Notice of Privacy Practices
Your Rights and Your Child’s Records
Revision Date: September 23, 2013
THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION ABOUT YOUR CHILD MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Information that relates to your child’s health or treatment and that identifies your child is protected under the Health Insurance Portability and Accountability Act (HIPAA). Early Intervention Specialists (EIS) makes a record of the services we provide and we may receive such records from others. We use these records to provide quality services, obtain payment for these services, and to enable us to meet our professional and legal obligations to operate this agency properly. We understand the importance of privacy and are committed to maintaining the confidentiality of your child’s protected health information. This notice describes how EIS may use or disclose your child’s protected health information and with whom that information may be shared. This notice also describes your rights and our legal obligations with respect to your child’s protected health information.
EIS is required by law to:
• Make sure your child’s protected health information (PHI) is kept private
• Provide to you this notice of our responsibilities and privacy practices related to the use and disclosure of your child’s protected health information
• Notify affected individuals following a breach of unsecured protected health information
How EIS May Use or Disclose Your Child’s Protected Health Information:
Protected health information (PHI) is individually identifiable health information. This includes demographics (for example age, address, or e-mail address) and information related to past, present, or future physical or mental health conditions, or any related health care or early intervention services. EIS collects this information in order to deliver Early Intervention services and stores this information in your child’s record. The record is the property of EIS, but the information in the record belongs to you. This protection covers written and electronic information. This protection lasts as long as the information is in the hands of EIS. The law permits us to use or disclose your child’s protected health information for the following purposes:
We use protected health information about you to provide your early intervention services. We disclose protected health information to our employees who are involved in providing and monitoring the services. For example, we will share your child’s protected health information with the EIS early interventionist assigned to provide your services and the administrative staff managing your child’s record.
Your child’s protected health information may be shared with funders (Medical Assistance Office, Pennsylvania Department of Public Welfare), related county early intervention programs, government monitors (Office of Child Development and Early Learning, Office of Special Education Programs) or Department of Children, Youth and Families, without your additional consent.
As required by law, EIS will use and disclose your child’s protected health information without your consent to report suspected abuse, neglect or domestic violence, or respond to judicial or administrative proceedings (such as response to subpoena, court order, or warrant), or to respond to law enforcement officials.
We may, and are sometimes required by law, to disclose your child’s protected health information to public health authorities for purposes related to: preventing or controlling disease, injury or disability; reporting child, elder or dependent adult abuse or neglect; reporting domestic violence; reporting to the Food and Drug Administration problems with products and reactions to medications; and reporting disease or infection exposure.
We may, and are sometimes required by law, to disclose your health information to appropriate persons in order to prevent or lessen a serious and imminent threat to the health or safety of a particular person or persons or the general public.
The information from your child’s record that is shared must be limited to what is necessary for that specific incident, except if the information is to be shared for treatment purposes. Then, the entire record may be shared.
EIS has established business practices to protect the privacy of your child’s records. These include: staff training, naming a privacy officer to assist with complaints, and establishing business guidelines for privacy with others who have contracts with EIS.
When EIS May Not Use or Disclose Your Child’s Protected Health Information:
Except as described in this Notice of Privacy Practices, and consistent with its legal obligations, EIS will not use or disclose protected health information which identifies your child without your written authorization. If you do authorize EIS to use or disclose your child’s protected health information for another purpose, you may revoke your authorization in writing at any time.
Protected Health Information Rights:
Right to Consent: You have the right to know how your child’s early intervention service records will be used, and with whom the information will be shared. You have the right to give informed consent before providers can use or share your child’s protected health information, even for routine purposes such as treatment, payment, and the operation of the health plan. EIS requires that treatment and participation in services is based on obtaining your consent.
Right to Request Special Privacy Protections: You have the right to refuse consent to share your child’s protected health information. If you do give consent, you have the right to limit the information given if it is to be used for non-routine purposes, such as sale or marketing. You have the right to limit the release of your child’s protected health information to specific persons. Your request should be in writing and EIS will notify you in writing as to whether your request can be honored.
Right to Request Confidential Communications: You have the right to ask that communications from those requesting protected health information be made in a certain way (such as no phone calls, written requests only). Your request will be honored unless it is unreasonable or creates too great a burden on EIS.
Right to Inspect and Copy: You have the right to see and copy your child’s record with limited exceptions. To access your child’s file, you must submit a written request detailing what information you want access to, and whether you want to inspect the record or to obtain a copy. We may deny your request under limited circumstances.
Right to an Accounting of Disclosures: You have the right to receive an accounting of disclosures of your child’s protected health information made by EIS, except for those instances where EIS does not have to account for the disclosures as described elsewhere in this notice.
Right to Amend or Supplement: You have the right to ask for a change to your child’s record if you believe it contains incorrect or unnecessary information. Your request must be in writing. EIS will decide whether your request can be honored and will notify you if your request has been denied. The information in your child’s record will be kept for a minimum of seven years after he/she is discharged from early intervention services with EIS.
Right to a Paper or Electronic Copy of this Notice: You have the right to notice of our legal duties and privacy practices with respect to your child’s protected health information, including a right to a paper copy of this Notice of Privacy Practices even if you have previously requested its receipt by e-mail.
In the case of a breach of unsecured protected health information, we will notify you as required by law.
Changes to this Notice of Privacy Practices:
EIS reserves the right to amend this Notice of Privacy Practices at any time in the future. Until such amendment is made, we are required by law to comply with the terms of this Notice currently in effect. After an amendment is made, the revised Notice of Privacy Practices will apply to all protected health information that we maintain, regardless of when it was created or received. We will keep a copy of the current noticed posted on our website or you may request a copy from EIS.
If you believe these privacy rights have been violated, you may file a written complaint with the EIS Privacy Officer, with the United States Secretary of Health and Human Services, or with the Office of Civil Rights Compliance.
You will not be penalized in any way for filing a complaint.
EIS Privacy Officer:
Jenni Galbraith, CEO
Phone: 412-364-2446 or 717-428-0150
Western Region: 9800b McKnight Rd. Ste 150 Pittsburgh, PA 15237
Central Region: 6864 Susquehanna Trail S. York, PA 17403