Keweenaw Home Nursing & Hospice (the AAgency@) may use your health information, information that constitutes protected health information as defined in the Privacy Rule of the Accountability Act of 1996, for purposes of providing you treatment, obtaining payment for your care and conducting health care operations. The Agency has established policies to guard against unnecessary disclosure of your health information.

1. Provide Treatment The Agency may use your health information to coordinate your care between the agency and its staff, your attending physician, the Hospice Interdisciplinary team members, pharmacists, suppliers of medical equipment, your designated clergy, family members and private caregivers who provide care to you at home unless specifically excluded by your request, and/or other health care professionals involved in caring for you.
   
   For example: your doctor will need information from our staff about your symptoms in order to prescribe your medications, and the pharmacist will need the doctor's order to fill the prescription.
   
   

2. Obtain payment for your care from your health insurer (Medicare, Medicaid etc) . The Agency may include information about your health care status on invoices used to collect payment.
   
   For example: the Agency may need to obtain prior approval from your insurer and may be required to explain why you need our care and what services we will provide to you.
   
   

3. Conduct health care operations of the Agency in order to facilitate its function and as necessary to provide quality care to all of the agency's patients. These health care operations include:
   
   Quality assessment and improvement
   Activities designed to improve health care or reduce health care costs
   Protocol development, case management and care coordination
   Professional review and performance evaluation
   Training of students, trainees and practitioners in health care or of non-health care professionals
   Accreditation, certification, licensing or credentialing activities
   Review and auditing, including compliance reviews, medical reviews, legal services and compliance programs
   Business planning and development including cost management, planning-related analyses and Formulary development
   Agency business management and general administrative activities
   Fundraising and certain marketing activities for the benefit of the agency

For example: the Agency may use your health information to evaluate staff performance, may combine your information with other agency patients to evaluate how to improve service to all agency patients, may disclose your health information when training agency staff or contracted personnel, may use your health information regarding a visit to you or to contact you by community information mailings (unless you tell us you do not want to be contacted).

1. When Legally Required by any Federal, State or local law.
   
   
2. When there are risks to public health such as to prevent or control disease, injury or disability, to report disease injury or vital events such as birth or death, and to conduct public health surveillance, investigations and interventions. Also to report adverse events or product defects, to track products or enable product recalls, repairs and replacements, and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration, or to an employer about an individual who is a member of the workforce, as legally required and

to notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.

3. To report abuse, neglect or domestic violence to government authorities, only when specifically required or authorized by law, or in cases when the patient agrees to the disclosure.
   
   
4. To conduct health oversight activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action, except that if you are the subject of the investigation, the agency may not disclose your health information if it is not directly related to your receipt of health care of public benefits.
   
   
5. For judicial and administrative proceedings, in response to a court or administrative tribunal order expressly authorizing disclosure, or in response to a subpoena, discovery request or other lawful process. The Agency is obligated to make reasonable efforts to either notify you of such proceedings, or to obtain an order protecting your health information.
   
   
6. For law enforcement purposes as required by law, for reporting of certain wounds or other physical injuries pursuant to a court order, warrant, subpoena or summons or similar process,

to identify or locate a suspect, fugitive, material witness or missing person, under certain limited circumstances when you are the victim of a crime, if the agency suspects that your death results from criminal conduct, including criminal conduct at the Agency or in an emergency in order to report a crime.

7. To coroners, medical examiners and funeral directors as authorized by law.
   
   
8. For organ, eye or tissue donation .
   
   
9. For certain research purposes under select circumstances.
   
   
10. To avert a serious threat to health and safety, either your own or the general public.
    
    
11. For specified government functions including military and veterans' activities, national security and intelligence activities, protective services to the President and others, medical suitability determinations, correctional or custodial institutions.
    
    
12. For Worker's Compensation purposes.

Other than is stated above, the Agnecy will not disclose your health information other than with your written authorization. If you or your representative authorizes the Agency to use or disclose your health information, you may revoke that authorization in writing at any time.

Duties of the Agency

The Agency must maintain the privacy of your health information and must provide this Notice to you and your representative. The Agency must abide by the terms of this Notice as currently in effect, but reserves the right to change its terms. The Agency must provide a copy of a revised Notice to you or your appointed representative within a reasonable period of time following any change in the terms of this Notice.

Your Rights, subject to certain conditions, include:

1. Right to request restrictions or limits on the Agency's disclosures of your health information. However, the Agency is not required to agree to your request.
   
   

2. Right to receive confidential communication of your health information. For example, you may request that other family members not be present when you are given any health information.
   
   

3. Right to inspect and receive a copy of your protected health information by request, for a reasonable fee.
   
   

4. Right to amend your health information without altering the medical record.
   
   

5. Right to receive an accounting of all disclosures of your health information, upon your request.
   
   

6. Right to have a paper copy of this notice.
   
   

7. Right to express complaints to the Agency and to the Secretary of Health and Human Services if you or your representative believe that your privacy rights have been violated.

If you have a complaint regarding your privacy rights, you may submit your complaint in writing. The Agency encourages you to express any concerns about your protected health information; please state the specific incident (s), subject, date and any other relevant information. There will be no retaliation of any kind against you because you filed a complaint.

Effective Date: This Notice is effective April 14, 2003