Notice of Privacy Practices 
 
 
 
 

NOTICE OF PRIVACY PRACTICES

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.

Who Presents this Notice

This Notice describes the privacy practices of Tenet Health System SL, Inc, which does business as Saint Louis University Hospital ("Hospital"), including members of the Hospital’s workforce, employees and volunteers and Saint Louis University ("University"), including University’s faculty physicians, allied health professionals and students (the Hospital, University and the individual health care providers together are sometimes called "the Hospital, University and Health Professionals" in this Notice). While the Hospital, University and Health Professionals engage in many joint activities and provide clinically integrated care, the Hospital, University and Health Professionals each are separate legal entities. This Notice applies to services furnished to you at the Hospital as a Hospital inpatient or outpatient or any other services provided to you in a Hospital-affiliated program involving the use or disclosure of your health information.

Privacy Obligations

Hospital, University and Health Professionals each are required by law to maintain the privacy of your health information maintained by the Hospital ("Hospital Protected Health Information" or "Hospital PHI”) and to provide you with this Notice of legal duties and privacy practices with respect to your Hospital PHI. Hospital, University and Health Professionals use computerized systems that may subject your Hospital PHI to electronic disclosure for purposes of treatment, payment and/or health care operations as described below. When the Hospital, University and Health Professionals use or disclose Hospital PHI, the Hospital, University and Health Professionals are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure). Special privacy obligations, described below, apply to you if you are admitted to the Hospital’s psychiatric unit or chemical dependency treatment center.

Permissible Uses and Disclosures Without Your Written Authorization

In certain situations your written authorization must be obtained in order to use and/or disclose your Hospital PHI. However, the Hospital, University and Health Professionals do not need any type of authorization from you for the following uses and disclosures:

Uses and Disclosures For Treatment, Payment and Health Care Operations. Your Hospital PHI may be used and disclosed to treat you, obtain payment for services provided to you and conduct “health care operations” as detailed below:

·         Treatment. Your Hospital PHI may be used and disclosed to provide treatment and other services to you--for example, to diagnose and treat your injury or illness. In addition, you may be contacted to provide you appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. Your Hospital PHI may also be disclosed to other providers involved in your treatment. For example, a doctor treating you for a broken leg may need to know if you have diabetes because if you do, this may impact your recovery.

·         Payment. Your Hospital PHI may be used and disclosed to obtain payment for services provided to you--for example, disclosures to claim and obtain payment from your health insurer, HMO, or other company that arranges or pays the cost of some or all of your health care (“Your Payor”) to verify that Your Payor will pay for health care. The physician who reads your x-ray may need to bill you or you’re your Payor for reading of your x-ray therefore your billing information may be shared with the physician who read your x-ray.

·         Health Care Operations. Your Hospital PHI may be used and disclosed for health care operations, which include internal administration and planning and various activities that improve the quality and cost effectiveness of the care delivered to you. For example, Hospital PHI may be used to evaluate the quality and competence of physicians, nurses and other health care workers. Hospital PHI may be disclosed to the Hospital Compliance & Privacy Office in order to resolve any complaints you may have and ensure that you have a comfortable visit. Your Hospital PHI may be provided to various governmental or accreditation entities such as the Joint Commission on Accreditation of Healthcare Organizations to maintain our license and accreditation. In addition, Hospital PHI may be shared with business associates who perform treatment, payment and health care operations services on behalf of the Hospital, University and Health Professionals.

Additionally, your PHI may be used or disclosed for the purpose of allowing students, residents, nurses, physicians and others who are interested in healthcare, pursuing careers in the medical field or desire an opportunity for an educational experience to tour, shadow employees and/or physician faculty members or engage in a clinical Practicum.

Use or Disclosure for Directory of Individuals in Hospital. Hospital may include your name, location in the Hospital, general health condition and religious affiliation in a patient directory without obtaining your authorization unless you object to inclusion in the directory. Information in the directory may be disclosed to anyone who asks 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.

Disclosure to Relatives, Close Friends and Other Caregivers. Your Hospital PHI may be disclosed to a family member, other relative, a close personal friend or any other person identified by you who is involved in your health care or helps pay for your care. If you are not present, or the opportunity to agree or object to a use or disclosure cannot practicably be provided because of your incapacity or an emergency circumstance, the Hospital, University and/or Health Professionals may exercise professional judgment to determine whether a disclosure is in your best interests. If information is disclosed to a family member, other relative or a close personal friend, the Hospital, University and/or Health Professionals would disclose only information believed to be directly relevant to the person’s involvement with your health care or payment related to your health care. Your Hospital PHI also may be disclosed in order to notify (or assist in notifying) such persons of your location or general condition.

