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.

Understanding your health record/information:

Each time you visit a hospital, physician, or other healthcare provider, a record of your visit is made. This information is often referred to as your health or medical record. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. Your record serves as:

• A basis for planning your care and treatment
• A means of communication among the many health professionals who contribute to your care
• A legal document describing the care you received
• A means by which you or a third-party payer can verify that services billed were actually provided
• A tool in educating health professionals
• A source of data for medical research
• A source of information for public health officials charged with improving the health of the nation
• A source of data for facility planning and marketing
• A tool with which we can assess and continually work to improve the care we render and the outcomes we achieve.

Understanding what is in your record and how your health information is used helps you ensure its accuracy, better understand who, what, when, where, and why others may access your health information and make more informed decisions when authorizing disclosure to others.

Your health information rights:

Although your health record is the physical property of the healthcare practitioner or facility that compiled it, the information belongs to you.

• You have the right to inspect or obtain a copy of your health record (except where restricted by law) upon your written request.
• You have the right to request an amendment of information in your health record that you believe is incorrect or incomplete. Any request for amendments to health information must provide the reason for the amendment. We can process your request more quickly if you prepare the form called Requests for Amendment of Health Information.
• You have the right to obtain an accounting of disclosures of your health information. This is a list of the disclosures we made of medical information about you.
• You have the right to request a restriction on certain uses and disclosures of your information; however, we are not required to agree to a requested restriction.
• You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can request that we only contact you at work or by mail.
• You have a right to a paper copy of this notice upon request, even if you agreed to receive this notice electronically. You may obtain a copy of this notice at our website, www.wchsys.org.
• You have the right to revoke your authorization to use or disclose health information except to the extent that action has already been taken. Any request must be made in writing.

Our responsibilities:

This organization is required to:

• Maintain the privacy of your health information
• Provide you with a notice as to our legal duties and privacy practices with respect to information we collect and maintain about you
• Abide by the terms of this notice
• Notify you if we are unable to agree to a requested restriction
• Accommodate reasonable requests you may have made to communicate health information by alternative means to alternative locations.

We will not use or disclose your health information without your authorization, except as described in this notice.

Permitted disclosures for treatment, payment, and health care operations that do not require patient authorization:

We will use your health information for treatment. For example: Information, obtained by a nurse, physician, or other member of your healthcare team will be recorded in your record and used to determine the course of treatment that should work best for you. Members of your healthcare team will then record the actions they took and their observations. In that way, the physician will know how you are responding to treatment. We will provide your physician or a subsequent healthcare provider with copies of various reports that should assist him or her in treating you in the future.

We will use your healthcare information for payment. For example: A bill may be sent to you or a third-party payer. Presenting insurance information at the time of service provides us with the authorization to release personal information to your insurance carrier. This includes, but is not limited to, social security number, full name, and date of birth, as well as the diagnosis pertaining to the service provided. Other personal information will be updated as necessary. In addition, many insurance carriers require medical records and results to determine payment. By requesting us to file a claim with your insurance company, you are consenting to this release of information.

Your clinical information may be reviewed to determine whether your insurance company will reimburse for your continued care.

We will use your health information for regular healthcare operations. For example: Members of the medical staff, the risk or quality improvement manager, or members of the quality improvement team may use information in your health record to assess the quality of care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and service we provide.

Appointment Reminders and Calls; Sign-In Sheets: We may contact you to remind you of your appointment for treatment or medical care at one of our facilities. We may ask you to sign in when you come for care so we can prepare for your visit and call you when your caregiver is ready to see you.

Healthcare Oversight and Quality Assurance; Peer Review: We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigation, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Sharing information to decide about treatment alternatives or other health related benefits and services that might be of interest to you. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you. We may also use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

Business Associates: There are some services provided in our organization through contracts with others. Examples include physician services in the emergency department, anesthesiology and radiology, certain laboratory tests, and a copy service we use when making copies of your health record. When these services are contracted, we may disclose your health information to our business associates so that they can perform the job we’ve asked them to do and bill you or your third-party payer for services rendered. To protect your health information, however, we require the business associate to appropriately safeguard your information.

