CONNECTICUT ORTHOPAEDIC SPECIALISTS, P.C.
PRIVACY NOTICE

USE AND DISCLOSURE OF PROTECTED INFORMATION

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

This Notice is effective beginning April 14, 2003.

Connecticut Orthopaedic Specialists (COS) is required by law to maintain the privacy of protected health information/records and to provide you with notice of its legal duties and privacy practices with respect to such information. The practice will abide by the terms of the notice currently in effect, however the practice reserves the right to change the terms of this notice as well as make the new provisions effective for all protected health information maintained. If there is a change, COS will inform you of this change at your next scheduled appointment or upon request. In addition, a copy of the effective notice will be posted at all times in the office with a date notifying you of the most recent update.

As a patient of COS, information about you must be used and disclosed to other parties for purposes of treatment, payment and healthcare operations. These uses and disclosures do not require your consent, and include, but are not limited to, a release of information contained in financial records, medical records, laboratory test results, medical history, treatment progress or any other related information, to:

  1. Your insurance company, self-funded or third-party health plan, Medicare, Medicaid, or any other person or entity that may be responsible for paying or processing for payment any portion of your bill of service;
  2. Any person or entity affiliated with or representing for purposes of administration, billing, and quality and risk management;
  3. Any hospital, nursing home, or other healthcare facility to which you may be admitted;
  4. Any assisted living or personal care facility of which you are a resident;
  5. Any physician providing you care;
  6. Any business associate of COS that agrees to abide by the privacy requirements regarding your protected health information; and
  7. Licensing and accrediting bodies, including the information containing the OASIS Data Set to the State agency acting as a representative of the Medicare/Medicaid program.

In addition, COS may contact you to provide appointment reminders or information about other health activities we provide. COS is also permitted to use or disclose information about you without consent or authorization in the following circumstances:

  1. Where the use of disclosure is required by another law, but only to the extent that is required and complies with such other law;
  2. For certain public health activities;
  3. Where the practice reasonably believes that you are a victim of abuse, neglect or domestic violence, but only to a government authorized to receive abuse, neglect or domestic violence complaints;
  4. Healthcare oversight activities;
  5. Certain judicial administrative proceedings;
  6. Certain law enforcement purposes;
  7. To coroners, medical examiners and funeral directors, in certain circumstances;
  8. For cadaveric organ or tissue donation purposes;
  9. For certain research purposes;
  10. To avert a serious threat to health and safety;
  11. For specialized government functions, including military and veterans' activities, national security and intelligence activities, protective services for the President and others, medical suitability determinations, correctional institution and custodial situations;
  12. For Workers' Compensation purposes.

COS is permitted to use or disclose information about you without consent or authorization provided you are informed in advance and given the opportunity to agree to or prohibit or restrict the disclosure in the following circumstances:

  1. To a family member, other close relative, close personal friend or other identified person, the information relevant to such person's involvement in your care or payment for care.
  2. To a public or private entity authorized by law or charter to assist in disaster relief efforts, but only for the purpose of coordinating with such entities.

Other uses and disclosures not specifically addressed earlier in this notice will be made only with your written authorization. In addition, Connecticut law requires an authorization to disclose highly sensitive information, including communicable diseases such as Human Immune Deficiency Virus (HIV) and Acquired Immune Deficiency Syndrome (AIDS), drug/alcohol abuse, psychiatric diagnosis and treatment records, and genetic testing information.

Examples of when authorization is required for COS to use or disclose your protected information include:

  1. Psychotherapy notes (notwithstanding the provisions that allow the use and disclosure of protected health information without consent and authorization for treatment, payment and healthcare operations, the law specifically requires an authorization to use or disclose psychotherapy notes) and
  2. Marketing, except if the communication is in the form of a face to face communication made by COS to you or a promotional gift of nominal value provided by COS.

These authorizations may be revoked, in writing, at any time, except in limited situations.

YOUR RIGHTS
The health Insurance Portability Accountability Act gives you certain rights with regard to your protected health information. Any of these rights may be exercised by contacting COS and in some situations, may require you to fill out a written request. You have the right subject to certain conditions to:

  1. Request restrictions on certain uses and disclosures of information about you for treatment, payment and healthcare operations, and to friends and family involved in your care. However, COS is not required to agree to the requested restriction;
  2. Receive confidential communication of protected health information;
  3. Inspect and copy protected health information;
  4. Amend protected health information;
  5. Receive an accounting of disclosures of protected health information; and
  6. Obtain a paper copy of this notice.

In addition, Connecticut state law may provide you with greater protection than the Health Insurance Portability Accountability Act. In situation where this is the case, COS will be in compliance with the applicable Connecticut law.

COMPLAINTS
If you believe that your privacy rights have been violated, you may complain to both COS and the Office of the Secretary of the U.S. Department of Health and Human Services. There will be no retaliation against you for filing a complaint. Complaints may be made to the COS Privacy Officer at 203-407-3508. We recommend that complaints be given to the Privacy Officer in writing, stating the specific incident(s) in terms of subject, date and other relevant matters. Complaints to the Office of the Secretary may be made in writing to the following address: The U.S. Department of Health and Human Services, Office of the Secretary, 200 Independence Avenue, S.W., Washington, D.C. 20201. Complaints may also be made by phone to 202-619-0257 or Toll Free: 877-696-6775.