PRIVACY POLICY:


CORPORATE COMPLIANCE POLICY:

We are committed to total integrity in our business dealings. To support this commitment, you are required to report any and all concerns of unlawful activity to the Corporate Compliance Officer (CCO). The address is 2723 Summer Oaks Drive, Bartlett, Tennessee 38134. You may also email the CCO at ComplianceLine@Orianna.com or call the confidential toll-free 800 line at 1-844-628-7571.

NOTICE OF PRIVACY PRACTICES

Effective Date: April 1, 2010

THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED TO OTHERS AND HOW YOU CAN GAIN ACCESS TO YOUR MEDICAL INFORMATION.

PLEASE REVIEW THE BELOW CAREFULLY.

If you have any questions about this notice, please contact the Privacy Office (Administrator) at the facility or the Corporate Compliance Office at (901) 201-6440.

WHO WILL FOLLOW THIS NOTICE.

This notice describes the center’s practices and that of:

  • The center’s medical staff comprised of physicians and and credentialed non-physician health care professionals.
  • Center volunteers.
  • Center personnel.
OUR EMPLOYEE CODE OF CONDUCT:

We understand that your medical information is private.  We are committed to protecting your medical information.  We create a record of the care and services you receive at the center to provide you with quality care and to comply with legal requirements.  This notice applies to all of your medical records generated by the center, whether made by center personnel or your personal doctor.

Confidentiality Policy:  All center employees have read and signed an agreement to abide by a corporate  confidentiality policy as a condition of employment.

CP-AP/HI (9/10)

This notice of Privacy Practices will tell you about the ways in which we may use and disclose your medical information about you.  We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.

We are required by law to keep private any medical information that identifies you;


HOW WE MAY USE AND DISCLOSE YOUR MEDICAL INFORMATION.

The following categories describe different ways that we use and disclose medical information.  For better understanding, we have provided some examples in each category.  

For Treatment: We may disclose your medical information to doctors, nurses, technicians, medical students, students in other health care fields, or other center personnel who are involved in taking care of you in the center.  For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process.  In addition, the doctor may need to tell the dietician if you have diabetes so that we can arrange for appropriate meals.  Different departments of the center also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work, and x-rays.  We may disclose medical information about you to people outside the center, such as family members assisting you or other health care providers, such as medical equipment providers, or hospitals.  We also may sue your medical information to contact you to check that you are progressing in your recovery.

For Payment:  We may use and disclose your medical information for billing and collection from you, an insurance company, or a third party.  We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.   We may share your information with other health care providers who treat you during your stay in the center, such as an ambulance service or a physician who serves as a consultant during your treatment.

For Health Care Operations:  We may use and disclose your medical information for center operations.  These uses and disclosures are necessary to run the center and make sure that all our residents receive quality care.  For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you.  We may also combine medical information about many center residents to decide what additional services the center should offer, what services are not needed, and whether certain new treatments are effective.  We may also disclose information to doctors, nurses, technicians, medical students, students in other health care fields, and other center personnel for review and educational purposes.  We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who you are.

Photographs:  We may photograph residents for security and identification purposes.

Resident Satisfaction Surveys:  We may use a limited amount of information about you to conduct resident satisfaction surveys by telephone, written communications, and via use of center websites.

Family Satisfaction Surveys: We may use a limited amount of information about you to conduct family satisfaction surveys to telephone, written communications, and visa use of center websites.

Health Awareness Materials:  We may use your information to send general health information to your family to create awareness in the community of important health topics.

Health Fairs/Screenings:  We may use your information to contact your family with the results of any screenings that are not available on the day of a health fair/screening.  

Personal Representatives:  If you or a court has authorized another individual to act on your behalf, we will share information regarding your treatment with your personal representative unless we believe that the sharing of information would jeopardize your health & safety. 

Appointment Reminders:  We may disclose medical information to your family or a personal representative as a reminder that you have an appointment for treatment or medical care at your physician’s office, a hospital, or care planning.  This practice includes in-person contact or contact by telephone and/or written communication.      

Emergencies:  We may use or disclose reasonably necessary information about you to notify your family, personal representative, or other person responsible for your care that you are in the hospital and your general condition.  In the event of a disaster, we may disclose reasonably necessary medical information about you to an entity assisting in a disaster relief effort (such as the Red Cross).

As Required By Law:  We will disclose your medical information when required to do so by federal, state, or local laws, rules and regulations.

To Avert a Serious Threat to Health or Safety:  We may use and disclose your medical information to law enforcement and government agencies when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another individual. 


SPECIAL SITUATIONS

Organ and Tissue Donation:  If you are an organ donor, we may release medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

Access by Parents:  Some state laws concerning minors permit or require disclosure of protected health information to parents, guardians, and persons acting in a similar status.  We will act consistently with the law of the state where the treatment is provided and will make disclosures following such laws.

Military and Veterans:  If you are a member of armed forces, we may release medical information about you as required by military command authorities.  We may also release medical information about foreign military personnel to the appropriate foreign military authority.