Patient Directory Information: We may include certain limited information about you in a patient list. This is so your family, friends, and clergy can visit you in the hospital and generally know how you are doing. This information may include your name, location in the facility, your general condition (e.g., fair, stable, etc.) and your religious affiliation. You may choose not to have the information released by telling the person who registers you for services. It may also be withheld under certain health system policies. This information, except for your religious affiliation, may also be released to people who ask for you by name. For example: A newspaper reporter may call for the condition of an accident victim.

Clergy: Your religious affiliation may be given to a member of the clergy in the community, such as a priest or rabbi, even if they don’t ask for you by name.

Family Notification and Communication: We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition. If these people are involved in your medical care in any way, we may share information about you. We may tell family or friends that you are in the hospital and what your condition is. If someone is in charge of paying for your care, we may share information with that person. During a disaster, we may share information with a disaster relief organization so that your family can be notified of your condition, status, and location.

Research: We may disclose information to researchers when an institutional review board that has reviewed the research proposal, and established protocols to ensure the privacy of your health information has approved their research.

Funeral Directors, Medical Examiners, and Coroners: It is sometimes necessary to release medical information to funeral directors, so that they can carry out their duties appropriately. Sometimes, when there are concerns about identification of a patient, or determining what caused a death, we will release medical information to medical examiners or coroners.

Organ and Tissue Donation: If you are an organ donor, we may release information to the organizations responsible for organ or tissue transplantation in order to help with the process.

Fundraising: Information about the healthcare services a patient receives cannot be used for fundraising purposes. However, the fundraising organizations associated with the Health System can collect basic contact and demographic data. Fundraising activities may include a direct mail request to patients discharged from the hospital or an invitation to participate in fundraising for a particular unit when the patient is discharged. If you do not want to be contacted for fundraising efforts, you must notify our Development Department in writing.

Patient Satisfaction Surveys: The health system conducts patient satisfaction surveys to understand how we can improve our services to patients and their families or friends. For example: A patient who was seen as an inpatient or outpatient may receive a survey from a patient satisfaction research organization, asking for comment on the services provided. A patient who received treatment in a doctor’s office may also receive a survey asking for his or her opinion about the service they received.

Food and Drug Administration (FDA): As required by law, we may disclose health information relative to adverse events with respect to food, supplements, product defects or post-marketing surveillance information to enable product recalls, repairs or replacement. For example: We maintain logs of medical devices that are implanted. In the event of a manufacturer’s recall, we can notify your physician so that appropriate actions may be taken.

Workers Compensation: We may release medical information about you to insurers, government administrators, and employers, etc. for workers’ compensation or similar programs. This relates to care provided for work-related injuries or illness.

Public Health: We 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 child abuse or neglect
• 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
• 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.

Correctional Institutions: Should you be an inmate of a correctional institution, we may disclose to the institution or their agents, health information necessary for your health and the health and safety of other individuals. An inmate does not have a right to the Notice of Privacy Practices.

Active Duty Military Personnel: 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.

Law Enforcement: We 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; and
• 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.

To Avert a Serious Threat to Health or Safety: We 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.

Access by Attorneys and the Judicial System: If you are involved in a lawsuit or a dispute, we 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 or to obtain an order protecting the information requested.

Government Security and Intelligence; Bioterrorism: We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law. We 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.

Mental Health, Substance Abuse, Sexual Assault, HIV/AIDS: There are special state and federal privacy rules relating to these care areas. If you have concerns about how information is used, maintained and disclosed relating to these areas, please contact the health information management department at 301-790-8137.

For more information or to report a problem:

If you have questions and would like additional information, you may contact the Privacy Officer at 301-790-7950 or toll-free at 888-847-9247. If you believe your privacy rights have been violated, you can file a complaint in writing with our Privacy Officer at 251 E. Antietam St., Hagerstown, MD 21740 or with the U.S. Secretary of Health and Human Services, Office of Civil Rights. There will be no retaliation for filing a complaint.

Changes to this notice

We reserve the right to change our practices and amend our notice of privacy practices effective for all protected health information we maintain for now and the future. An amended notice shall be available to you in paper or electronic form upon request.

Effective date: April 14, 2003