the reasn fr the denial and yur rights t: File a statement disagreeing with the denial; r If yu d nt file a statement f disagreement, submit a request that any future disclsures f the relevant PHI be made with a cpy f yur request and Prject Open Hand s Denial attached; and Cmplain abut the denial.

5 Right t an Accunting f Disclsures. Yu have the right t request a list f the disclsures we made f PHI abut yu fr disclsures ther than treatment, payment r health care peratins, disclsures made at yur request, disclsures made t persns invlved in yur health care, disclsures made fr natinal security r intelligence purpses r disclsures mad t crrectinal institutins r law enfrcement fficials. T request this list r accunting f disclsures, yu must submit yur request in writing t Prject Open Hand Cmpliance Officer 176 Ottley Drive Atlanta GA, Yur request must state a time perid, which may nt be lnger than six years and may nt includes dates befre April 14, Yur request shuld indicate in what frm yu want the list (fr example, n paper, electrnically). Within sixty (60) days f receiving yur request, we will respnd t yu regarding the status f yur request. The first list yu request with in a 12- mnth perid will be free. Fr additinal lists, we may charge yu fr the csts f prviding the list. We will ntify yu f the cst invlved and yu may chse t withdraw r mdify yur request at that time befre any csts are incurred. Right t Request Restrictins. Beginning April , yu have the right t request a restrictin r limitatin n the PHI we use r disclse abut yu fr treatment, reimbursement r health care peratins. Yu als have the right t request a limit n the PHI we disclse abut yu t smene wh is invlved in yur care r the reimbursement fr yur care, like a family member r friend. Fr example, yu culd ask that we nt use r disclse infrmatin abut a surgery yu had. We are nt required t agree t yur request. If we d agree, we will cmply with yur request unless the infrmatin is needed t prvide yu emergency treatment. T request restrictins yu must make yur request in writing t Prject Open Hand Cmpliance Officer 176 Ottley Drive Atlanta GA, In yur request yu must tell us (1) what infrmatin yu want t limit; (2) whether yu want t limit ur use, disclsure r bth; and (3) t whm yu want the limits t apply, fr example disclsure t yur spuse. Right t Request Cnfidential Cmmunicatins. Beginning April 14, 2003 yu have the right t request that we cmmunicate with yu abut medical matters in a certain way r at certain lcatin. Fr example, yu can ask that we nly cntact yu at wrk r by mail. T request cnfidential cmmunicatins, yu must make yur request in writing t Prject Open Hand Atlanta Cmpliance Officer at 176 Ottley drive Atlanta GA, Right t a Paper Cpy f this Ntice. Even if yu have agreed t receive this ntice electrnically yu have the right t a paper cpy f this ntice, which yu may ask fr at any time. Yu may btain a cpy f this ntice at ur website, T btain a paper cpy f this ntice, write t Prject Open Hand Cmpliance Officer 176 Ottley Drive Atlanta GA, Changes t this ntice We reserve the right t change this ntice. We reserve the right t make the revised r changed ntice effective fr PHI we already have abut yu as well as any infrmatin we receive in the future. We will pst a cpy f the current ntice. The ntice will cntain the effective date n the first page, in the tp right hand crner.

6 Cmplaints If yu believe yur privacy rights have been vilated, yu may file a cmplaint with Prject Open Hand r with the Secretary f the Department f Health and Human Services. T file a cmplaint with Prject Open Hand Atlanta, cntact the Prject Open Hand Cmpliance Officer, 176 Ottley Dr, Atlanta GA, All cmplaints must be submitted in writing. TO discuss the matter prir t submitting the cmplaint in writing, call the Prject Open Hand Cmpliance Officer at Cmplaints made t the Secretary f the Department f Health and Human Services must be filed within 180 days f when the cmplainant knew r shuld have knw that the vilatin r missin ccurred unless the time limit is waived by the Secretary fr demnstrated gd cause. Yu will nt be penalized fr filing a cmplaint. OTHER USES OF PROTECTED HEALTH INFORMATION Other uses and disclsures f prtected health infrmatin nt cvered by this ntice r the laws that apply t us will be made nly with yur written permissin If yu prvide us permissin t use r disclse PHI abut yu, yu may revke that permissin, in writing, at any time by mailing the revcatin t Prject Open Hand Atlanta Cmpliance Officer, 176 Ottley Dr. Atlanta GA If yu revke yur permissin, we will n lnger use r disclse PHI abut yu fr the reasns cvered by yur written authrizatin. Yu understand that we are required t retain ur recrds f the care that we prvide t yu.

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