Riverview Health

Our Responsibilities

Riverview Health takes the privacy of your protected health information seriously. We are required by law to maintain privacy of your protected health information and to provide you with this Notice of Privacy Practices. This Notice is provided to tell you about our duties and practices with respect to your information. We are required to abide by the terms of this Notice that is currently in effect.

How we may use and disclose your health information

The following categories describe different ways that we use and disclose your “protected health information” or “PHI.” For each category we explain what we mean and give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

For Treatment We may use PHI about you to provide you with treatment, health care or other related services. We may disclose your PHI to doctors, nurses, aids, technicians or other employees who are involved in taking care of you. Additionally, we may use or disclose your PHI to manage or coordinate your treatment, health care or other related services. For example, we may provide lab and x-ray test results to referring hospitals, physicians, or nursing homes.

For Payment We may use and disclose your PHI, as needed, to bill and collect for the treatment and services we provide to you. We may send your PHI to an insurance company or other third party for payment purposes, including to a collection service. For example, we may provide test results, procedures notes, surgeries to your insurance carrier in order to process your healthcare claims. We may also provide your information to another provider or other entity for their payment purposes.

For Health Care Operations We may use and disclose your PHI, as necessary, for health care operations. These uses and disclosures are necessary to run Riverview Health, to make sure you receive competent, quality health care, and to maintain and improve the quality of health care we provide. We may also give your PHI to other entities covered by privacy laws for some of their health care operations, as long as the other entity also has a relationship with you. We may also provide your PHI to various governmental or accreditation entities to maintain our license and accreditation. Some examples of health care operations are quality assurance processes, reporting to the Healthcare Facilities Accreditation Program, and to the Indiana State Department of Health.

Incidental Uses and Disclosures We may occasionally inadvertently use or disclose your medical information when such use or disclosure is incident to another use or disclosure that is permitted or required by law. For example, while we have safeguards in place to protect against others overhearing our conversations that take place between doctors, nurses or other Riverview Health personnel, there may be times that such conversations are in fact overheard. Please be assured, however, that we have appropriate safeguards in place to avoid such situations, and others, as much as possible.

Disclosures to You Upon a request by you, we may use or disclose your medical information in accordance with your request.

Limited Data Sets We may use or disclose certain parts of your medical information, called a "limited data set," for purposes of research, public health reasons, or for our health care operations. We would disclose a limited data set only to third parties that have provided us with satisfactory assurances that they will use or disclose your medical information only for limited purposes.

Disclosures to the Secretary of Health and Human Services We might be required by law to disclose your medical information to the Secretary of the Department of Health and Human Services, or his/her designee, in the case of a compliance review to determine whether we are complying with privacy laws.

De-Identified Information We may use your medical information, or disclose it to a third party whom we have hired, to create information that does not identify you in any way. Once we have de-identified your information, it can be used or disclosed in any way according to law.

Disclosures by Members of Our Workforce Members of our workforce, including employees, volunteers, trainees, or independent contractors, may disclose your medical information to a health oversight agency, public health authority, health care accreditation organization or attorney hired by the workforce member, to report the workforce member's belief that we have engaged in unlawful conduct or that our care or services could endanger a patient, workers, or the public. In addition, if a workforce member is a crime victim, the member may disclose your medical information to a law enforcement official, as needed.

To Third Parties We may disclose your medical information to certain third parties with which we contract to perform services on our behalf. If we do so, we will have written assurances from the third party that the third party will safeguard your information.

Suspected Abuse or Neglect If we believe that a person is a victim of child or adult abuse or neglect, we are required by law to report certain information to public authorities.

About Victims of Abuse We may disclose your PHI to notify the appropriate government authority if we believe an individual has been the victim of abuse or neglect.

