Notice of Privacy Practices
Effective Date: 02/5/2020
Privacy Officer: Debra Plemmons, VP of Nursing 970-724-3121
NOTICE OF PRIVACY PRACTICES
Effective Date: 06/08/13
Reviewed: 09/01/2014
Updated: February 5, 2020
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.
We understand the importance of privacy and are committed to maintaining the confidentiality of
your medical information. We make a record of the medical care we provide and may receive
such records from others. We use these records to provide or enable other health care providers
to provide quality medical care, to obtain payment for services provided to you as allowed by your
health plan and to enable us to meet our professional and legal obligations to operate this medical
practice properly. We are required by law to maintain the privacy of protected health information,
to provide individuals with notice of our legal duties and privacy practices with respect to protected
health information, and to notify affected individuals following a breach of unsecured protected
health information. This notice describes how we may use and disclose your medical information.
It also describes your rights and our legal obligations with respect to your medical information. If
you have any questions about this Notice, please contact our Privacy Officer listed above.
A. How This Medical Practice May Use or Disclose Your Health Information
Middle Park Medical Center – Granby (MPMC-G) collects health information about you and stores
it an electronic health record/personal health record. This is your medical record. The medical
record is the property of this medical practice, but the information in the medical record belongs
to you. The law permits us to use or disclose your health information for the following purposes:
1. Treatment: We use medical information about you to provide your medical care. We disclose
medical information to our employees and others who are involved in providing the care you
need. For example, we may share your medical information with other physicians or other
health care providers who will provide services that we do not provide. Or we may share this
information with a pharmacist who needs it to dispense a prescription to you, or a laboratory
that performs a test. We may also disclose medical information to members of your family or
others who can help you when you are sick or injured, or after you die.
2. Payment: We use and disclose medical information about you to obtain payment for the
services we provide. For example, we give your health plan the information it requires before
it will pay us. We may also disclose information to other health care providers to assist them
in obtaining payment for services they have provided to you.
3. Health Care Operations: We may use and disclose medical information about you to operate
this medical practice. For example, we may use and disclose this information to review and
improve the quality of care we provide, or the competence and qualifications of our
professional staff. Or we may use and disclose this information to get your health plan to
authorize services or referrals. We may also use and disclose this information as necessary
for medical reviews, legal services and audits, including fraud and abuse detection and
compliance programs and business planning and management. We may also share your
medical information with our “business associates,” such as our billing service, that perform
administrative services for us. We have a written contract with each of these business
associates that contains terms requiring them and their subcontractors to protect the
confidentiality and security of your medical information. We may also share your information
with other health care providers, health care clearinghouses or health plans that have a
relationship with you, when they request this information to help them with their quality
assessment and improvement activities, their patient-safety activities, their population-based
efforts to improve health or reduce health care costs, their protocol development, case
management or care-coordination activities, their review of competence, qualifications and
performance of health care professionals, their training programs, their accreditation,
certification or licensing activities, or their health care fraud and abuse detection and
compliance efforts.
4. Appointment Reminders: We may use and disclose medical information to contact and
remind you about appointments. If you are not home, we may leave this information on your
answering machine or in a message left with the person answering the phone.
5. Sign In Sheet: We may use and disclose medical information about you by having you sign
in when you arrive at our office. We may also call out your name when we are ready to see
you.
6. Notification and Communication with Family: We may disclose your health information to
notify or assist in notifying a family member, your personal representative or another person
responsible for your care about your location, your general condition or, unless you had
instructed us otherwise, in the event of your death. In the event of a disaster, we may disclose
information to a relief organization so that they may coordinate these notification efforts. We
may also disclose information to someone who is involved with your care or helps pay for
your care. If you are able and available to agree or object, we will give you the opportunity to
object prior to making these disclosures, although we may disclose this information in a
disaster even over your objection if we believe it is necessary to respond to the emergency
circumstances. If you are unable or unavailable to agree or object, our health professionals
will use their best judgment in communication with your family and others.
