North Country Health System
Joint Notice of Health Information Practices

• North Country Health System continues to respect the confidentiality of its patients’ medical information.  We believe that patients have the right to have their medical information kept private, and the right to review their medical records and understand how their medical information will be used.

• We use patient information to provide quality care to our patients; we carefully protect that information.  We balance protecting patient information with ensuring caregivers have the information they need to properly care for patients.

• The federal rules provide patients with privacy rights and national standards, such as the right to see and copy medical information about them.  Some states already had medical privacy laws on the books; others did not.

• Hospitals are committed to informing patients of their privacy rights.  Under the new rule, every patient will receive a written explanation of how the hospital uses and discloses their information, such as for treatment and to obtain payment for their care.  For some uses, such as marketing, patients will first be asked for their permission before their information is used.

• Within the hospital itself, patients will have greater control of their information.  The new rule lets patients choose not to be listed in the hospital’s patient directory. 

• Hospitals are committed to making the medical privacy rule work for patients and those who care for them.  North Country Health System has provided extensive training and education about the new medical privacy rule to our medical care staff and all of our employees.  We also have provided patient education.  This is just one of the ways our hospital is working to enhance our patients’ experiences and the quality of the care they receive at our facility.

HIPAA Privacy Regulations

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.

This notice covers information gathered about you in connection with your medical treatment provided here at North Country Hospital or one of the practice groups that are departments of the Hospital. Physicians who provide care for you may be employed by North Country Hospital or are independent appointees to our medical staff that are granted privileges here. This notice applies to both in and outpatient services.

Understanding Your Health Record/Information
Each time you visit a hospital, physician, or other healthcare provider, a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. This information, which we refer to as your health or medical record, is an essential part of the health care we provide for you. It serves as a:

• History and foundation for planning care and treatment.
• Way to communicate between the various health professionals who contribute to your care.
• Legal document describing the care you received, and a way for the payer for services can verify charges.
• Source of information for officials charged with improving public health.
• Tool with which we can assess and continually work to improve the care we provide.

Your health record contains personal health information, the confidentiality of which is protected under both state and federal law. Understanding how we expect to use and disclose your health information helps you to:

• Ensure its accuracy.
• Better understand who, what, when, where, and why your health care providers and 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. Under the Federal Privacy Rules, you generally have the right to:

• Receive notice of the uses and disclosures we expect to make of your health information. You may elect to receive this notice electronically, but you are also entitled to receive a paper copy upon request.
• Request additional restrictions on uses and disclosures of your health information (though we are not required to agree to any such request), or request that we send you confidential communications by alternative means or at alternative locations.
• Inspect and obtain a copy of your health record.
• Request that your health record be amended.
• Obtain an accounting of disclosures of your health information made without authorization after April 14, 2003 for purposes other than treatment, payment, or health care operations.

Some of these rights are subject to exceptions and restrictions according to Federal Rules.

Records may be in more than one location. We require a request to inspect and copy to be in writing. We reserve the right to restrict requests to normal business hours with an appointment, if necessary. We also reserve the right to use the time allotted by law to comply with your request.

Please direct requests to: Carmen Nolte, Director of Health Information Management, 334.2365.  E-Mail  cnolte@nchsi.org

Our Responsibilities
We are required by the Federal Privacy Rules to:

• Maintain the privacy of your health information,
• Provide you with notice as to our legal duties and privacy practices with respect to health information we collect and maintain about you,
• Abide by the terms of this notice, subject to the following reservation of rights.

We reserve the right to change our health information practices and the terms of this notice, and to make the new provisions effective for all protected health information we maintain, including health information created or received prior to the effective date of any such revised notice. Should our health information practices change, we will post and/or provide a revised notice. We will not use or disclose your health information without your consent or authorization, except as described in this notice.

Uses and Disclosures for Treatment, Payment and Health Care Operations
(This is not an exhaustive list. Other uses and disclosures occur. The examples below are given to give you an idea of how information is used)

We will use or disclose 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. Your physician will document in your record his or her expectations of the members of your healthcare team. 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 use or disclose your health information for payment.
For example: A bill may be sent to you or your insurance company or health plan. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, procedures, and supplies used.