Communications Regarding Our Services or Products We may use and disclose your PHI to make a communication to you to describe a health-related product or service of Riverview Health. In addition, we may use or disclose your PHI to tell you about products or services related to your treatment, case management or care coordination, or alternative treatments, therapies, providers or settings of care for you. We may occasionally tell you about another company's products or services, but will use or disclose your PHI for such communications only if they occur in person with you. We may also use and disclose your PHI to give you a promotional gift from us that is a minimal value. We must obtain an authorization from you for any other use or disclosure of PHI for marketing purposes or when we are paid in exchange for disclosure of your PHI.

As Required By Law We will disclose your PHI when required to do so by federal, state, or local law.

For Public Health Purposes We may disclose your PHI for public health activities. While there may be others, public health activities generally include the following:

  • Preventing or controlling disease, injury or disability;
  • Reporting births and deaths;
  • Reporting defective medical devices or problems with medications;
  • Notifying people of recalls of products they may be using;
  • Notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition.

Health Oversight Activities We may disclose your PHI to a health oversight agency for activities authorized by law. These oversight activities might include audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government benefit programs, and compliance with civil rights laws.

Judicial Purposes We may disclose your PHI in response to a court or administrative order. In certain circumstances, we may also disclose your PHI in response to a subpoena, discovery request, or other lawful process but only if we receive satisfactory assurances that you have been notified of the request or that an effort was made to secure a protective order.

Law Enforcement We may release PHI if asked to do so by a law enforcement official, if such disclosure is:

  • Required by law;
  • 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 Riverview Health; or
  • 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.

Except for the first two reasons for disclosures, the information that will be provided to law enforcement officials is limited to your contact information or your physical characteristics.

Coroners, Medical Examiners and Funeral Directors In certain circumstances, we may disclose PHI to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release PHI about individuals to funeral directors as necessary to carry out their duties.

Organ and Tissue Donation We may disclose your PHI to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

Research Under certain circumstances, we may use and disclose PHI about you for research purposes. For example, a research project may involve comparing the health and recovery of all individuals who received one medication to those who received another. All research projects, however, are subject to a special approval process. This process includes evaluating a proposed research project and its use of PHI, trying to balance the research needs with your need for privacy of your PHI. Before we use or disclose PHI for research, the project will have been approved through this research approval process. Additionally, when it is necessary for research purposes and so long as the PHI does not leave Riverview Health, we may disclose your PHI to researchers preparing to conduct a research project, for example, to help the researchers look for individuals with specific health needs. Lastly, if certain criteria are met, we may disclose your PHI to researchers after your death when it is necessary for research purposes.

To Avert a Serious Threat to Health or Safety We may use and disclose your PHI when we believe it is 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 or lessen the threat or to law enforcement authorities in particular circumstances.

Military and Veterans If you are a member of the armed forces, we may release your PHI as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.

National Security and Intelligence Activities We may release your PHI to authorized federal officials for lawful intelligence, counterintelligence, and other national security activities authorized by law.

Protective Services for the President and Others We may disclose your PHI to authorized federal officials so they may provide protection to the President, other authorized persons, or foreign heads of state or for the conduct of special investigations.

Custodial Situations If you are an inmate in a correctional institution and if the correctional institution or law enforcement authority makes certain representations to us, we may disclose your PHI to a correctional institution or law enforcement official. Except for disclosures to another provider for your treatment, the information disclosed will be limited to your contact information or physical characteristics.

Workers' Compensation We may disclose your PHI as authorized by and to the extent necessary to comply with workers' compensation laws or laws relating to similar programs.

Treatment Alternatives, Appointment Reminders, and Health-Related Benefits We may use and disclose your PHI to tell you about or recommend possible treatment alternatives or health-related benefits or services that may be of interest to you. Additionally, we may use and disclose your PHI to provide appointment reminders. If you do not wish us to contact you about treatment alternatives, health-related benefits or appointment reminders, you must notify us in writing, and state which of those activities you wish to be excluded from.

