ll. WE HAVE A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION (PHI).

We are legally required to protect the privacy of your health information. We call this information "protected health information" or "PHI" for short and it includes information that can be used to identify you that we’ve created or received about your past, present or future health condition, the provision of healthcare to you, or the payment of this healthcare. We must provide you with this notice about our privacy practices that explains how, when and why we use and disclose your PHI. With some exceptions, we may not use or disclose any of your PHI than is necessary to accomplish the purpose of the use of the disclosure. We are legally required to follow the privacy practices that are described in this notice. We reserve the right to change the terms of this notice and our privacy policies at any time. Any changes will apply to the PHI we already have. You may request a copy of this notice from main office at any time.

lll. HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION.

We use and disclose health information for many different reasons. For some of these uses and disclosures, we need your prior consent or specific authorization. Below we describe the different categories of our uses and disclosures and give you some examples of each category.

A. Uses and Disclosures Relating to Treatment, Payment or Health Care Operations May Require Your Prior Written Consent. We may use and disclose your PHI for the following reasons:

1. For treatment. We may disclose your PHI to physicians, nurses, medical students and any other health care personnel who provide you with health care services or are involved in your care. For example, if you are being treated for a tumor, we may disclose your PHI to the surgeon or oncologist in order to coordinate your care.

2. To obtain payment for treatment. We may use and disclose your PHI in order to bill and collect payment for the treatment and services provided to you. For example, we may provide portions of your PHI to our billing agent and they would disclose this information to your health plan to get paid for the health care services we provided to you.

3. For health care operations. We may disclose your PHI in order to operate our medical group. For example, we may use your PHI in order to evaluate the quality of health care services that you received or to evaluate the performance of the health care professionals who provided health care services to you. We may also provide your PHI to our accountants, attorneys, consultants and others in order to make sure we are complying with the laws that affect us.

B. Certain Uses and Disclosures Do Not Require Your Consent. We may use and disclose your PHI without your consent or authorization for the following reasons:

1. When a disclosure is required by federal, state or local law, judicial or administrative proceedings, or law enforcement. For example, we make disclosures when a law requires that we report information to government agencies and law enforcement personnel about victims of abuse, neglect or domestic violence; when dealing with gunshot and other wounds; or when ordered in a judicial administrative proceeding.

2. For public health activities. For example, we will report information about births, deaths and various diseases to government officials in charge of collecting that information and we provide coroners, medical examiners and funeral directors necessary information relating to an individual’s death.

3. For health oversight activities. For example, we will provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.

4. To avoid harm. In order to avoid a serious threat to the health or safety of a person or to the public, we may provide PHI to law enforcement personnel or persons able to prevent or lessen such harm.

5. For specific government functions. We may disclose PHI of military personnel and veterans in certain situations. We may also disclose PHI for national security purposes, such as protecting the President of the United States or conducting intelligence operations.

6. For worker’s compensation purposes. We may provide PHI in order to comply with worker’s compensation laws.

7. Reminders of health-related benefits or services. We may use PHI to provide reminders about treatment alternatives or other health care services and benefits that we offer.

C. Two Uses and Disclosures Require You to Have to Opportunity to Object.

1. Patient directories. We may include your name in our patient directory for use by our sales and marketing staff, unless you object in whole or in part. The opportunity to consent may be obtained retroactively in emergency situations.

2. Disclosures to family, friends, and others. We may provide your PHI to a family member; friend or other person that you indicate is involved in your care or the payment for your health care, unless you object in whole or in part. The opportunity to consent may be obtained retroactively in emergency situations.

D. All Other Uses and Disclosures Require Your Prior Written Authorization. In any other situation not described in sections III A, B, and C above, we will ask for your written authorization before using or disclosing any of your PHI.

lV. WHAT RIGHTS YOU HAVE REGARDING YOUR PHI. You have the following rights with respect to your PHI:

A. The right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask that we limit how we use and disclose your PHI. We will consider you request but are not legally required to accept it. If we accept your request, we will put any limits in writing and abide by them except in emergencies. You may not limit the uses and disclosures that we are legally required or allowed to make.

B. The Right to Choose How We Send PHI to You. You have the right to ask that we send information to you to an alternative address (for example, sending information to you to your work address rather than your home address) or by alternate means (for example, e-mail instead of regular mail). We must agree to your request so long as we can easily provide it in the format you requested.