We will use or disclose your health information for health care operations.
Certain uses of health information are necessary for the day-to-day operations of a health care facility. For example: Appointees to the medical staff, risk managers, or members of the quality improvement team may use information in your health record to assess the 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.

Uses and Disclosures That We May Make Unless You Object
Patient List: We maintain a list of current inpatients in the Hospital. If someone inquires about you by name, we will disclose your room number and telephone extension. If you object, in writing, we will not so disclose this information. We also provide a list of religious affiliations available only to clergy. It is, of course, not necessary to indicate such an affiliation.

Family or friends involved in care: Unless you object, preferably in writing, health professionals, may, using their best judgment, disclose health information to a family member, close personal friend, or any other person you identify relevant to that person’s involvement in your care or payment for that care.

Other Uses and Disclosures
Unless you object, we may contact you to remind you of your appointments, healthcare treatment options or other health services that may be of interest to you.

Required Disclosures
The Federal Privacy Rules require us to disclose your personal health information in two instances: to you at your request, and to the Secretary of Health and Human Services when requested as part of an investigation or compliance review.

Other Disclosures We May Be Required To Make Without Your Authorization
In addition, Federal Privacy Rules permit uses and disclosure of your health information without
your authorization including:

• When required by state or federal law. (This includes, but not limited to, required reports to cancer and mammography registries, reports to law enforcement agencies concerning gunshot wounds, and reports to law enforcement agencies illegal alcohol levels tested in the emergency department on a patient involved in a motor vehicle accident.)
• To state and federal public health authorities, including state medical officers, the Food and Drug Administration (FDA), and other agencies charged with preventing or controlling disease.
• To government authorities, including protective service agencies, authorized to receive reports of abuse, neglect, or domestic violence.
• To government health oversight agencies, such as the state and federal Departments of Health and Human Services, Medicare/Medicaid Peer Review Organizations (QIOs), state Boards of Medicine, Nursing, and Pharmacy, and other licensing authorities.
• When required or court ordered in a judicial or administrative proceeding. We will, however, make every effort to protect your privacy, if possible.
• To law enforcement officials for certain law enforcement purposes, including the reporting of certain types of wounds or injuries, or pursuant to a warrant, subpoena, or other legal process, or for the purpose of identifying or locating a subject, fugitive, material witness, missing person, or victim, provided that the conditions in the rule are met. We will however, make every effort to protect your privacy, if possible.
• To coroners, medical examiners, or funeral directors for purposes of identifying a deceased person or carrying out their duties as required by law.
• To organ procurement organizations for purposes of organ or tissue donation and transplantation, consistent with applicable law.
• For research approved by an Institutional Review Board (IRB) or Privacy Board that has reviewed the research proposal and established protocols to ensure the privacy of your health information.
• When required to avert a serious threat to health or safety.
• When requested for certain specialized government functions authorized by law, including military and similar situations.
• As authorized by law in connection with workers compensation programs.

Uses and Disclosures Specifically Authorized By You
We expect to make other uses and disclosures of your protected health information only on the basis of specific written authorization forms signed by you. You have the right to revoke any
such authorization at any time, except to the extent we have already relied on it in making an authorized use or disclosure. If the disclosure is at our request, your authorization is optional, and your treatment will not be affected.

For More Information or to Report a Problem
If you have questions you may contact Carmen Nolte, Director of Health Information Management, 334.2365.  E-Mail  cnolte@nchsi.org

If you believe your privacy rights have been violated, you may file a complaint with the Privacy Officer at the above address, or with the Office for Civil Rights, U.S. Department of Health and Human Services, Government Center, J.F. Kennedy Federal Building, Room 1875, Boston, MA, 02203. Voice-617.565.1340, Fax-617.565.3809, TDD-617.565.1343.

Effective Date: April 14, 2003