Public Health Activities. Your Hospital PHI may be disclosed for the following public health activities: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to public health authorities or other government authorities authorized by law to receive such reports; (3) to report information about products and services under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance.

Victims of Abuse, Neglect or Domestic Violence. Your Hospital PHI may be disclosed to a governmental authority, including a social service or protective services agency, authorized by law to receive reports of such abuse, neglect, or domestic violence if there is a reasonable belief that you are a victim of abuse, neglect or domestic violence.

Health Oversight Activities. Your Hospital PHI may be disclosed to a health oversight agency that oversees the health care system and is charged with responsibility for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.

Judicial and Administrative Proceedings. Your Hospital PHI may be disclosed in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

Law Enforcement Officials. Your Hospital PHI may be disclosed to the police or other law enforcement officials as required or permitted by law or in compliance with a court order or a grand jury or administrative subpoena. For example, your Hospital PHI may be disclosed to identify or locate a suspect, fugitive, material witness, or missing person or to report a crime or criminal conduct at the facility.

Correctional Institution. You Hospital PHI may be disclosed to a correctional institution if you are an inmate in a correctional institution and if the correctional institution or law enforcement authority makes certain requests to us.

Business Associates. Your Hospital PHI may be disclosed to business associates or third parties that the Hospital, University and Health Professionals have contracted with to perform agreed upon services.

Decedents. Your Hospital PHI may be disclosed to a coroner or medical examiner as authorized by law.

Organ and Tissue Procurement. Your Hospital PHI may be disclosed to organizations that facilitate organ, eye or tissue procurement, banking or transplantation.

Research. Your Hospital PHI may be used or disclosed without your consent or authorization if an Institutional Review Board approves a waiver of authorization for disclosure.

Health or Safety. Your Hospital PHI may be used or disclosed to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.

Specialized Government Functions. Your Hospital PHI may be disclosed to units of the government with special functions, such as the U.S. military, the U.S. Department of State under certain circumstances such as the Secret Service or NSA to protect, for example, the country or the President.

Workers’ Compensation. Your Hospital PHI may be disclosed as authorized by and to the extent necessary to comply with state law relating to workers' compensation or other similar programs.

As Required by Law. Your Hospital PHI may be used and disclosed when required to do so by any other law not already referred to in the preceding categories; such as required by the FDA, to monitor the safety of a medical device.

Appointment Reminders. Your Hospital PHI may be used to tell or remind you about appointments.

Fundraising. Your Hospital PHI may be used to contact you as a part of fundraising efforts, unless you elect not to receive this type of information.

USES AND DISCLOSURES REQUIRING YOUR WRITTEN AUTHORIZATION

Use or Disclosure with Your Authorization. For any purpose other than the ones described above, your Hospital PHI may be used or disclosed only when you provide your written authorization on an authorization form (“Your Authorization”). For instance, you will need to execute an authorization form before your Hospital PHI can be sent to your life insurance company or to the attorney representing the other party in litigation in which you are involved.

Marketing. Your written authorization (“Your Marketing Authorization”) also must be obtained prior to using your Hospital PHI to send you any marketing materials. (However, marketing materials can be provided you in a face-to-face encounter without obtaining Your Marketing Authorization. Hospital, University and/or Health Professionals are also permitted to give you a promotional gift of nominal value, if they so choose, without obtaining Your Marketing Authorization.) Hospital, University and/or Health Professionals may communicate with you in a face-to-face encounter about products or services relating to your treatment, case management or care coordination, or alternative treatments, therapies, providers or care settings without Your Marketing Authorization.

In addition, the Hospital, University and/or Health Professionals may send you treatment communications, unless you elect not to receive this type of communication, for which the Hospital, University and/or Health Professionals may receive financial remuneration.

Sale of Hospital PHI. Hospital, University and Health Professionals will not disclose your Hospital PHI without your authorization in exchange for direct or indirect payment except in limited circumstances permitted by law. These circumstances include public health activities; research; treatment of the individual; sale, transfer, merger or consolidation of the Hospital; services provided by a business associate, pursuant to a business associate agreement; providing an individual with a copy of their Hospital PHI; and other purposes deemed necessary and appropriate by HHS.

