HIPAA Notice of Privacy Practices – Effective 10/31/2019
Pacific Coast Hospice understands that your health information is highly personal, and we are committed to safeguarding your privacy. Please read this Notice of Privacy Practices thoroughly. It describes how Pacific Coast Hospice will use and disclose your Protected Health Information (PHI). 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.
Use and Disclosure of Health Information
PCH USA, LLC dba Pacific Coast Hospice [“Agency”] may use your health information, information that constitutes protected health information as defined in the Privacy Rule of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996, for purposes of providing you treatment, obtaining payment for your care and conducting health care operations. The Agency has established policies to guard against unnecessary disclosure of your health information.
The Following Is A Summary Of The Circumstances Under Which, And Purposes For Which Your Health Information May Be Used And Disclosed:
To Provide Treatment. The Agency may use your health information to coordinate care within the Agency and with others involved in your care, such as your attending physician, members of the Agency interdisciplinary team and other health care professionals who have agreed to assist the Agency in coordinating care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. The Agency also may disclose your healthcare information to individuals outside of the Agency involved in your care including family members, close friends, clergy whom you have designated, pharmacists, suppliers of medical equipment or other health care professionals the agency uses in order to coordinate your care. If you are not able to tell us your preference, for example if you are unconscious, we may share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
To Obtain Payment. The Agency may include your health information in invoices to collect payment from third parties for the care you receive from the Agency. For example, the Agency may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or the Agency. The Agency also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for hospice care and the services that will be provided to you.
To Conduct Health Care Operations. The Agency may use and disclose health information for its own operations in order to facilitate the function of the Agency and as necessary to provide quality care to all of the Agency’s patients. Health care operations includes such activities as:
● Quality assessment and improvement activities
● Activities designed to improve health or reduce health care costs
● Protocol development, case management and care coordination
● Professional review and performance evaluation
● Training programs including those in which student trainees or practitioners in healthcare learn under supervision
● Training of non-health care professionals
● Accreditation, certification, licensing or credentialing activities
● Review and auditing, including compliance reviews, medical reviews, legal services and compliance programs
● Business planning and development, including cost management and planning related analyses and formulary development
● Business management and general administrative activities of the Agency
● Certain marketing activities
For example the Agency may use your health information to evaluate its staff performance, combine your health information with other Agency patients in evaluating how to more effectively serve all Agency patients, disclose your health information to Agency staff and contracted personnel for training purposes, use your health information to contact you as a reminder regarding a visit to you, or contact you as part of general fundraising and community information mailings. You have a right to opt-out of these mailings and tell us you do not want to be contacted for these purposes.
The Agency may disclose certain information about you including your name, your general health status, your religious affiliation and where you are in the Agency’s facility in an Agency directory. The Agency may disclose this information to people who ask for you by name. Please inform us if you do not want your information to be included in the directory.
Federal and State privacy rules allow the Agency to use or disclose your health information without your consent or authorization for a number of reasons
When Legally Required. The Agency will disclose your health information when it is required to do so by any Federal, State or local law.
When There Are Risks to Public Health. The Agency may disclose your health information for public activities and purposes in order to:
● Prevent or control disease, injury or disability, report disease, injury, vital events such as birth or death and the conduct of public health surveillance, investigations and interventions.
● Report adverse events, product defects, to track products or enable product recalls, repairs and replacements and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
● Notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
● Notify an employer about an individual who is a member of the workforce as legally required.
To Report Abuse, Neglect Or Domestic Violence. The Agency is allowed to notify government authorities if the Agency believes a patient is the victim of abuse, neglect or domestic violence. The Agency will make this disclosure only when specifically required or authorized by law or when the patient agrees to the disclosure.
To Conduct Health Oversight Activities. The Agency may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. The Agency, however, may not disclose your health information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.
In Connection With Judicial And Administrative Proceedings. The Agency may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only when the Agency makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information.
