Transitions Supportive Care takes the privacy of your health information seriously. We are required by law to maintain that privacy 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. 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.
USES AND DISCLOSURES OF HEALTH INFORMATION
Transitions Supportive Care (TSC) may use your health information for purposes of providing you treatment, obtaining payment for your care, and conducting health care operations. Your health information may be used or disclosed for other purposes only after TSC has obtained your written authorization. TSC has established a policy to guard
against unnecessary disclosure of your health information and does not sell health information.
THE FOLLOWING IS A SUMMARY OF CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR
WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:
To Provide Treatment. TSC may use your health information to coordinate care within TSC and with others involved in your care, such as your attending physician, members of the TSC interdisciplinary team, and other health care professionals who have agreed to assist TSC in coordinating care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. TSC also may disclose your health care information to individuals outside of TSC involved in your care including, pharmacists, suppliers of medical equipment, or other health care professionals that TSC uses in order to coordinate your care.
With your authorization, TSC may also disclose information about your care to family members or clergy for whom you have provided written authorization.
To Obtain Payment. TSC may include your health information in invoices to collect payment from third parties for the care you may receive from TSC. For example, TSC may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or TSC. TSC 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. TSC may use and disclose health care information for its own operations in order to facilitate the function of TSC and as necessary to provide quality care to all of TSC’s patients. Health care operations include such activities as:
• To meet legally required health care information reporting requirements
• Quality assessment and improvement activities.
• Activities designed to improve health or reduce healthcare costs.
• Protocol development, case management, and care coordination.
• Contacting health care providers and patients with information about treatment alternatives and other related functions that do not include treatment.
• Professional review and performance evaluation.
• Training programs including those in which students, trainees, or practitioners in health care learn under supervision.
• Training of non-healthcare professionals.
• Accreditation, certification, licensing, or credentialing activities.
• Review and auditing, including compliance reviews, medical reviews, legal services, and
• Business planning and development including cost management and planning-related analyses and formulary development.
• Business management and general administrative activities of BBH.
• Fundraising for the benefit of TSC and certain marketing activities.
For example, TSC may use your health information to evaluate its staff performance, combine your health information with other TSC patients in evaluating how to more effectively serve all TSC patients, or report legally required information to a state or federal agency, to disclose your health information to TSC staff and contracted personnel for training purposes, use your health information to contact you as a reminder regarding
a visit to you, and community information mailings (unless you tell us you do not want to be contacted). TSC will not release all or any part of its mailing list to any outside organization or individual. TSC does not market health-related products or services to patients nor will TSC give PHI to a telemarketer, door-to-door salesperson, or other marketers it may hire.
TSC may disclose certain information about you including your name, your general health status, and your religious affiliation.
TSC may disclose this information to people who ask for you by name. Please inform us if you do not want your information to be released.
For Fundraising Activities. TSC may use information about you including your name, address, phone number, and the dates you received care at TSC in order to contact you or your family to raise money for TSC. If you do not want TSC to contact you or your family, notify the Compliance Officer and indicate that you do not wish to be contacted. In no event will BBH sell patients’ personal health information and such practice requires an
authorization from you in advance.
Federal privacy rules allow or require TSC to use or disclose your health information without your consent or authorization for a number of reasons:
When Legally Required. TSC 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. TSC 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.
• To 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.
• To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
• To an employer about an individual who is a member of the workforce as legally required.
To Report Abuse, Neglect, or Domestic Violence. TSC is allowed to notify government authorities if TSC believes a patient is the victim of abuse, neglect, or domestic violence. TSC 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. TSC may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure, or disciplinary action. TSC, 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. TSC may disclose your health
information in the course of any judicial or administrative proceeding in response to an order of a court as expressly authorized by such order.
For Law Enforcement Purposes. TSC may disclose your health information to a law enforcement official for 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 TSC has a suspicion that your death was the result of criminal conduct including criminal conduct at TSC.
• In an emergency in order to report a crime.
