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Privacy Policy

Effective April 14, 2003 (updated June 6, 2011)

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE READ IT CAREFULLY.

The following is the privacy policy Dawn Farm as described in the Health Insurance Portability and Accountability Act of 1996 and regulations promulgated thereunder, commonly known as HIPAA.  HIPAA requires Covered Entity by law to maintain the privacy of your personal health information and to provide you with notice of Covered Entity’s legal duties and privacy policies with respect to your personal health information.  We are required by law to abide by the terms of this Privacy Notice.

Your Personal Health Information

 We collect personal health information from you through treatment, payment and related healthcare operations, the application and enrollment process, and/or healthcare providers or health plans, or through other means, as applicable.  Your personal health information that is protected by law broadly includes any information, oral, written or recorded, that is created or received by certain health care entities, including health care providers, such as physicians and hospitals, as well as, health insurance companies or plans. The law specifically protects health information that contains data, such as your name, address, social security number, and others, that could be used to identify you as the individual patient who is associated with that health information.

How We May Use And Disclose Health Information About You

We must have your written, signed Consent to use and disclose health information for the following purposes:

For Treatment
We may use health information about you to provide you with medical treatment or services. We may disclose health information about you to doctors, nurses, technicians, office staff or other personnel who are involved in taking care of you and your health.

For Payment
We may use and disclose health information about you so that the treatment and services you receive at this office may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about a service you received here so your health plan will pay us or reimburse you for the service. We may also tell your health plan 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
We may use and disclose health information about you in order to run the office and make sure that you and our other patients receive quality care.   For example, we may use your health information to evaluate the performance of our staff in caring for you. We may also use health information about all or many of our patients to help us decide what additional services we should offer, how we can become more efficient, or whether certain new treatments are effective.

You may revoke your Consent at any time by giving us written notice. Your revocation will be effective when we receive it, but it will not apply to any uses and disclosures which occurred before that time.

If you do revoke your Consent, we will not be permitted to use or disclose information for purposes of treatment, payment or health care operations, and we may therefore choose to discontinue providing you with health care treatment and services.

SPECIAL SITUATIONS

We may use or disclose health information about you without your permission for the following purposes, subject to all applicable legal requirements and limitations:

Medical Emergencies
We may use and disclose health information about you when necessary to prevent a serious threat to your health.

Required By Law
We may disclose health information about you when required to do so by a circuit court order.

Research
We may use and disclose health information about you for research projects that are subject to a special approval process. We will ask you for your 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 office.

Information Not Personally Identifiable
We may use or disclose health information about you in a way that does not personally identify you or reveal who you are.

Miscellaneous Activities, Notice
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.  We may contact you to raise funds for Covered Entity.  If we are a group health plan or health insurance issuer or HMO with respect to a group health plan, we may disclose your personal health information to be sponsor of the plan.

Your Rights With Respect to Your Personal Health Information

Under HIPAA, you have certain rights with respect to your personal health information.  The following is a brief overview of your rights and our duties with respect to enforcing those rights.

Right To Request Restrictions On Use Or Disclosure
You have the right to request restrictions on certain uses and disclosures of your personal health information about yourself.  HIPAA grants you rights to restrict disclosure of your health information. However, federal law for substance abuse treatment records provide even greater confidentiality protection. Generally, the program may not say to a person outside the program that a resident attends the program, or disclose any information identifying a resident as an alcohol or drug abuser unless: 1) You consent in writing; OR 2) The disclosure is allowed by a court order; OR 3) The disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit or program evaluation; OR 4) The resident commits or threatens to commit a crime either at the program or against any person who works at the program.

Right To Receive Confidential Communications
You have the right to receive confidential communications of your personal health information.  We may require written requests.  We may condition the provision of confidential communications on you providing us with information as to how payment will be handled and specification of an alternative address or other method of contact.  We may require that a request contain a statement that disclosure of all or a part of the information to which the request pertains could endanger you.  We may not require you to provide an explanation of the basis for your request as a condition of providing communications to you on a confidential basis. We must permit you to request and must accommodate reasonable requests by you to receive communications of personal health information from us by alternative means or at alternative locations.  If we are a health care plan, we must permit you to request and must accommodate reasonable requests by you to receive communications of personal health information from us by alternative means or at alternative locations if you clearly state that the disclosure of all or part of that information could endanger you.

Right To Inspect And Copy Your Personal Health Information
Your designated record set is a group of records we maintain that includes Medical records and billing records about you, or enrollment, payment, claims adjudication, and case or medical management records systems, as applicable.  You have the right of access in order to inspect and obtain a copy your personal health information contained in your designated record set, except for (a) psychotherapy notes, (b) information complied in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding, and (c) health information maintained by us to the extent to which the provision of access to you would be prohibited by law.  We may require written requests.  We must provide you with access to your personal health information in the form or format requested by you, if it is readily producible in such form or format, or, if not, in a readable hard copy form or such other form or format.  We may provide you with a summary of the personal health information requested, in lieu of providing access to the personal health information or may provide an explanation of the personal health information to which access has been provided, if you agree in advance to such a summary or explanation and agree to the fees imposed for such summary or explanation. We will provide you with access as requested in a timely manner, including arranging with you a convenient time and place to inspect or obtain copies of your personal health information or mailing a copy to you at your request.  We will discuss the scope, format, and other aspects of your request for access as necessary to facilitate timely access.  If you request a copy of your personal health information or agree to a summary or explanation of such information, we may charge a reasonable cost-based fee for copying, postage, if you request a mailing, and the costs of preparing an explanation or summary as agreed upon in advance. We reserve the right to deny you access to and copies of certain personal health information as permitted or required by law.  We will reasonably attempt to accommodate any request for personal health information by, to the extent possible, giving you access to other personal health information after excluding the information as to which we have a ground to deny access.  Upon denial of a request for access or request for information, we will provide you with a written denial specifying the legal basis for denial, a statement of your rights, and a description of how you may file a complaint with us If we do not maintain the information that is the subject of your request for access but we know where the requested information is maintained, we will inform you of where to direct your request for access.

