Service Program for Older People

Privacy Notice


I. Introduction
SPOP is dedicated to maintaining the privacy and confidentiality of your health information, as required by law. We are required to provide you with this notice of privacy practices. We realize that these laws are complicated, but they are also important.

Information protected by privacy laws, “protected health information,” is individually identifiable health information that we receive from you or from others (such as your health care provider). It may include information about your past or present physical or mental health, the provision of your health care, and payment for your health care services.

Your rights regarding your protected health information (PHI) are described in this notice. You also need to be aware that we may use and disclose your protected health information (PHI) for treatment, payment, health care operations and other purposes permitted or required by law, as described below.

II.    How We May Use and Disclose Your Health Information
A.  Uses and Disclosures for Treatment, Payment and Operations

As a policy, SPOP makes every effort to discuss in advance the use or disclosure of protected health information and to obtain the client’s consent.  However, you should be aware that we are legally permitted to disclose information in the following circumstances.

For Treatment. To provide and coordinate your health care and related services.  We may disclose information to our clinicians and other staff or to health care providers outside of SPOP.

For Payment.  In order to bill for the services you receive and to collect payment from your health plan or other third party payer.  Examples include: determination of eligibility or review of services to determine medical necessity. We may also disclose to outside providers, such as ambulette services, so that they can bill you.

For Health Care Operations. To run our organization and make sure our customers receive quality care. These activities may include: staff training and supervision, business planning and development, quality improvement, licensing, accreditation, and other general administrative activities. In addition, we may call you at home to remind you of your appointment.

For Health-Related Benefits and Services. To tell you about health-related benefits or services that may be of interest to you.  If you do not want us to provide you with this information, you must notify your Program Director in writing.

Fundraising Activities. To contact you to raise money for our programs and services.  If you do not want such contact, you must notify your Program Director in writing.

 B.    Disclosures to Persons Involved in Your Care
Disclosures to persons involved in your care may be made without your written authorization, but you will have an opportunity to object. If you are physically present and have the capacity to make health care decisions, your information may only be disclosed to persons you designate. If you are unable to make decisions, we will provide health information to guardians (and other persons designated to participate in your care) and, if applicable, the responsible state agency. We may disclose your health information in the following situations:

To notify family members, friends, and others responsible for your care.
To give news of your condition to group members or other program participants.
In disaster relief efforts and other emergencies.

 C.    Uses and Disclosures Required by Law.
In some serious situations, SPOP is required by law to use or disclose your protected health information.  You should be aware that we are required to disclose your information without your consent in the following circumstances:

In Emergencies, to those treating you.
Research.  We may disclose your health information to researchers when their research has been approved by an Institutional Review Board or similar privacy board and has protocols to protect the privacy of your information.
To Avert a Serious Threat to health or safety to you or another person.
Public Health Activities.  Examples include: reports of child abuse and neglect and domestic violence, vital events such as birth or death, FDA recalls, and information about communicable diseases.
Health Oversight Activities. To agencies such as Medicare or Medicaid, or to government agencies that oversee the health care system.
Disclosure in Legal Proceedings. When we receive a court order or subpoena for your health information.
Law Enforcement Activities.  To locate suspects or missing persons, to report criminal activity on our premises, in dangerous situations, and when clients are victims of crimes. These disclosures will only be made when they are in the client’s best interest or when required by law.
Medical Examiners or Funeral Directors. 
Military and Veterans.  To military command authorities, and to determine your eligibility for Veterans’ benefits.
National Security and Protective Services for the President and Others.  We may be required to disclose medical information about you to authorized federal officials engaging in national security activities.
Inmates.  If you are under the custody of a law enforcement official.
Workers’ Compensation.  To comply with the State Workers’ Compensation Law.
As Required By Federal, State, or Local Law. In any other situation required by law.

III. Use and Disclosure of Your Health Information with Your Permission.
Disclosure not described in Section II of this Notice of Privacy Practices will generally only be made with your written permission, called an “authorization.”  You have the right to revoke an authorization at any time.

IV. Your Rights Regarding Your Health Information.
All of these requests must be submitted in writing to your Program Director.

A.  Right to Inspect and Copy.
You have the right to request an opportunity to inspect and copy health information in your clinical chart and/or billing records.

B. Right to Request an Amendment.
You have the right to request an amendment to your health records.

C.  Right to an Accounting of Disclosures.
You have the right to request that we provide you with an accounting (list) of disclosures other than those made for purposes of treatment, payment, or health care operations.

D.  Right to Request Restrictions. 
You have the right to request restrictions on the health information we disclose for treatment, payment or health care operations.

E.  Right to Request Confidential Communications.
You have the right to request that we communicate with you only in a certain location or through a certain method.

F.  Right to Obtain a Paper Copy of Privacy Notice upon Request.

G. Right to File a Complaint.

If you believe your privacy rights have been violated, you may file a complaint in writing with your Program Director or with the United States Department of Health and Human Services.  Please see our grievance policy and procedures.  We will not penalize you for filing a complaint.

V.  Changes to this Notice
We reserve the right to change the terms of our Notice of Privacy Practices. We will post a copy of the current Notice of Privacy Practices at each of our offices.

VI.  Compliance
We will abide by the notice currently in effect and will inform clients of our legal duties and privacy practices related to protected health information. If a Program Director is contacted about a privacy issue, the Compliance Officer will be consulted.

If you have any questions about this Privacy Notice, please contact the Program Director at 212-787-7120 or SPOP’s Compliance Officer at ext. 528.

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