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NOTICE OF PRIVACY PRACTICES THE BRIDGE OF CENTRAL MASSACHUSETTS,
INC.
4 MANN STREET, WORCESTER MA 01602
BRIEF SUMMARY
This notice describes the privacy policy of The Bridge of Central
Massachusetts, Inc. We may amend this policy at any time. We
collect personal information only when appropriate. We may use
or disclose your information to provide you services. We may
also use or disclose it to comply with legal and other
obligations. We assume that you agree to allow us to collect
information and to use or disclose it as described in this
notice. You can inspect personal information about you that we
maintain. You can also ask us to correct inaccurate or
incomplete information. You can ask us about our privacy
policy or practices. We respond to questions and complaints.
Read the full notice for more details. Anyone may have a copy
of the full notice upon request.
NOTICE OF PRIVACY PRACTICES
THE BRIDGE OF CENTRAL
MASSACHUSETTS, INC.
4 MANN STREET, WORCESTER MA 01602
________________________________________________________________
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
Privacy Notice, please contact our Privacy Officer, Douglas Watts at (508)
755-0333 or E-mail at: dougw@thebridgecm.org.
I. Introduction
This Notice of Privacy Practices
describes how we may use and disclose your protected health information to
carry out treatment, payment or health care operations and for other purposes
that are permitted or required by law. This Notice also describes your rights
regarding health information we maintain about you and a brief description of
how you may exercise these rights. This Notice further states the
obligations we have to protect your health information.
“Protected health information” means
health information (including identifying information about you) we have
collected from you or received from your health care providers, health plans,
your employer or a health care clearinghouse. It may include
information about your past, present or future physical or mental health or
condition, the provision of your health care, and payment for your health care
services.
We
are required by law to maintain the privacy of your health information and to
provide you with this notice of our legal duties and privacy practices with
respect to your health information. We are also required to comply with
the terms of our current Notice of Privacy Practices.
II. How We Will Use and Disclose Your
Health Information
We will use and disclose your health information as
described in each category listed below. For each category, we will
explain what we mean in general, but not describe all specific uses or
disclosures of health information.
A. Uses
and Disclosures That May Be Made With Your Written Consent
1. For Treatment.
We will use and disclosure your health information without your authorization
to provide your health care and any related services. We will also use
and disclose your health information to coordinate and manage your health care
and related services. For example, we may need to disclose information to
a case manager who is responsible for coordinating your care. However,
when we make disclosures to a third party (other than your health plan) for
coordination or management of your health care, we will usually obtain your
written authorization prior to the disclosure. A third party is a person
or entity who is not affiliated with our organization.
We may also disclose your health
information without your authorization among our clinicians and other staff
(including clinicians other than your therapist or principal clinician), who
work at The Bridge of Central Massachusetts, Inc. For example, our staff
may discuss your care at a case conference.
In addition, with your authorization, we will disclose
your health information to another health care provider (e.g., your primary
care physician or a laboratory) working outside of The Bridge of Central
Massachusetts, Inc.
2. For Payment. We may use or
disclose your health information without your authorization so that the
treatment and services you receive are billed to, and payment is collected
from, your health plan or other third party payer. By way of example, we
may disclose your health information to permit your health plan to take certain
actions before your health plan approves or pays for your services. These
actions may include:
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making a determination of eligibility or coverage for
health insurance;
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reviewing your services to determine if they were
medically necessary;
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reviewing your services to determine if they were
appropriately authorized or certified in advance of your care; or
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reviewing your services for purposes of utilization
review, to ensure the appropriateness of your care, or to justify the charges
for your care.
3. For Health Care Operations. We may
use and disclose health information about you without your authorization for
our health care operations. These uses and disclosures are necessary to run our
organization and make sure that our consumers receive quality care. These
activities may include, by way of example, quality assessment and improvement,
reviewing the performance or qualifications of our clinicians, training
students in clinical activities, licensing, accreditation, business planning
and development, and general administrative activities.
We may combine health information of
many of our consumers to decide what additional services we should offer, what
services are no longer needed, and whether certain new treatments are
effective. We may also combine our health information with health
information from other providers to compare how we are doing and see where we
can make improvements in our services. When we combine our health
information with information of other providers, we will remove identifying
information so others may use it to study health care or health care delivery
without identifying specific clients.
4. Health-Related Benefits and Services.
We may use and disclose health information to tell you about health-related
benefits or services that may be of interest to you. If you do not want
us to provide you with information about health-related benefits or services,
you must notify the Privacy Officer in writing at The Bridge of Central
Massachusetts, Inc, 4 Mann Street, Worcester MA 01602-(508)
755-0333. Please state clearly that you do not want to receive materials
about health-related benefits or services.