You can also request an electronic copy of information that is stored in your Electronic Health Record (EHR).

Right To Amend Your Personal Health Information
You have the right to request that we amend your personal health information or a record about you contained in your designated record set, for as long as the designated record set is maintained by us.  We have the right to deny your request for amendment, if: (a) we determine that the information or record that is the subject of the request was not created by us, unless you provide a reasonable basis to believe that the originator of the information is no longer available to act on the requested amendment, (b) the information is not part of your designated record set maintained by us, (c) the information is prohibited from inspection by law, or (d) the information is accurate and complete.  We may require that you submit written requests and provide a reason to support the requested amendment.  If we deny your request, we will provide you with a written denial stating the basis of the denial, your right to submit a written statement disagreeing with the denial, and a description of how you may file a complaint with us or the Secretary of the U.S. Department of Health and Human Services (“DHHS”).  This denial will also include a notice that if you do not submit a statement of disagreement, you may request that we include your request for amendment and the denial with any future disclosures of your personal health information that is the subject of the requested amendment.  Copies of all requests, denials, and statements of disagreement will be included in your designated record set.  If we accept your request for amendment, we will make reasonable efforts to inform and provide the amendment within a reasonable time to persons identified by you as having received personal health information of yours prior to amendment and persons that we know have the personal health information that is the subject of the amendment and that may have relied, or could foreseeably rely, on such information to your detriment.  All requests for amendment shall be sent to Dawn Farm, ATTN: Clinical Director, P.O. Box 981098, Ypsilanti, MI 48198.

Right To Receive An Accounting Of Disclosures Of Your Personal Health Information
Beginning April 14, 2003, you have the right to receive a written accounting of all disclosures of your personal health information that we have made within the six (6) year period immediately preceding the date on which the accounting is requested.  You may request an accounting of disclosures for a period of time less than six (6) years from the date of the request. Such disclosures will include the date of each disclosure, the name and, if known, the address of the entity or person who received the information, a brief description of the information disclosed, and a brief statement of the purpose and basis of the disclosure or, in lieu of such statement, a copy of your written authorization or written request for disclosure pertaining to such information.  We are not required to provide accountings of disclosures for the following purposes: (a) treatment, payment, and healthcare operations, (b) disclosures pursuant to your authorization, (c) disclosures to you, (d) for a facility directory or to persons involved in your care, (e) for national security or intelligence purposes, (f) to correctional institutions, and (g) with respect to disclosures occurring prior to 4/14/03.  We reserve our right to temporarily suspend your right to receive an accounting of disclosures to health oversight agencies or law enforcement officials, as required by law.  We will provide the first accounting to you in any twelve (12) month period without charge, but will impose a reasonable cost-based fee for responding to each subsequent request for accounting within that same twelve (12) month period.  All requests for an accounting shall be sent to Dawn Farm, ATTN: Clinical Director, P.O. Box 981098, Ypsilanti, MI 48198.

Breaches

When an Electronic Health Record is used to hold/store your personal health information, it must be secured and protected in specific ways.  You have the right to know if there has been unauthorized access to information in your EHR, and what was done to fix or protect it.

Complaints

You may file a complaint with us and with the Secretary of DHHS if you believe that your privacy rights have been violated.  You may submit your complaint in writing by mail or electronically to our privacy officer, Dawn Farm, ATTN: Jason Schwartz, P.O. Box 981098, Ypsilanti, MI 48198 (734) 485-8725.  A complaint must name the entity that is the subject of the complaint and describe the acts or omissions believed to be in violation of the applicable requirements of HIPAA or this Privacy Policy.  A complaint must be received by usor filed with the Secretary of DHHS within 180 days of when you knew or should have known that the act or omission complained of occurred.  You will not be retaliated against for filing any complaint.

Amendments to this Privacy Policy

We reserve the right to revise or amend this Privacy Policy at any time.  These revisions or amendments may be made effective for all personal health information we maintain even if created or received prior to the effective date of the revision or amendment.  We will provide you with notice of any revisions or amendments to this Privacy Policy, or changes in the law affecting this Privacy Notice, by mail or electronically within 60 days of the effective date of such revision, amendment, or change.

On-going Access to Privacy Policy

We will provide you with a copy of the most recent version of this Privacy Policy at any time upon your written request sent to Dawn Farm, ATTN: Clinical Director, P.O. Box 981098, Ypsilanti, MI 48198.  For any other requests or for further information regarding the privacy of your personal health information, and for information regarding the filing of a complaint with us, please contact our privacy officer Jason Schwartz at the address, telephone number, or e-mail address listed above.

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