Fundraising Activities We may use your PHI to contact you in an effort to raise money for Riverview Health and its operations. We may disclose PHI to a foundation related to Riverview Health so that the foundation may contact you to raise money for Riverview Health. In these cases, we would release only contact information, such as your name, address and phone number and the dates you were here. If you do not want us to contact you for fundraising efforts, you can notify, in writing, the person listed on the last page of this Notice. All such fundraising communications shall provide an opportunity for you to elect not to receive any further such communications.

Facility Directory We may include certain limited information about you in our directory. This information may include your name, location in the Hospital, your general condition (e.g., fair, stable, etc.) and your religious affiliation. The directory information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or minister, even if they do not ask for you by name. If you do not wish to be included in the facility directory, you will be given an opportunity to object at the time of admission.

Individuals Involved in Your Care or Payment for Your Care We may release certain PHI about you to a family member, other relative, or any other person identified by you who is involved in your health care, to the extent that such PHI is directly relevant to such person’s involvement with your health care. We may also give information to someone who is involved with or helps pay for your care, to the extent that such PHI is directly relevant to such person’s involvement with payment related to your health care. We may also tell your family, friends, personal representative, or other person responsible for your health care your condition and that you are at the Hospital.

Third Parties We may disclose your PHI to third parties with whom we contract to perform services on our behalf. If we disclose your information to these entities, we will have an agreement by them to safeguard your information.

Disclosures of Medical Information of Minors Under Indiana law, we cannot disclose the medical information of minors to non-custodial parents if a court order or decree is in place that prohibits the noncustodial parent from receiving such information. However, we must have documentation of the court order prior to denying the non-custodial parent such access.

Disclosures of Records Containing Drug or Alcohol Abuse Information Because of federal law, we will not release your medical information if it contains information about drug or alcohol abuse without your written permission except in very limited situations.

Disclosures of Mental Health Records If your records contain information regarding your mental health, we are restricted in the ways that we can use and disclose them. We can disclose such records without written permission only in the following situations:

  • If the disclosure is made to you (unless it is determined by a physician that the release would be detrimental to your health);
  • Disclosures to our employees in certain circumstances;
  • For payment purposes;
  • For data collection, research, and monitoring managed care providers if the disclosure is made to the division of mental health;
  • For law enforcement purposes or to avert a serious threat to the health and safety of you or others;
  • To a coroner or medical examiner;
  • To satisfy reporting requirements;
  • To satisfy release of information requirements that are required by law;
  • To another provider in an emergency;
  • For legitimate business purposes;
  • Under a court order;
  • To the Secret Service if necessary to protect a person under Secret Service protection; and
  • To the Statewide waiver ombudsman.

Most uses and disclosures of psychotherapy notes require written authorization by you.

Other uses of health information

Other uses and disclosures of PHI not covered by this Notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to use or disclose your PHI, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose PHI about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made under the authorization, and that we are required to retain our records of the care that we provided to you.

Your rights regarding your health information

You have the following rights regarding PHI we maintain about you:

Right to Request Restrictions You have the right to request a restriction or limitation on the PHI we use or disclose about you. You also have the right to request a limit on the PHI we disclose about you to someone who is involved in your care or the payment for your care. For example, if you pay for a particular service in full, out- of-pocket, on the date of service, you may ask us not to disclose any related PHI to your health plan.

You may also ask us not to disclose your PHI to certain family members or friends who may be involved in your care or for other notification purposes described in this Privacy Notice, or how you would like us to communicate with you regarding upcoming appointments, treatment alternatives and the like by contacting you at a telephone number or address other than at home. Please note that we are only required to agree to those restrictions that are reasonable and which are not too difficult for us to administer. We will notify you if we deny any part of your request, but if we are able to agree to a particular restriction, we will communicate and comply with your request except in the case of an emergency. Under certain circumstances, we may choose to terminate our agreement to a restriction if it becomes too burdensome to carry out. Finally, please note that it is your obligation to notify us if you wish to change or update these restrictions by contacting the Privacy Officer.

