Purpose of This Notice
Compass Residential and Consulting, LLC (Compass) is required by law to protect certain aspects of your health care information known as Protected Health Information, or PHI, and to provide you with this Notice of Privacy Practices.
This Notice describes our privacy practices, your legal rights, and lets you know how Compass is permitted to:
- Use and disclose PHI about you
- How you can access and copy that information
- How you may request amendment of that information
- How you may request restrictions on our use and disclosure of your PHI
Our Use of Your PHI
In most situations we may use this information described in this Notice without your permission, but there are some situations where we may use it only after we obtain your written authorization, if we are required by law to do so.
We respect your privacy, and treat all health care information about our clients with care under strict policies of confidentiality that our staff is committed to following at all times. Compass may use PHI for the purposes of treatment, payment and health care operations, in most cases without your written permission. Not every use or disclosure will be listed; however, all of the ways Compass is permitted to use and disclose information will fall within one of the following categories. Information may be disclosed in writing, orally, or electronically. Examples of our use of your PHI include:
This includes such things as verbal and written information that we obtain about you and use pertaining to your developmental disabilities services and treatment provided to you by Compass and other healthcare personnel. For example, your information will be shared among members of your support team.
This includes any activities we must undertake in order to get reimbursed for the services we provide to you, including such things as organizing your PHI and submitting bills to insurance companies, management of billed claims for services rendered, and collection of outstanding accounts.
This includes quality assurance activities, licensing, and training programs to ensure that our personnel meet our standards of care and follow established policies and procedures, obtaining legal and financial services, conducting business planning, processing grievances and complaints, and creating reports that do not individually identify you for data collection purposes.
Use and Disclosure of PHI Without Your Authorization
Compass is permitted to use PHI without your written authorization or opportunity to object in certain situations, including:
- As required by state or federal law.
- To a government authority if necessary to report abuse or neglect of a child.
- To a person legally authorized to investigate a report that you have been abused or have been denied your rights.
- For public health and health oversight activities we may disclose confidential information about you when we are required to collect information about disease or injury, for public health investigations, or to report vital statistics.
- To another healthcare provider or entity for the payment activities of the provider or entity that receives the information (such as your other healthcare services providers or insurance company).
- To another healthcare provider for the healthcare operations activities of the covered entity that receives the information as long as the covered entity receiving the information has or has had a relationship with you and the PHI pertains to the relationship.
- For healthcare fraud abuse detection or for activities related to compliance with the law.
- To a family member, other relative, or close personal friend or other individual involved in your care if we obtain your verbal agreement to do so or if we give you an opportunity to object to such a disclosure and you do not raise an objection. We may also disclose health information to your family, relatives, or friends if we infer from the circumstances that you would not object. For example, we may assume you agree to our disclosure of your personal health information to your spouse when your spouse has called the ambulance for you. In situations where you are not capable of objecting because you are not present or due to your incapacity or medical emergency, we may, in our professional judgment, determine that a disclosure to your family member, relative, or friend is in your best interest. In that situation, we will disclose only health information relevant to that person’s involvement in your care.
- To avert a serious threat to health or safety we may disclose information to medical, law enforcement personnel or other persons who can reasonably prevent or lessen the threat of harm, if you or others are in danger and the information is necessary to prevent physical harm.
- To a public health authority in certain situations (such as reporting a birth, death or disease as required by law, as part of a public health investigation, to report child or adult abuse or neglect or domestic violence, to report adverse events such as product defects, or to notify a person about exposure to a possible communicable disease as required by law).
- For health oversight activities including audits or government investigations, inspections, disciplinary proceedings, and other administrative or judicial actions undertaken by the government (or their contractors) by law to oversee the health care system.
- For judicial and administrative proceedings as required by a court or administrative order, or in some cases in response to a subpoena or other legal process.
- For law enforcement activities in limited situations, such as when there is a warrant for the request, or when the information is needed to locate a suspect or stop a crime.
- For military, national defense and security and other special government functions.
- To avert a serious threat to the health and safety of a person or the public at large.
- For workers’ compensation purposes, and in compliance with workers’ compensation laws.
- To coroners, medical examiners, and funeral directors for identifying a deceased person, determining cause of death, or carrying on their duties as authorized by law.
- If you are an organ donor, we may release health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ donation and transplantation.
- For research projects, but this will be subject to strict oversight and approvals and health information will be released only when there is a minimal risk to your privacy and adequate safeguards are in place in accordance with the law.
- We may use or disclose health information about you in a way that does not personally identify you or reveal who you are.
- Any other use or disclosure of PHI, other than those listed above will only be made with your written authorization, (the authorization must specifically identify the information we seek to use or disclose, as well as when and how we seek to use or disclose it). You may revoke your authorization at any time, in writing, except to the extent that we have already used or disclosed medical information based upon that authorization.
You have a number of rights with respect to the protection of your PHI, including:
- The right to access, copy or inspect your PHI.
- This means you may come to our offices and inspect and copy most of the information about you that we maintain. We will normally provide you with access to this information within 30 days of your request. We may also charge you a fee for you to copy any information that you have the right to access. If you wish to inspect and copy your information, you should contact the privacy officer liaison listed at the end of this Notice.
- The right to request an amendment of your PHI.
- You have the right to ask us to amend written information that we may have about you. If errors are found, we will generally amend your information within 60 days of your request and will notify you when we have amended the information. We are permitted by law to deny your request to amend your information, but only in certain circumstances. For example, if we believe the information is correct and no errors exist, your request will be denied. If you wish to request that we amend the information that we have about you, you should contact in writing the privacy officer listed at the end of this Notice.
- The right to request an accounting of our disclosure of your PHI.
- You may request an accounting from us of certain disclosures of your health information that we have made in the last 6 years prior to the date of your request. We are not required to give you an accounting of information we have used or disclosed for purposes of treatment, payment or health care operations. We are also not required to give you an accounting of our uses of protected health information for which you have already given us written authorization. If you wish to request an accounting of the health information about you that we have used or disclosed that is not exempted from the accounting requirement, you should contact the privacy officer listed at the end of this Notice.
- The right to request that we restrict the uses and disclosures of your PHI.
- You have the right to request that we restrict how we use and disclose your medical information that we have about you for treatment, payment or health care operations, or to restrict the information that is provided to family, friends and other individuals involved in your health care. Requests must be made in writing to the privacy officer and must explain: what information you want to limit and to whom you want the limits to apply. However, if you request a restriction and the information you asked us to restrict is needed to provide you with emergency treatment, then we may use the PHI or disclose the PHI to a health care provider to provide you with emergency treatment. Compass is not required to agree to any restrictions you request, but any restrictions agreed to by Compass are binding on Compass.
- Internet, Electronic Mail, and the Right to Obtain Copy of Paper Notice on Request.
- We will prominently post a copy of this Notice on our website and make the Notice available electronically through the web site. If you allow us, we will forward you this Notice by electronic mail instead of on paper and you may always request a paper copy of the Notice.
Your Legal Rights and Complaints
You also have the right to complain to us, or to the Secretary of the United States Department of Health and Human Services if you believe your privacy rights have been violated. You will not be retaliated against in any way for filing a complaint with us or to the government. Should you have any questions, comments or complaints you may direct all inquiries to the privacy officer listed at the end of this Notice.
Revisions to the Notice
Compass reserves the right to change the terms of this Notice at any time, and the changes will be effective immediately and will apply to all protected health information that we maintain. Any material changes to the Notice will be promptly posted in our facilities and posted to our website. You can get a copy of the latest version of this Notice by contacting the Privacy Officer identified below.
Jennifer Sims: HR Director/ Privacy Officer