5. Fundraising Activities. We may use
or disclose health information about you to contact you about raising money for
our programs, services and operations. If you do not want us to contact
you for fundraising purposes, you must notify the Privacy Officer in writing at
The Bridge of Central Massachusetts, Inc, 4 Mann Street, Worcester MA
01602-(508) 755-0333. Please state clearly that you do not want to
receive any fundraising solicitations from us.
B. Uses and Disclosures That May be Made Without
Your Consent or Authorization, But For Which You Will Have an Opportunity to
Object.
1. Facility Directory. We maintain a
limited facility directory within our
group home and residential treatment facilities for the purpose of allowing
visitors and callers to locate you. This limited information will only be
provided to individuals who ask for you by name and may include your name, and
whether or not you are currently present in the facility.
When you are admitted to our group
home or residential treatment facility, you will generally have an opportunity
to object to being included in our facility directory. If you choose NOT
to be included in the facility directory, your directory information will not
be provided to person asking for you by name. Nor will you be identified
as present in the facility.
We do not maintain a facility
directory at any of our supported housing, family-based outreach and support or
Safe Homes programs. If asked, we will not confirm orally, in writing or
through any other medium that you are our current or former client, with the
exceptions listed below under “Person’s Involved in an Individual’s
Care.”
2. Persons Involved in Your Care. We
may provide health information about you to someone who helps pay for your
care. We may use or disclose your health information to notify or assist
in notifying a family member, personal representative or any other person that
is responsible for your care of your location, general condition or
death. We may also use or disclose your health information to an entity
assisting in disaster relief efforts and to coordinate uses and disclosures for
this purpose to family or other individuals involved in your health care.
In limited circumstances, we may
disclose health information about you to a friend or family member who is
involved in your care. If you are physically present and have the
capacity to make health care decisions, your health information may only be
disclosed with your agreement to persons you designate to be involved in your
care.
But, if you are in an emergency
situation, we may disclose your health information to a spouse, a family
member, or a friend so that such person may assist in your care. In this case
we will determine whether the disclosure is in your best interest and, if so,
only disclose information that is directly relevant to participation in your
care.
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your health care agent if we have received a valid
health care proxy from you,
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your guardian or medication monitor if one has been
appointed by a court, or
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if applicable, the state agency responsible for
consenting to your care.
C. Uses and Disclosures That May be Made
Without Your Consent, Authorization or Opportunity to Object.
1. Emergencies. We may use and
disclose your health information in an emergency treatment situation. By
way of example, we may provide your health information to a paramedic who is
transporting you in an ambulance. We will attempt to obtain your
authorization as soon as reasonably practicable after we provide you with
emergency treatment. If a clinician is required by law to treat you and
your treating clinician has attempted to obtain your authorization but is
unable to do so, the treating clinician may nevertheless use or disclose your
health information to treat you.
2. Communication Barriers. We may use
and disclose your health information if one of our clinicians attempts to
obtain authorization from you, but is unable to do so due to substantial
communication barriers. However, we will only use or disclose your health
information if the clinician determines in his/her professional judgment that,
absent the communication barriers, you likely would have consented to use or
disclose information under the circumstances.
5. To Avert a Serious Threat to Health or Safety.
We may use and disclose health information about you when necessary to prevent
a serious and imminent threat to your health or safety or to the health or
safety of the public or another person. Under these circumstances, we
will only disclose health information to someone who is able to help prevent or
lessen the threat.
6. Organ and Tissue Donation. If you
are an organ donor, we may release your health information to an organ
procurement organization or to an entity that conducts organ, eye or tissue
transplantation, or serves as an organ donation bank, as necessary to
facilitate organ, eye or tissue donation and transplantation.
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report to public health authorities for the purpose of
preventing or controlling disease, injury or disability;
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report vital events such as birth or death;
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conduct public health surveillance or investigations;
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report abuse or neglect;
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report to the Food and Drug Administration (FDA) or to
a person required by the FDA to report certain events including information
about defective products or problems with medications;
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notify consumers about FDA-initiated product recalls;
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notify a person who may have been exposed to a
communicable disease or who is at risk of contracting or spreading a disease or
condition;
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notify the appropriate government agency if we believe
you have been a victim of abuse, neglect or domestic violence. We will
only notify an agency if we obtain your agreement or if we are required or
authorized by law to report such abuse, neglect or domestic violence.
8. Health Oversight Activities. We
may disclose health information about you to a health oversight agency for
activities authorized by law. Oversight agencies include government
agencies that oversee the health care system, government benefit programs such
as Medicare or Medicaid, other government programs regulating health care and
civil rights laws.