Uses and Disclosures of Your Highly Confidential Information. In addition, federal and state law require special privacy protections for certain highly confidential information about you (“Highly Confidential Information”), including the subset of your Hospital PHI that: (1) is maintained in psychotherapy notes; (2) is about mental illness, mental retardation and developmental disabilities; (3) is about alcohol or drug abuse or addiction; (4) is about HIV/AIDS testing, diagnosis or treatment; (5) is about communicable disease(s), including venereal disease(s); (6) is about genetic testing; (7) is about child abuse and neglect; (8) is about domestic abuse of an adult; or (9) is about sexual assault. In order for your Highly Confidential Information to be disclosed for a purpose other than those permitted by law, your written authorization is required.

Use and Disclosure of Information Upon Admission to a Psychiatric Unit or Alcohol or Drug Abuse Treatment Program. Information regarding your care in the Hospital’s psychiatric unit or alcohol or drug abuse treatment unit is subject to special protection under state and federal law. The terms of this Notice shall apply to your Hospital PHI unless otherwise described in this Section.

·         Psychiatric Treatment. Your Hospital PHI will be disclosed to Hospital personnel involved in your treatment or supervising those involved in your treatment for the purpose of treating you or consulting about your treatment. Your Authorization will be obtained prior to disclosing your Hospital PHI to other treatment providers except in the event of a medical emergency or as permitted by law to other persons or agencies responsible for providing health care services to you. Your Authorization generally will be obtained prior to disclosing your Hospital PHI to obtain payment for services rendered to you, such as for example, to your insurance company. However, your Hospital PHI may be disclosed to your insurance company or other third party payor to the extent necessary for to make a claim on your behalf for aid or insurance benefits. On occasion, your Hospital PHI may be used for health care operations but, to the extent possible, your personally identifiable information will be removed. Neither the Hospital, University or Health Professionals will respond to inquiries about your treatment or disclose information revealing that you are a patient of the psychiatric unit to unauthorized individuals who call the Hospital to seek information. Your Hospital PHI will not be disclosed to a family member, relative or any other person seeking information about your care unless your written Authorization is obtained. If you are a minor or have a personal representative (such as a guardian or person authorized under a power of attorney), you will be consulted prior to sharing information with such person. If you refuse to grant permission or are unable to grant permission, information may be shared with your personal representative only to the extent permitted or required by state law. Hospital, University and Health Professionals will comply with state law in reporting your Hospital PHI for public health activities or health oversight activities. If you disclose information related to child abuse or other types of actual or threatened abuse, the Hospital, University and/or Health Professionals may be required to report such information to governmental authorities responsible to investigate such abuse. If you commit a crime on the premises, your Hospital PHI may be used to report the crime. To the extent possible, the Hospital, University and/or Health Professionals will notify you or seek a protective order prior to disclosing information to a judicial or administrative proceeding. Your Hospital PHI will not be used for marketing.

·         Alcohol or Drug Abuse Treatment. If you are a recipient of alcohol or drug abuse treatment, your Hospital PHI is protected by federal and state confidentiality laws (42 U.S.C. 290dd-3, 290ee-3 and 42 CFR Part 2). Violations of these laws is a crime and may be reported to appropriate authorities. Your Hospital PHI will be disclosed to Hospital personnel within the alcohol or drug abuse treatment program and certain organizations providing services to the program that have a need to know your Hospital PHI to perform their job duties or to medical personnel in the event of a medical emergency. Your Authorization will be obtained prior to disclosing any Hospital PHI to obtain payment for services rendered to you, such as for example, to your insurance company. On occasion, your Hospital PHI may be used for health care operations but your identifying information will be removed. Hospital, University and Health Professionals will not respond to inquiries about your treatment and will not disclose information revealing that you are a patient of the alcohol or drug abuse treatment program to unauthorized individuals who call the Hospital to seek information. Your Hospital PHI will not be disclosed to a family member, relative or any other person seeking information about your care unless your written Authorization is obtained. If you are a minor or have a personal representative (such as a guardian or person authorized under a power of attorney), you will be consulted prior to sharing information with such person. If you refuse to grant permission or are unable to grant permission, information may be shared with your personal representative only to the extent permitted or required by state law. Hospital, University and Health Professionals will comply with federal and state law in reporting your Hospital PHI for public health activities or health oversight activities. If you disclose information related to child abuse, the Hospital, University and/or Health Professionals may be required to report such information to governmental authorities responsible to investigate such abuse. If you commit a crime on the premises, your Hospital PHI may be used to report the crime. To the extent possible, the Hospital, University and/or Health Professionals will notify you or seek a protective order prior to disclosing information to a judicial or administrative proceeding. Your Hospital PHI will not be used for marketing.

YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION

Right to Request Additional Restrictions. You may request restrictions on the use and disclosure of your Hospital PHI (1) for treatment, payment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While all requests for additional restrictions will be carefully considered, the Hospital, University and Health Professionals are not required to agree to these requested restrictions.

You may also request to restrict disclosures of your Hospital PHI to your health plan for payment and healthcare operations purposes (and not for treatment) if the disclosure pertains to a healthcare item or service for which you paid out-of-pocket in full. Hospital, University and Health Professionals must agree to abide by the restriction to your health plan EXCEPT when the disclosure is required by law.

If you wish to request additional restrictions, please obtain a request form from the Health Information Management Office and submit the completed form to the Health Information Management Office. A written response will be sent to you.

Right to Receive Confidential Communications. You may request, and the Hospital, University and Health Professionals will accommodate, any reasonable written request for you to receive your Hospital PHI by alternative means of communication or at alternative locations.

Right to Revoke Your Authorization. You may revoke Your Authorization, Your Marketing Authorization or any written authorization obtained in connection with your Hospital PHI, except to the extent that the Hospital, University and/or Health Professionals have taken action in reliance upon it, by delivering a written revocation statement to the Hospital Health Information Management Office below.

Right to Inspect and Copy Your Health Information. You may request access to your medical record file and billing records maintained by the Hospital, University and Health Professionals in order to inspect and request copies of the records. Under limited circumstances, you may be denied access to a portion of your records. If you desire access to your records, please obtain a record request form from the Hospital Health Information Management Office and submit the completed form to the Hospital [Health Information Management Office. If you request copies of paper records, you will be charged in accordance with federal and state law. To the extent the request for records includes portions of records which are not in paper form (e.g., x-ray films), you will be charge the reasonable cost of the copies. You also will be charged for the postage costs, if you request that the copies be mailed to you. However, you will not be charged for copies that are requested in order to make or complete an application for a federal or state disability benefits program.

Right to Amend Your Records. You have the right to request that Hospital PHI maintained in your medical record file or billing records be amended. If you desire to amend your records, please obtain an amendment request form from the Hospital Health Information Management Office and submit the completed form to the Hospital Health Information Management Office. Your request will be accommodated unless the Hospital, University and/or Health Professionals believe that the information that would be amended is accurate and complete or other special circumstances apply.

Right to Receive an Accounting of Disclosures. Upon request, you may obtain an accounting of certain disclosures of your Hospital PHI made during any period of time prior to the date of your request provided such period does not exceed six years and does not apply to disclosures that occurred prior to April 14, 2003. If you request an accounting more than once during a twelve (12) month period, you will be charged for the accounting statement.

Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice, even if you have agreed to receive such notice electronically.

For Further Information or Complaints. If you desire further information about your privacy rights, are concerned that your privacy rights have been violated or disagree with a decision made about access to your Hospital PHI, you may contact the Hospital Compliance & Privacy Office. You may also file written complaints with the Director, Office for Civil Rights of the U.S. Department of Health and Human Services. Upon request, the Hospital Compliance & Privacy Office will provide you with the correct address for the Director. Hospital, University and Health Professionals will not retaliate against you if you file a complaint with the Hospital Privacy Office or the Director.

Effective Date and Duration of This Notice

Effective Date. This Notice is effective on September 23, 2013.

Right to Change Terms of this Notice. The terms of this Notice may be changed at any time. If this Notice is changed, the new notice terms may be made effective for all Hospital PHI that the Hospital, University and Health Professionals maintain, including any information created or received prior to issuing the new notice. If this Notice is changed, the new notice will be posted in waiting areas around the Hospital and on our Internet site at www.sluhospital.com. You also may obtain any new notice by contacting the Hospital Compliance & Privacy Office.

HOSPITAL CONTACTS:

You may contact the Hospital Compliance & Privacy Office at:

Tenet Saint Louis Privacy Office
                3635 Vista
               
St. Louis, MO 63110
               
Phone: 314-268-5580
               
Fax: 314-577-8003

Or at:

Corporate Compliance & Privacy Office
               
Tenet Healthcare
               
1445 Ross Avenue, Suite 1400
               
Dallas, Texas 75202
                
E-mail: PrivacySecurityOffice@tenethealth.com
                Phone: 1-877-893-8363 ext. 2009
                
Ethics Action Line (EAL): 1-800-8-ETHICS

You may contact the Health Information Management Office at:

Health Information Management Office
               
3635 Vista at Grand
               
St. Louis, MO 63110
                
Phone: 314-577-8045
                
Fax: 314-268-5107

 
 
 
 
 
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