To request restrictions, you must make your request in writing to the Privacy Officer at 395 Westfield Road, Noblesville, IN 46060. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.

Right to Request Confidential Communications You have the right to request that we communicate with you or your responsible party about your health care in an alternative way or at a certain location.

To request confidential communications, you must make your request in writing to the Privacy Officer at 395 Westfield Road, Noblesville, IN 46060. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to Inspect and Copy You have the right to inspect and copy PHI that may be used to make decisions about your care. A copy may be made available to you in either paper or electronic format. Depending on the circumstances, you may have the right to request a second review if our Privacy Officer denies your request to access your PHI.

To inspect and copy PHI that may be used to make decisions about you, you can submit your request in writing to the Privacy Officer at 395 Westfield Road, Noblesville, IN 46060. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.

Right to Amend You have the right to ask us to amend your health and/or billing information for as long as the information is kept by us.

To request an amendment, your request must be made in writing and submitted to the Privacy Officer at 395 Westfield Road, Noblesville, IN 46060. In addition, you must provide a reason that supports your request.

We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that

  • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
  • Is not part of the PHI kept by or for us;
  • Is not part of the information which you would be permitted to inspect and copy; or
  • Is accurate and complete.
  • If we deny your request for an amendment, you have the right to file a statement of disagreement with us and we may respond to your statement in writing and provide you with a copy.

    Right to an Accounting or Disclosures You have the right to request a list of certain disclosures that we have made of your PHI.

    To request this list of disclosures, you must submit your request in writing to the Privacy Officer at 395 Westfield Road, Noblesville, IN 46060. Your request must state a time period which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a twelve-month period will be free. For additional lists, during such twelve-month period, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

    Right to Receive Notice of a Breach You have the right to receive written notice in the event we learn of any unauthorized acquisition, use, or disclosure of your PHI that was not otherwise properly secured as required by HIPAA. We will notify you of the breach as soon as possible, but no later than sixty (60) days after the breach has been discovered.

    Right to a Paper Copy of This Notice You have the right to a paper copy of this Notice. You may ask us to give you a copy of this Notice at any time. Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy of this Notice. To obtain a paper copy of this Notice, contact the Privacy Officer at 395 Westfield Road, Noblesville, IN 46060.

    Who this notice applies to

    This Notice describes Riverview Health practices and those of:

    • Any health care professional authorized to enter information into or consult your medical record;
    • All departments and units of Riverview Health;
    • Any member of a volunteer group we allow to help you;
    • All employees, staff and other Riverview Health personnel; and
    • The Medical Staff of Riverview Health and its members.

    Riverview Health as the covered entity includes Riverview Health Medical Practices, Riverview Surgical Management Association, Riverview Community Health Clinic, Noblesville CarePoint Immediate Medical Care, and Fishers CarePoint Immediate Medical Care.

    All these entities, sites, and locations follow the terms of this Notice. In addition, these entities, sites, and locations may share PHI with each other for treatment, payment, or operations purposes described in this Notice.

    Changes to this notice

    We reserve the right to change this Notice. We reserve the right to make the revised Notice effective for PHI we already have about you as well as any information we receive in the future. We will post a copy of the current Notice in a clear and prominent location to which you have access. The Notice is also available to you upon request. The Notice will contain on the first page, in the top right-hand corner, the effective date. In addition, if we revise the Notice, you may request a copy of the current Notice in effect.

    Complaints

    If you believe your privacy rights have been violated, you may file a complaint with Riverview Health or with the Secretary of the Department of Health and Human Service-Office for Civil Rights in Baltimore, Maryland.

    To file a complaint with us either in writing or by telephone as follows:

    Riverview Health
    Attn: Privacy Officer
    395 Westfield Road
    Noblesville, IN 46060
    (317) 776-7421

    You will not be penalized or otherwise retaliated against for filing a complaint.