To Coroners And Medical Examiners. TSC 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. TSC 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, TSC may disclose your health information prior to and in reasonable anticipation, of your death.
For Organ, Eye, or Tissue Donation. TSC 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. TSC may, under very select circumstances, use your health information for research.
Before TSC discloses any of your health information for such research purposes, the project will be subject to an extensive approval process. TSC 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. TSC may, consistent with applicable law and ethical standards of conduct, disclose your health information if TSC, 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 TSC 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. TSC may release your health information for worker’s compensation or similar programs.
Other than what is stated above, TSC will not disclose your health information other than with your written express authorization. If you or your representative authorizes TSC 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 BBH maintains:
• Right to request restrictions. You have the right to request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on TSC’s disclosure of your health information to someone who is involved in your care or the payment of your care. TSC is not required to agree to your request unless your request is for a restriction on a disclosure to a health plan for purposes of payment or health care
operations (and is not for purposes of treatment) and the medical information you are requesting to be restricted from disclosure pertains solely to a health care item or service for which you have paid out of pocket in full. If you wish to make a request for restrictions, please contact the Compliance Officer.
• Right to receive confidential communications. You have the right to request that TSC communicate with you in a certain way. For example, you may ask that TSC only conduct communications pertaining to your health information with you privately with no other family members present. If you wish to receive confidential communications, please contact the Compliance Officer. TSC 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 may be made to the Compliance Officer. If you request a copy of your health information, TSC may charge a reasonable fee for copying and assembling costs associated with your request. You have the right to request that
TSC provides you, an entity or a designated individual with an electronic copy of your electronic health record containing your health information. TSC may require you to pay the labor costs incurred by TSC in responding to your request.
• Right to amend health care information. If you or your representative believes that your health information records are incorrect or incomplete, you may request that TSC amend the records. That request may be made as long as the information is maintained by TSC. A request for an amendment of records must be made in writing to the Compliance Officer. TSC 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 TSC, if the records you are requesting are not part of BBH’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 TSC, the records containing your health information are accurate and complete.
• Right to accounting. You or your representative have the right to request an accounting of disclosures of your health information made by TSC for any reason other than for treatment, payment, or health operations. The request for an accounting must be made in writing to the Compliance Officer. The request should specify the time period for the accounting starting on December 14, 2021. Accounting requests may not be made for periods of time in excess of six years. TSC 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 has a right to a separate paper copy of this Notice at any time even if you or your representative has received this Notice previously. To obtain a separate paper copy, please contact the Compliance Officer. Anyone may also obtain a copy of the current version of TSC’s Notice of Privacy Practices at its website, www.transitions-support.org.
• In the event of a Breach of Health Information. TSC is required to timely notify you in the event of a breach that poses a significant risk of financial, reputation, or other harm to you. Any such notification will include a description of what happened, the types of information involved in the breach, steps we have taken and will take to mitigate any potentially harmful effects of the breach and further information for you on how to protect
yourself following the breach. In addition, you will be informed of contact information such as a toll-free phone number to call or e-mail and internet or postal address for you to receive further information.
DUTIES OF TRANSITIONS SUPPORTIVE CARE
TSC 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. TSC is required to abide by the terms of this Notice as may be amended from time to time. TSC reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all health information that it maintains. If TSC changes its Notice, TSC 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 TSC and to the Secretary of Health and Human Services if you or your representative believe that your privacy rights have been violated. Any complaints to TSC should be made in writing to the Compliance Officer. TSC encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.
IF YOU HAVE ANY QUESTIONS REGARDING THIS NOTICE, PLEASE CONTACT THE
COMPLIANCE OFFICER OF TRANSITIONS SUPPORTIVE CARE.
TSC’s contact person for all issues regarding patient privacy and your rights under the Federal privacy standards is:
Karl Brousard, Compliance Officer
Transitions Supportive Care
1669 Mahan Center Blvd
Tallahassee, FL 32308