C. The Right to See and Get Copies of Your PHI. In most cases, you have the right to look at or get copies of your PHI that we have, but you must make the request in writing. If we don’t have your PHI but know who does, we will tell you how to get it. We will respond to you within 30 days after receiving your written request. In certain situations, we may deny your request. If we do, we will tell you, in writing, our reasons for the denial and explain your right to have your denial reviewed. If you request copies of your PHI, we will charge you $1.75 for each page. Instead of providing the PHI you requested, we may provide you with a summary or explanation of the PHI as long as you agree to that and to the cost in advance.

D. The Right to Get a List of the Disclosures We Have Made. You have the right to get a list of instances in which we have disclosed your PHI annually. The list will not include uses or disclosures that you have already consented to, such as those made for treatment, payment or health care operations, directly to you, to your family, or in our facility directory. We will respond within 60 days of receiving your request. The list we will give you will include disclosures made in the last year unless. The list will include the date of the disclosure, to whom your PHI was disclosed, a description of the information disclosed and the reason for disclosure. We will provide the list to you at no cost, but if you make more than one request in the same year, we will charge you $25.00 for each additional request.

E. The Right to Correct or Update Your PHI. If you believe that there is a mistake in your PHI or that a piece of important information is missing, you have the right to request that we correct the existing information or add the missing information. You must provide the request and your reason for the request in writing. We will respond within 60 days of receiving your request. We may deny your request in writing if the PHI is (i) correct and complete, (ii) not created by us, (iii) not allowed to be disclosed or (iv) not part of our records. Our written denial will state the reasons for the denial and explain your right to file a written statement of disagreement with the denial. If you don’t file one, you have the right to request that your request and our denial be attached to all future disclosures of your PHI. If we approve your request, we will make the change to your PHI, tell you that we have done it and tell others that need to know about the change to your PHI.

F. The Right to Get This Notice by E-Mail. You have the right to get a copy of this notice by e-mail. Even if you have agreed to receive notice via e-mail, you also have the right to request a paper copy of this notice.

V. HOW TO COMPLAIN ABOUT OUR PRIVACY PRACTICES
If you think that we may have violated your privacy right or you disagree with a decision we made about access to your PHI, you may file a complaint with the person listed in Section VI below. You also may send a written complaint to the Secretary of the Department of Health and Human Services. We will take no retaliatory action against you if you file a complaint about our privacy practices.

VI. PERSON TO CONTACT FOR INFORMATION ABOUT THIS NOTICE OR TO COMPLAIN ABOUT OUR PRIVACY PRACTICES. If you have any questions about this notice, contact Gary N. Onofry, Administrator at our main office at 561-659-0770.

VII EFFECTIVE DATE OF THIS NOTICE. This notice went in effect on October 1, 2002.

Release of Information Procedures

This policy is to define all of the procedures necessary in the release of patient information, specimens, slides, pathology reports and other patient related material and/or data. All members of Palm Beach Pathology will adhere to these procedures when releasing information. Failure to do so will result in disciplinary actions to include termination.

The following represents each item that is available for release:

1. Patient demographic information – this information will only be released to appropriate parties as specified above for the purposes of payment, insurance verification, patient identification or other legal matters.

2. Patient diagnostic information – this information will only be released to appropriate medical personnel responsible for the care and treatment of the patient or as noted above.

3. Cytology slides – slides will not be released outside of the laboratory. Legal or medical review of slides by consultants will be available on site. Under no circumstances will slides be removed from Palm Beach Pathology.

4. Histology material – additional slides can be processed from obtained specimens for the express use of outside legal or medical consultants.

5. Medical reports – copies of pathology or cytology reports will be released to appropriate medical and /or legal consultants. Other copies will be released subject to the policies noted above.

Who can approve the release of patient related information?

1. The Administrator will be the responsible party for releasing all items for legal purposes.

2. The Administrative Operations Manager will be responsible for releasing all items for non-legal purposes.

3. The Supervisor of Transcription will be responsible for releasing items to appropriate medical consultants.

Fee for the release of information:

1. A fee will be assessed based on the amount of information requested and the method of sending the information.

2. The Administrator or Operations Manager in his or her absence will determine the fee.