For Law Enforcement Purposes. As permitted or required by State law, the Agency may disclose your health information to a law enforcement official for certain law enforcement purposes as follows:
● As required by law for reporting of certain types of wounds or other physical injuries pursuant to the court order, warrant, subpoena or summons or similar process.
● For the purpose of identifying or locating a suspect, fugitive, material witness or missing person.
● Under certain limited circumstances, when you are the victim of a crime.
● To a law enforcement official if the Agency has a suspicion that your death was the result of criminal conduct including criminal conduct at the Agency.
● In an emergency in order to report a crime.
To Coroners And Medical Examiners. The Agency may disclose your health information to coroners and medical examiners for purposes of determining your cause of death or for other duties, as authorized by law.
To Funeral Directors. The Agency may disclose your health information to funeral directors consistent with applicable law and if necessary, to carry out their duties with respect to your funeral arrangements. If necessary to carry out their duties, the Agency may disclose your health information prior to and in reasonable anticipation of your death.
For Organ, Eye Or Tissue Donation. The Agency may use or disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue for the purpose of facilitating the donation and transplantation.
For Research Purposes. The Agency may, under very select circumstances, use your health information for research. Before the Agency discloses any of your health information for such research purposes, the project will be subject to an extensive approval process. The Agency will ask your permission if any researcher will be granted access to your individually identifiable health information.
In the Event of A Serious Threat To Health Or Safety. The Agency may, consistent with applicable law and ethical standards of conduct, disclose your health information if the Agency, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety, or to the health and safety of the public.
For Specified Government Functions. In certain circumstances, the Federal regulations authorize the Agency to use or disclose your health information to facilitate specified government functions relating to military and veterans, national security and intelligence activities, protective services for the President and others, medical suitability determinations and inmates and law enforcement custody.
For Worker’s Compensation. The Agency may release your health information for worker’s compensation or similar programs.
Authorization To Use Or Disclose Health Information
Other than is stated above, the Agency will not disclose your health information other than with your written authorization. The Agency will not sell or disclose your health information for marketing purposes. If you or your representative authorizes the Agency to use or disclose your health information, you may revoke that authorization in writing at any time.
Your Rights With Respect To Your Health Information
You have the following rights regarding your health information that the Agency maintains:
● Right to be notified of a breach. You have the right to be notified in the event the Agency discovers a breach of your health information.
● Right to request restrictions. You may request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on the Agency‘s disclosure of your health information to someone who is involved in your care or the payment of your care. However, the Agency is not required to agree to your request. If you wish to make a request for restrictions, please contact the Privacy Officer. You have the right to request restriction of certain disclosures of your health information to a health plan when you have paid out of pocket and in full for those services.
● Right to receive confidential communications. You have the right to request that the Agency communicate with you in a certain way. For example, you may ask that the Agency only conduct communications pertaining to your health information with you privately with no other family members present. The Agency will not request that you provide any reasons for your request and will attempt to honor your reasonable requests for confidential communications.
● Right to inspect and copy your health information. You have the right to inspect and copy your health information, including billing records. A request to inspect and copy records containing your health information must be made in writing to: Pacific Coast Hospice, ATTN: Privacy Officer, 2919 S Ellsworth Rd. Ste 129, Mesa, AZ 85121-2167, or telephone (480) 637-4100. If you request a copy of your health information, the Agency may charge a reasonable fee for copying and assembling costs associated with your request. A copy may be made available to you, usually within 30 days of your request, either in paper or electronic format.
● Right to amend health care information. You or your representative have the right to request that the Agency amend your records, if you believe that your health information is incorrect or incomplete. That request may be made as long as the information is maintained by the Agency. A request for an amendment of records must be made in writing to the Privacy Officer, Pacific Coast Hospice, 2919 S Ellsworth Rd. Ste 129, Mesa,AZ 85212-2167. The Agency may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by the Agency, if the records you are requesting are not part of the Agency‘s records, if the health information you wish to amend is not part of the health information you or your representative are permitted to inspect and copy, or if, in the opinion of the Agency, the records containing your health information are accurate and complete.