7. Marketing: Provided we do not receive any payment for making these communications, we
may contact you to give you information about products or services related to your treatment,
case management or care coordination, or to direct or recommend other treatments,
therapies, health care providers or settings of care that may be of interest to you. We may
similarly describe products or services provided by this practice and tell you which health
plans this practice participates in. We may also encourage you to maintain a healthy lifestyle
and get recommended tests, recommend that you participate in a disease management
program, provide you with small gifts, tell you about government sponsored health programs
or encourage you to purchase a product or service when we see you, for which we may be
paid. Finally, we may receive compensation which covers our cost of reminding you to take
and refill your medication, or otherwise communicate about a drug or biologic that is currently
prescribed for you. We will not otherwise use or disclose your medical information for
marketing purposes or accept any payment for other marketing communications without your
prior written authorization. The authorization will disclose whether we receive any
compensation for any marketing activity you authorize, and we will stop any future marketing
activity to the extent you revoke that authorization.
8. Sale of Health Information: We will not sell your health information without your prior written
authorization. The authorization will disclose that we will receive compensation for your health
information if you authorize us to sell it, and we will stop any future sales of your information
to the extent that you revoke that authorization.
9. Required by Law: As required by law, we will use and disclose your health information, but
we will limit our use or disclosure to the relevant requirements of the law. When the law
requires us to report abuse, neglect or domestic violence, or respond to judicial or
administrative proceedings, or to law enforcement officials, we will further comply with the
requirement set forth below concerning those activities.
10. Public Health: We may, and are sometimes required by law to disclose your 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. When
we report suspected elder or dependent adult abuse or domestic violence, we will inform you
or your personal representative promptly unless in our best professional judgment, we believe
the notification would place you at risk of serious harm or would require informing a personal
representative we believe is responsible for the abuse or harm.
11. Health Oversight Activities: We may, and are sometimes required by law to disclose your
health information to health oversight agencies during the course of audits, investigations,
inspections, licensure and other proceedings, subject to the limitations imposed by law.
12. Judicial and Administrative Proceedings: We may, and are sometimes required by law, to
disclose your health information in the course of any administrative or judicial proceeding to
the extent expressly authorized by a court or administrative order. We may also disclose
information about you in response to a subpoena, discovery request or other lawful process
if reasonable efforts have been made to notify you of the request and you have not objected,
or if your objections have been resolved by a court or administrative order.
13. Law Enforcement: We may, and are sometimes required by law, to disclose your health
information to a law enforcement official for purposes such as identifying of locating a
suspect, fugitive, material witness or missing person, complying with a court order, warrant,
grand jury subpoena and other law enforcement purposes.
14. Coroners: We may, and are often required by law, to disclose your health information to
coroners in connection with their investigations of deaths.
15. Organ or Tissue Donation: We may disclose your health information to organizations involved
in procuring, banking or transplanting organs and tissues.
16. Public Safety: 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 the general public.
17. Specialized Government Functions: We may disclose your health information for military or
national security purposes or to correctional institutions or law enforcement officers that have
you in their lawful custody.
18. Worker’s Compensation: We may disclose your health information as necessary to comply
with worker’s compensation laws. For example, to the extent your care is covered by workers’
compensation, we will make periodic reports to your employer about your condition. We are
also required by law to report cases of occupational injury or occupational illness to the
employer or workers’ compensation insurer.
19. Change of Ownership: In the event that this medical practice is sold or merged with another
organization, your health information/record will become the property of the new owner,
although you will maintain the right to request that copies of your health information be
transferred to another physician or medical group.
20. Breach Notification: In the case of a breach of unsecured protected health information, we
will notify you as required by law. If you have provided us with a current email address,
we may use email to communicate information related to the breach. In some
circumstances our business associate may provide the notification. We may also
provide notification by other methods as appropriate
21. Fundraising: We may use or disclose your demographic information, the dates that you
received treatment, the department of service, your treating physician, outcome information
and health insurance status in order to contact you for our fundraising activities. If you do not
want to receive these materials, notify the Privacy Officer listed at the top of this Notice of
Privacy Practices and we will stop any further fundraising communications. Similarly, you
should notify the Privacy Officer if you decide you want to start receiving these solicitations
again.
B. When This Medical Practice May Not Use or Disclose Your Health Information
Except as described in this Notice of Privacy Practices, this medical practice will, consistent with
its legal obligations, not use or disclose health information which identifies you without your written
authorization. If you do authorize this medical practice to use or disclose your health information
for another purpose, you may revoke your authorization in writing at any time.