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you are a party to a legal proceeding and we receive a
subpoena for your health information. Normally, we will not provide this
information in response to a subpoena without your authorization if the request
is for substance abuse records or for information relating to AIDS or HIV
status;
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your health information involves communications made
during a court-ordered psychiatric examination;
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you introduce your mental or emotional condition in
evidence in support of your claim or defense in any proceeding and the judge
approves our disclosure of your health information;
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you sue any of our clinicians or staff for malpractice
or initiate a complaint with a licensing board against any of our clinicians;
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the legal proceeding involves child custody, adoption
or dispensing with consent to adoption and the judge approves our disclosure of
your health information;
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one of our social workers brings a proceeding, or is
asked to testify in a proceeding, involving foster care of a child or
commitment of a child to the custody of the Massachusetts Department of Social
Services.
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you agree to the disclosure; or
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when the information is provided in response to an
order of a court; or
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we determine that the law enforcement purpose is to
respond to a threat of an imminently dangerous activity by you against yourself
or another person; or
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the disclosure is otherwise required by law.
We may also disclose health information about a client
who is a victim of a crime, without a court order or without being required to
do so by law. However, we will do so only if the disclosure has been
requested by a law enforcement official and the victim agrees to the disclosure
or, in the case of the victim’s incapacity, the following occurs:
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the law enforcement official represents to us that (i)
the victim is not the subject of the investigation and (ii) an immediate law
enforcement activity to meet a serious danger to the victim or others depends
upon the disclosure; and
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we determine that the disclosure is in the victim’s
best interest.
12. Military and Veterans. If you a
member of the armed forces, we may disclose your health information as required
by military command authorities. We may also disclose your health
information for the purpose of determining your eligibility for benefits
provided by the Department of Veterans Affairs. Finally, if you are a
member of a foreign military service, we may disclose your health information
to that foreign military authority.
13. National Security and Protective Services for
the President and Others. We may disclose medical information
about you to authorized federal officials for intelligence,
counter-intelligence, and other national security activities authorized by
law. We may also disclose health information about you to authorized
federal officials so they may provide protection to the President, other
authorized persons or foreign heads of state or so they may conduct special
investigations.
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Workers’ Compensation. We may disclose
health information about you to comply with the Massachusetts Workers’
Compensation Law. These disclosures will usually be made only when we
have received a court order or, sometimes, when we have received a subpoena for
the information.
III. Uses and Disclosures of
Your Health Information with Your Permission.
Uses and disclosures not described in Section II of this
Notice of Privacy Practices will generally only be made with your written
permission, called an “authorization.” You have the right to revoke an
authorization at any time. If you revoke your authorization we will not
make any further uses or disclosures of your health information under that
authorization, unless we have already taken an action relying upon the uses or
disclosures you have previously authorized.
You have the right to request an opportunity to inspect
or copy health information used to make decisions about your care – whether
they are decisions about your treatment or payment of your care. Usually,
this would include clinical and billing records, but not psychotherapy
notes.
You must submit your request in writing to our Privacy
Officer at The Bridge of Central Massachusetts, Inc., 4 Mann Street, Worcester
MA 01602. If you request a copy of the information, we may charge a
fee for the cost of copying, mailing and supplies associated with your
request.
We may deny your request to inspect or copy your health
information in certain limited circumstances. In some cases, you will
have the right to have the denial reviewed by a licensed health care
professional not directly involved in the original decision to deny
access. We will inform you in writing if the denial of your request may
be reviewed. Once the review is completed, we will honor the decision
made by the licensed health care professional reviewer.
For as long as we keep records about you, you have the
right to request us to amend any health information used to make decisions
about your care – whether they are decisions about your treatment or
payment of your care. Usually, this would include clinical and billing
records, but not psychotherapy notes.
To request an amendment, you must submit a written
document to our Privacy Officer at The Bridge of Central Massachusetts, Inc., 4
Mann Street, Worcester MA 01602 and tell us why you believe the
information is incorrect or inaccurate.
We may deny your request for an amendment if it is not
in writing or does not include a reason to support the request. We may
also deny your request if you ask us to amend health information that:
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was not created by us, unless the person or entity that
created the health information is no longer available to make the amendment;
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is not part of the health information we maintain to
make decisions about your care;
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is not part of the health information that you would be
permitted to inspect or copy; or
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is accurate and complete.
If we deny your request to amend, we will send you a
written notice of the denial stating the basis for the denial and offering you
the opportunity to provide a written statement disagreeing with the
denial. If you do not wish to prepare a written statement of
disagreement, you may ask that the requested amendment and our denial be
attached to all future disclosures of the health information that is the
subject of your request.
If you choose to submit a written statement of
disagreement, we have the right to prepare a written rebuttal to your statement
of disagreement. In this case, we will attach the written request and the
rebuttal (as well as the original request and denial) to all future disclosures
of the health information that is the subject of your request.
