LFS Privacy Policy

Lutheran Family Services

NOTICE OF PRIVACY PRACTICES

Effective: 8/25/08

THIS NOTICE DESCRIBES HOW CONFIDENTIAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.

If you have any questions about this notice, please contact: Julie Douglass, Lutheran Family Services, Privacy Officer, 4100 Franklin Blvd., Cleveland, Ohio, (216) 281-2500, ext. 101

WHO WILL FOLLOW THE REQUIREMENTS OF THIS NOTICE.

This notice describes our agency’s practices and those of:

• Any health care professional authorized to enter information into your agency chart.

• Any member of a volunteer group we allow to help you while under the care of the agency.

• All agency personnel, full-time, part-time, contractual or any interns and/or volunteer help.

• The ADAMHS Board of Cuyahoga County and the Ohio Department of Alcohol and Drug Addiction Services comply with the terms of this notice.

ODADAS Confidentiality Requirements   As a certified agency of the Ohio Department of Alcohol and Drug Addiction Services, confidentiality of client records are strictly protected.   Agency staff shall not convey to a person outside of the agency that a client attends or receives services from the agency or disclose any information identifying a client as an alcohol or other drug services client unless 1) the client consents in writing for the release of information, 2) the disclosure is allowed by a court order, 3) the disclosure is made to qualified personnel for a medical emergency, or 4) for research, audit or program evaluation purposes.

Federal laws and regulations do not protect any threat to commit a crime, any information about a crime committed by a client either at the agency or against any person who works for the agency; or any information about suspected child abuse or neglect from being reported under state law to appropriate state or local authorities.

OUR PLEDGE REGARDING CLIENT INFORMATION:

We understand that information about you is personal and we are committed to protecting that information.  We create a record of the care and services you receive at the agency and need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by this agency.

We are required by law to:

• Assure information that identifies you is kept private;

• Give you this notice of our legal duties and privacy practices; and

• Follow the terms of the notice that is currently in effect.

HOW WE MAY USE AND DISCLOSE INFORMATION ABOUT YOU.

The following categories describe different ways that we use and disclose information.

• For Treatment We may use information about you to provide you with services at our agency.  We may disclose information about you to agency personnel who are involved in taking care of you.  For example, a group facilitator.

• For Payment We may use and disclose information about you so that the services you receive at the agency may be billed to and payment may be collected from you, an insurance company or a third party.  For example, we may need to give theADAMHS Board of Cuyahoga and/or the State Department (ODMH/ODADAS) information about services you have received.

• For Healthcare Operations We may use and disclose information about you for agency operations.  These uses and disclosures may be necessary to run the agency and make sure that all of our clients receive quality care.  For example, we may use information to review services and to evaluate the performance of the staff providing the services.  We may also combine information about a number of agency clients to determine what additional services the agency should offer, what services are not needed, and whether certain treatments are effective.

• Research Under certain circumstances, we may use and disclose information about you for research purposes.    We will always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are.

• Required By Law We will disclose information about you when required to do so by federal, state or local law.

• To Avert a Serious Threat to Health or Safety We may use and disclose information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.  Any disclosure would only be to someone able to help prevent the threat.

YOUR RIGHTS REGARDING INFORMATION ABOUT YOU

You have the following rights regarding information we have about you:

• Right to Request Restrictions   You have the right to request a restriction or limitation on the 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 Agency Privacy Officer.  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, for example, disclosures to insurance companies.  We are not required to agree to your request.

• Right to Request Confidential Communications   You have the right to request that we communicate with you about matters involving your care at the agency in a certain way or at a certain location.  For example, you can ask that we only contact you at work or by mail.  To request confidential communications, you must make your request in writing to the Agency Privacy Officer.   We will not ask you the reason for your request.  We will accommodate all reasonable requests.  Your request must specify how or where you wish to be contacted.

• Right of Access to Inspect and Copy   You have the right to inspect and copy information that may be used to make decisions about services provided to you.  To do so, you must submit your request in writing to the Agency Privacy Officer.   If you request a copy of the information, we may charge a fee.  We may deny your request to inspect and copy information if we determine, for example, that the information may present a danger to you or someone else.  If you are denied access to information, you may request that the denial be reviewed.  Another licensed health care professional chosen by the agency will review your request and the denial.  We will comply with the outcome of the review.

• Right to Amend If you feel that information we have about you is incorrect or incomplete you may ask us to amend the information.  You have the right to request an amendment for as long as the information is kept by the agency.  A request for an amendment must be made in writing and submitted to the agency Privacy Officer.  In addition, you must provide a reason that supports your request.  We may deny your request for an amendment if it is not in writing or does not include a reason to support the request.  In addition, we may deny your request if you ask us to amend information that:

1. Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;

2. Is not part of the information kept by or for the agency;

3. Is not part of the information which you would be permitted to inspect and copy; or

4. 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 medical information about you.  To request this list or accounting of disclosures, you must submit your request in writing to agency Privacy Officer.  Your request must state a time period that may not be longer than six years and may not include dates before April 14, 2003.  Your request should indicate in what form you want the list (for example, on paper, electronically).  The first list you request within a 12-month period will be free.  For additional lists, we may charge you for the costs of providing the list.  We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

• 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.

CHANGES TO THIS NOTICE

We reserve the right to change this notice.  We reserve the right to make the revised or changed notice effective for information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in the agency.  The notice will contain on the first page in the top center, the effective date.  In addition, each time you register at or are re-admitted to the agency for services, you will be offered a copy of the current notice in effect.

COMPLAINTS

You will not be penalized for filing a complaint.

If you believe your privacy rights have been violated, you may file a complaint with the agency or with the Secretary of the Department of Health and Human Services.  All complaints must be submitted in writing.

Complaints to: Lutheran Family Services Complaints to the Secretary HHS:

Privacy Officer HIPAA Complaint

4100 Franklin Blvd. 7500 Security Blvd C5-24-04

Cleveland, Ohio   44113 Baltimore, MD 21244

OTHER USES OF CLIENT INFORMATION

Other uses and disclosures of information not covered by this notice or the laws that apply to us will be made only with your written permission.  If you provide us permission to use or disclose information about you, you may revoke that permission, in writing, at any time.  If you revoke your permission, we will no longer use or disclose information about you for the reasons covered by your written authorization.  You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

02.13.2013