C. Your Health Information Rights
1. Right to Request Special Privacy Protections: You have the right to request restrictions on
certain uses and disclosures of your health information by a written request specifying
what information you want to limit, and what limitations on our use or disclosure of that
information you wish to have imposed. If you tell us not to disclose information to your
commercial health plan concerning health care items or services for which you paid for in
full out-of-pocket, we will abide by your request, unless we must disclose the information
for treatment or legal reasons. We reserve the right to accept or reject any other request,
and will notify you of our decision.
2. Right to Request Confidential Communications: You have the right to request that you
receive your health information in a specific way or at a specific location. For example,
you may ask that we send information to a particular e-mail account or to your work
address. We will comply with all reasonable requests submitted in writing which specify
how or where you wish to receive these communications.
3. Right to Inspect and Copy: You have the right to inspect and copy your health information,
with limited exceptions. To access your medical information, you must submit a written
request detailing what information you want access to, whether you want to inspect it or
get a copy of it, and if you want a copy, your preferred form and format. We will provide
copies in your requested form and format if it is readily producible, or we will provide you
with an alternative format you find acceptable, or if we can’t agree and we maintain the
record in an electronic format, we will provide your choice of a readable electronic or
hardcopy format. We will also send a copy to any other person you designate in writing.
We will charge a reasonable fee which covers our costs for labor, supplies, postage, and
if requested and agreed to in advance, the cost of preparing an explanation or summary,
as allowed by federal and Colorado state law. We may deny your request under limited
circumstances. If we deny your request to access your child’s records or the records of an
incapacitated adult you are representing because we believe allowing access would be
reasonably likely to cause substantial harm to the patient, you will have a right to appeal
our decision.
4. Right to Amend: You have a right to request that we amend your health information that
you believe is incorrect or incomplete. You must make a request to amend in writing, and
include the reasons you believe the information is inaccurate or incomplete. We are not
required to change your health information, and will provide you with information about
this medical practice’s denial and how you can disagree with the denial. We may deny
your request if we do not have the information, if we did not create the information (unless
the person or entity that created the information is no longer available to make the
amendment), if you would not be permitted to inspect or copy the information at issue, or
if the information is accurate and complete as is. If we deny your request, you may submit
a written statement of your disagreement with that decision, and we may, in turn, prepare
a written rebuttal. All information related to any request to amend will be maintained and
disclosed in conjunction with any subsequent disclosure of the disputed information.
5. Right to an Accounting of Disclosures: You have a right to receive an accounting of
disclosures of your health information made by this medical practice, except that this
medical practice does not have to account for the disclosures provided to you or pursuant
to your written authorization, or as described in paragraphs 1 (treatment), 2 (payment), 3
(health care operations), 6 (notification and communication with family) and 18
(specialized government functions) of Section A of this Notice of Privacy Practices or
disclosures for purposes of research or public health which exclude direct patient
identifiers, or which are incident to a use or disclosure otherwise permitted or authorized
by law, or the disclosures to a health oversight agency or law enforcement official to the
extent this medical practice has received notice from that agency or official that providing
this accounting would be reasonably likely to impede their activities.
6. Right to a Paper or Electronic Copy of this Notice. You have a right to notice of our legal
duties and privacy practices with respect to your 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.
If you would like to have a more detailed explanation of these rights or if you would like to
exercise one or more of these rights, contact our Privacy Officer listed at the top of this
Notice of Privacy Practices
D. Changes to this Notice of Privacy Practices
We reserve 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 this Notice. After an amendment is
made, the revised Notice of Privacy Protections will apply to all protected health information that
we maintain, regardless of when it was created or received. We will keep a summary of the current
notice posted in our reception area, and a copy will be available at each appointment. We will
also post the current notice on our website.
E. Complaints
Complaints about this Notice of Privacy Practices or how this medical practice handles your health
information should be directed to our Privacy Officer listed at the top of this Notice of Privacy
Practices.
If you are not satisfied with the manner in which this office handles a complaint, you may submit
a formal complaint to: OCRMail@hhs.gov
The complaint form may be found
at: www.hhs.gov/ocr/privacy/hipaa/complaints/hipcomplaint.pdf.
You will not be penalized in any way for filing a complaint.