You have the right to request that we provide you with
an accounting of disclosures we have made of your health information. An
accounting is a list of disclosures. But this list will not include
certain disclosures of your health information, by way of example, those we
have made for purposes of treatment, payment, and health care operations.
To request an accounting of disclosures, you must submit
your request in writing to the Privacy Officer at The Bridge of Central
Massachusetts, Inc., 4 Mann Street, Worcester MA 01602. For your
convenience, you may submit your request on a form called a “Request For
Accounting,” which you may obtain from our Privacy Officer. The request
should state the time period for which you wish to receive an accounting. This
time period should not be longer than six years and not include dates before
April 14, 2003.
The first accounting you request within a twelve-month
period will be free. For additional requests during the same 12 month
period, we will charge you for the costs of providing the accounting. We
will notify you of the amount we will charge and you may choose to withdraw or
modify your request before we incur any costs.
You have the right to request a restriction on the
health information we use or disclose about you for treatment, payment or
health care operations. You may also ask that any part (or all) of your
health information not be disclosed to family members or friends who may be
involved in your care or for notification purposes as described in Section
II(B)(2) of this Notice of Privacy Practices.
To request a restriction, you must either include it
(with our approval) in the Consent for Use or Disclosure Form or request the
restriction in writing addressed to the Clinical Director and the Director of
Residential Operations at The Bridge of Central Massachusetts, Inc., 4 Mann
Street, Worcester MA 01602-(508) 755-0333. They will ask you to
fill out a Request for Restriction Form, which you should complete and return
to them.
We are not required to agree to a restriction that you
may request. If we do agree, we will honor your request unless the
restricted health information is needed to provide you with emergency
treatment.
You have the right to request that we communicate with
you about your health care only in a certain location or through a certain
method. For example, you may request that we contact you only at work or
by e-mail.
To request such a confidential communication, you must
make your request in writing to the Privacy Officer at The Bridge of Central
Massachusetts, Inc., 4 Mann Street, Worcester MA 01602-(508)
755-0333. We will accommodate all reasonable requests. You do not
need to give us a reason for the request; but your request must specify how or
where you wish to be contacted.
You have the right to obtain a paper copy of this Notice
of Privacy Practices at any time. Even if you have agreed to receive this
Notice of Privacy Practices electronically, you may still obtain a paper
copy. To obtain a paper copy, contact our Privacy Officer at The Bridge
of Central Massachusetts, Inc., 4 Mann Street, Worcester MA 01602-(508)
755-0333.
For individuals who have received treatment, diagnosis
or referral for treatment from our drug or alcohol abuse programs, the
confidentiality of drug or alcohol abuse records is protected by federal law
and regulations. As a general rule, we may not tell a person outside the
programs that you attend any of these programs, or disclose any information
identifying you as an alcohol or drug abuser, unless:
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you authorize the disclosure in writing; or
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the disclosure is permitted by a court order; or
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the disclosure is made to medical personnel in a
medical emergency or to qualified personnel for research, audit or program
evaluation purposes; or
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you threaten to commit a crime either at the drug abuse
or alcohol program or against any person who works for our drug abuse or
alcohol programs.
A violation by us of the federal law and regulations
governing drug or alcohol abuse is a crime. Suspected violations may be
reported to the Unites States Attorney in the district where the violation
occurs.
Federal law and regulations governing confidentiality of
drug or alcohol abuse permit us to report suspected child abuse or neglect
under state law to appropriate state or local authorities.
Please see 42 U.S.C. § 290dd-2 for federal law and 42
C.F.R., Part 2 for federal regulations governing confidentiality of alcohol and
drug abuse patient records.
VI. Complaints
If you believe your privacy rights have been violated,
you may file a complaint with us or with the Secretary of the U.S. Department
of Health and Human Services. To file a complaint with us, contact our
Clinical Director at The Bridge of Central Massachusetts, Inc., 4 Mann Street,
Worcester MA 01602-(508)
755-0333-marvinlew@thebridgecm.org. All complaints must be
submitted in writing.
Our Privacy Officer, who can be contacted at The Bridge
of Central Massachusetts, Inc., 4 Mann Street, Worcester MA 01602-(508)
755-0333-dougw@thebridgecm.org., will assist you with writing your
complaint, if you request such assistance.
We will not retaliate against you for filing a complaint.
VII. Changes to this Notice
We reserve the right to change the terms
of our Notice of Privacy Practices. We also reserve the right to make the
revised or changed Notice of Privacy Practices effective for all health
information we already have about you as well as any health information we
receive in the future. We will post a copy of the current Notice of
Privacy Practices at our main office and at each site where we provide
care. You may also obtain a copy of the current Notice of Privacy
Practices by accessing our website at
http://www.thebridgecm.org/ or by calling us at (508) 755-0333
and requesting that a copy be sent to you in the mail or by asking for one any
time you are at our offices.
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