● Right to an accounting. You or your representative have the right to request an accounting of disclosures of your health information made by the Agency for certain reasons, including reasons related to public purposes authorized by law and certain research. The request for an accounting must be made in writing to the Privacy Officer, Pacific Coast Hospice, 2919 S Ellsworth Rd. Ste 129, Mesa, AZ 85212-2167. The request should specify the time period for the accounting. Accounting requests may not be made for periods of time in excess of seven (7) years. The Agency would provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.
● Right to a paper copy of this notice. You or your representative have the right to a separate paper copy of this Notice at any time even if you or your representative have received this Notice previously. You may also obtain a copy of the current version of the Agency’s Notice of Privacy Practices at its website: http://pchusa.org/privacy
● Requests for all of the above mentioned patient rights are to be made to: Privacy Officer, Pacific Coast Hospice, 2919 S Ellsworth Rd. Ste 129, Mesa, AZ 85212-2167.
Notice of Health Information Practices
You are receiving this notice because your healthcare provider participates in a non-profit, non-governmental health information exchange (HIE) called Health Current. It will not cost you anything and can help your doctor, healthcare providers, and health plans better coordinate your care by securely sharing your health information. This Notice explains how the HIE works and will help you understand your rights regarding the HIE under state and federal law.
How does Health Current help you to get better care?
In a paper-based record system, your health information is mailed or faxed to your doctor, but sometimes these records are lost or don’t arrive in time for your appointment. If you allow your health information to be shared through the HIE, your doctors are able to access it electronically in a secure and timely manner.
What health information is available through Health Current?
The following types of health information may be available:
• Hospital records • Radiology reports • Medical history • Clinic and doctor visit information • Medications • Health plan enrollment and eligibility • Allergies • Lab test results • Other information helpful for your treatment
Who can view your health information through Health Current and when can it be shared?
People involved in your care will have access to your health information. This may include your doctors, nurses, other healthcare providers, health plan and any organization or person who is working on behalf of your healthcare providers and health plan. They may access your information for treatment, care coordination, care or case management, transition of care planning, payment for your treatment, conducting quality assessment and improvement activities, developing clinical guidelines and protocols, conducting patient safety activities, and population health services. Medical examiners, public health authorities, organ procurement organizations, and others may also access health information for certain approved purposes, such as conducting death investigations, public health investigations and organ, eye or tissue donation and transplantation, as permitted by applicable law.
Health Current may also use your health information as required by law and as necessary to perform services for healthcare providers, health plans and others participating with Health Current.
The Health Current Board of Directors can expand the reasons why healthcare providers and others may access your health information in the future as long as the access is permitted by law. That information is on the Health Current website at healthcurrent.org/permitted-use.
You also may permit others to access your health information by signing an authorization form. They may only access the health information described in the authorization form for the purposes stated on that form.
Does Health Current receive behavioral health information and if so, who can access it?
Health Current does receive behavioral health information, including substance abuse treatment records. Federal law gives special confidentiality protection to substance abuse treatment records from some substance abuse treatment programs. Health Current keeps these protected substance abuse treatment records separate from the rest of your health information. Health Current will only share these protected substance abuse treatment records it receives from these programs in two cases. One, medical personnel may access this information in a medical emergency. Two, you may sign a consent form giving your healthcare provider or others access to this information.
How is your health information protected?
Federal and state laws, such as HIPAA, protect the confidentiality of your health information. Your information is shared using secure transmission. Health Current has security measures in place to prevent someone who is not authorized from having access. Each person has a username and password, and the system records all access to your information.
Your Rights Regarding Secure Electronic Information Sharing You have the right to:
1. Ask for a copy of your health information that is available through Health Current. To make this request, complete the Health Information Request Form and return it to your healthcare provider.
2. Request to have any information in the HIE corrected. If any information in the HIE is incorrect, you can ask your healthcare provider to correct the information.