Public Health Risks:  We may disclose your medical information for public health purposes.  These purposes include the following:

  • To prevent or control disease, injury or disability;
  • To report births and deaths;
  • To report suspected child or adult abuse or neglect;
  • To report reactions to medications or problems with products;
  • To notify people of recalls of products they may be using;
  • To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
  •  To notify the appropriate government authority if we believe a resident has been the victim of abuse, neglect, or domestic violence.

Health Oversight Activities:  We may disclose medical information to government agencies for audits, investigations, inspections, and licensure purposes. 

Lawsuits and Disputes:  If you are involved in a lawsuit or a dispute, we may disclose your medical information in response to a court or administrative order, subpoena, or legal defense in accordance with applicable local, state and federal laws, rules, and regulations.. 

Coroners, Medical Examiners and Funeral Directors:  We may release reasonably necessary medical information to a coroner, medical examiner, or funeral director. 

Inmates:  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release reasonably necessary medical information about you to the correctional institution or law enforcement official.   This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.


 YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU

You have the following rights regarding your medical information maintained by the center;

Right to Inspect and Copy:  You have the right to inspect and copy your medical information and records included medical and billing records.

To inspect and copy your medical information and records, you must submit your request orally or in writing to the center’s Medical Records Department or to the Business/Billing Office for billing records.  If you request a copy of the information, you may be charged a fee for the cost of copying, mailing, or other supplies associated with your request.

We may deny your request to inspect and copy in certain, limited circumstances.   If you are denied access to medical information, you may appeal the denial. 

Right to Amend:  If you feel that your medical information is incorrect or incomplete, you may ask us to amend the information. 

To request an amendment, your request must be made in writing and submitted to the center’s Medical Records Department, Attention:  Privacy Contact.  In addition, you must provide a reason that supports your request. 

We may deny your request if you ask us to amend information that:

  • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
  • Is not part of the medical information kept by or for the center;
  • Is not part of the information which you would be permitted to inspect and copy; or
  • Is accurate and complete.

Right to an Accounting of Disclosures:  You have the right to request an “accounting of disclosures.”  This is a list of the disclosures we made of your medical information for reasons other than treatment, payment or health care operations.  For example, an accounting of disclosures would include disclosures that we are request by law to make, such as reporting communicable diseases to the county health department.

To request this accounting of disclosures, you must submit your request in writing to the center’s Medical Records Department, Attention: Privacy Contact.  Your request must state a time period, which may not include dates longer than six years prior to the date on which the account is requested.  The first list you request within a 12-month period will be free.  For additional lists, you may be charged for the costs of providing the list.  We will notify you of the costs involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions:  You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment, or health care operations.

To request restrictions, you must make your request in writing to the center.  In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.

Right to Request Confidential Communications:  You have the right to request that we communicate with you about medical matters in a certain way or at a certain location.  For example, you can ask that we only contact you at work.  However, you must provide us with an address to which we can send all written correspondence, including your bill. 

At the time of admission to the center, you may request a change to your confidential communications address and phone number by submitting a written request to the Medical Records Department, Attention: Privacy Contact.  We will not ask you the reason for your request.  We will accommodate reasonable requests.  Your request must specify how or where you wish to be contacted.

Right to a Paper Copy of This Notice:  You have the right to a paper copy of this notice.  You may ask us to give you a copy of this notice at any time.  Paper copies are available in each center’s admission area.


 CHANGES TO THE NOTICE

We reserve the right to change this notice.  We reserve the right to amend this notice.  We will post a copy of the current notice in the center.  The notice will contain on the first page, in the top right-hand corner, the effective date.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with the facility.  To file a privacy complaint with the facility, contact the Privacy Officer (Administrator) at your facility, or submit in writing to the Corporate Compliance Office, 2723 Summer Oaks Drive, Bartlett, Tennessee, 38134 or e-mail to ComplianceLine@orianna.com.
 

You will not be penalized for filing a complaint.

OTHER USES OF MEDICAL INFORMATION

Other uses and disclosures of medical information not covered by this notice will only be made with your written authorization.  If you provide us authorization to use or disclose your medical information, you may revoke that authorization, in writing, at any time.  You understand that we are unable to rescind any authorized disclosures and that the center is required to maintain your records in accordance with local, state and federal laws, rules and regulations.

NONDISCRIMINATION POLICY:

As a recipient of Federal financial assistance, none of our centers exclude, deny benefits to, or otherwise discriminate against any person on the grounds of race, color, or national origin, or on the basis of disability or age in admission to, participation in, or receipt of the services and benefits under any of its programs and activities, whether carried out by the center directly or through a contractor or any other entity with which the center arranges to carry out its programs and activities. This statement is in accordance with the provisions of Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and Regulations of the U.S. Department of Health and Human Services issued pursuant to these statutes at Title 45 Code of Federal Regulations Parts 80, 84, and 91.