3. Ask for a list of people who have viewed your information through Health Current. To make this request, complete the Health Information Request Form and return it to your healthcare provider. Please let your healthcare provider know if you think someone has viewed your information who should not have.
You have the right under article 27, section 2 of the Arizona Constitution and Arizona Revised Statutes title 36, section 3802 to keep your health information from being shared electronically through Health Current:
1. Except as otherwise provided by state or federal law, you may “opt out” of having your information shared through Health Current. To opt out, ask your healthcare provider for the Opt Out Form. Your information will not be available for sharing through Health Current within 30 days of Health Current receiving your Opt Out Form from your healthcare provider. Caution: If you opt out, your health information will NOT be available to your healthcare providers—even in an emergency.
2. If you opt out today, you can change your mind at any time by completing an Opt Back In Form and returning it to your healthcare provider.
3. If you do nothing today and allow your health information to be shared through Health Current, you may opt out in the future.
IF YOU DO NOTHING, YOUR INFORMATION MAY BE SECURELY SHARED THROUGH HEALTH CURRENT.
Duties Of The Agency
The Agency is required by law to maintain the privacy of your health information and to provide to you and your representative this Notice of its duties and privacy practices. The Agency is required to abide by the terms of this Notice as may be amended from time to time. The Agency reserves the right to change the terms of its Notice and tomake the new Notice provisions effective for all health information that it maintains. If the Agency changes its Notice, the Agency will provide a copy of the revised Notice to you or your appointed representative. You or your personal representative have the right to express complaints to the Agency orto the Secretary of DHHS if you or your representative believe that your privacy rights have been violated. Any complaints to the Agency should be made in writing to the Privacy Officer, Pacific Coast Hospice, 2919 S Ellsworth Rd.Ste 129, Mesa, AZ 85212-2167. Complaints to the Secretary of Health and Human Services are directed to: Department of Human Services, 200 Independence Ave. SW, Washington, D.C. 20201, toll-free 877-696-6775, or visiting http://www.hhs.gov/ocr/privacy/hipaa/complaints/. You will not be retaliated against in any way for filing a complaint. The Agency encourages you to express any concerns you may have regarding the privacy of your information.
The Agency has designated the Privacy Officer as its contact person for all issues regarding patient privacy and your rights under Federal privacy standards. You may contact this person at Privacy Officer, Pacific Coast Hospice, 2919 S Ellsworth Rd. Ste 129, Mesa, AZ 85212-2167 or by telephone at (480) 637-4100.
This Notice is effective October 31, 2019.
IF YOU HAVE ANY QUESTIONS REGARDING THIS NOTICE, PLEASE CONTACT THE PRIVACY OFFICER, PACIFIC COAST HOSPICE, 2919 S ELLSWORTH RD. STE 129, MESA, AZ 85212-2167. (480) 637-4100.
In addition to this HIPAA Notice of Privacy Practices, we may collect data on our website and via other electronic means.
Collection and Use of Personal Information – From Electronic sources
Personal information is data that can be used to identify or contact a single person.
Here are some examples of the types of personal information Pacific Coast Hospice may collect and how we may use it:
- When you contact our company, including by social media, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, and profile information where the contact is via social media.
- In certain jurisdictions, we may ask for a government issued ID in limited circumstances as required by law.
How we use your personal information – From Electronic sources
- The personal information we collect allows us to keep you posted on Pacific Coast Hospice’s latest service announcements and upcoming events. If you don’t want to be on our mailing list, you can opt-out anytime by updating your preferences.
- We also use personal information to help us create, develop, operate, deliver, and improve our services, content and advertising, and for anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our patients, and pre-screening or scanning uploaded content for potentially illegal content, including child sexual exploitation material. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.
- We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services.
- From time to time, we may use your personal information to send important notices, such as communications about changes to our terms, conditions, and policies. Because this information is important to your interaction with Pacific Coast Hospice, you may not opt out of receiving these communications.
- We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Pacific Coast Hospice services, and patient communications.
- If you enter into a sweepstake, contest, or similar promotion we may use the information you provide to administer those programs.
- If you apply for a position at Pacific Coast Hospice or we receive your information in connection with a potential role at Pacific Coast Hospice, we may use your information to evaluate your candidacy and to contact you. If you are a candidate, you will receive more information about how Pacific Coast Hospice handles candidate personal information at the time of application.
Source of your personal information where they are not collected from you – From Electronic sources
If you are a potential candidate for employment with Pacific Coast Hospice, we may have received your personal information from third parties such as recruiters or external websites. We will use the personal information we receive to contact you about a potential opportunity or in evaluating your candidacy. If you did not provide us your personal information directly, we will inform you of the source when we first contact you regarding your candidacy. For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.
Collection and Use of Non-Personal Information – From Electronic sources
We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:
- We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where Pacific Coast Hospice services are used so that we can better understand patient behavior and improve our services and advertising.
- We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
If we do combine non-personal information with personal information the combined information will be treated as confidential information for as long as it remains combined.
Cookies and Other Technologies
If you want to disable cookies check with your provider to find out how to disable cookies. Please note that certain features of the Pacific Coast Hospice website will not be available once cookies are disabled.
As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Pacific Coast Hospice may use this information in our marketing and advertising services.
In some of our email messages, we use a “click-through URL” linked to content on the Pacific Coast Hospice website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.
Disclosure to Third Parties – From Electronic sources
At times Pacific Coast Hospice may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help Pacific Coast Hospice market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. Personal information will never be shared with third parties for their marketing purposes.
Pacific Coast Hospice shares personal information with companies who provide services such as information processing, managing patient data, providing customer service, and conducting patient research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Pacific Coast Hospice operates.
It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within your country of residence − for Pacific Coast Hospice to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.
Protection of Personal Information
Pacific Coast Hospice takes the security of your personal information very seriously. Pacific Coast Hospice online services protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by Pacific Coast Hospice, we use computer systems with limited access housed in facilities using physical security measures. All protected health information (PHI) data is stored in encrypted form including when we utilize third-party storage.
When you use some Pacific Coast Hospice services, or applications or post on a forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.
The Existence of Automated Decision-Making, Including Profiling
Pacific Coast Hospice does not make any decisions involving the use of algorithms or profiling that significantly affects you.
Integrity and Retention of Personal Information
Access to Personal Information
For information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Pacific Coast Hospice is not required to retain it by law or for legitimate business purposes.
We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. For access requests, a request may be made directly to the Privacy Officer.
Children & Education – California Privacy Disclosure
We understand the importance of taking extra precautions to protect the privacy and safety of children. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated, they may contact us through one of the options provided at the bottom of this page.
Pacific Coast Hospice may offer interactive services which allow you to post content to share publicly. At any time you can delete or remove content you have posted using the deletion or removal options within those services. If you have questions about how to remove content in a specific service or if you would like additional assistance with deletion you can contact our Privacy Officer. Although we may offer deletion capability for our services, you should be aware that the removal of content may not ensure complete or comprehensive removal of that content or information posted through the services.
Third‑Party Sites and Services
Pacific Coast Hospice websites, products, applications, and services may contain links to third-party websites, products, and services. Our services may also use or offer products or services from third parties. Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.
Our Companywide Commitment to Your Privacy
To make sure your personal information is secure, we communicate our privacy and security guidelines to Pacific Coast Hospice employees and strictly enforce privacy safeguards within the agency.
When a privacy question is received we have a team which triages your contact to address your issue. Where your issue may be more substantive in nature, we may request more information from you. All such substantive contacts receive a response within seven (7), days wherever possible – providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time. You may at any time refer your complaint to the relevant regulator in your jurisdiction if you are unsatisfied with a reply received from us. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.
Where your complaint indicates an improvement could be made in our handling of privacy issues we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.
PCH USA, LLC dba Pacific Coast Hospice 2919 S Ellsworth Rd. Ste 129, Mesa, AZ 85212