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.
I. Who We Are. This Notice describes the privacy practices of The Onward Group Inc, DBA Onward Wellness (referred to in this document as, Onward Wellness, “we”, or “us”), and (i) All healthcare professionals allowed to enter or access information in your medical record; and (ii) all employees, officers, directors, members, managers, and other health care professionals of Onward Wellness with access to your Protected Health Information including medical or billing records or health information (“PHI”).
II. Our Privacy Obligations. We understand your health information is personal and we are committed to protecting your privacy. In addition, we are required by law to maintain the privacy of your PHI, to provide you with this Notice of our legal duties and privacy practices with respect to your PHI, and to notify you in the event of a breach of your unsecured PHI. Unless you tell us otherwise, we will include your name, location of the facility, and your general condition (good, fair etc.) in our patient directory and make this information available to anyone who asks for you by name.
III. Permissible Uses and Disclosures Without Your Written Authorization
In certain situations, which we will describe in Section IV below, we must obtain your written authorization in order to use and/or disclose your PHI. However, unless the PHI is Highly Confidential Information (defined in Section IV.D) and the applicable law regulating such information imposes special restrictions on us, we may use and disclose your PHI without your written authorization for the following purposes:
A. Treatment. We may use and disclose health information to contact you for an appointment reminder, to tell you about health related services or recommend possible treatment options or alternatives that may be of interest to you, to help prepare a research project, to contact you to ask whether you want to participate in a study.(I am not sure if this sentence is relevant to the company at the current time. However, in the future I may want to perform a study, so should we keep the sentence?). Doctors and other providers who may treat you at places other than Onward Wellness need access to the most complete information possible in order to make treatment decisions about your care. These providers are able to access your electronic and paper records from Onward Wellness for this purpose. For example they may view your medications and test results. If you must leave Onward Wellness for care, your new provider may view your Onward Wellness treatment records. Likewise, when a provider has referred you to Onward Wellness for treatment, they are able to access your electronic record to provide follow up medical care.
B. Payment. We may use and disclose your PHI to obtain payment for health care services we provide to you; for example, disclosures to claim and obtain payment from Medicare, Medicaid, your health insurer, HMO, or other company or program that arranges or pays the cost of your health care (“Your Payer”) to verify Your Payer will pay for the health care. We may also disclose PHI to your other health care providers when such PHI is required for them to receive payment for services they render to you.
C. Health Care Operations. We may use and disclose your PHI for our health care operations, which include internal administration and planning and various activities that improve the quality and cost effectiveness of the care we deliver to you. For example, we may use PHI to evaluate the quality of our services and employees.
D. Disclosure to Relatives, Close Friends and Other Caregivers. We may use or disclose your Protected Health Information to a family member, other relative, a close personal friend or any other person identified by you when you are present for, or otherwise available prior to, the disclosure, if: (1) we obtain your agreement or provide you with the opportunity to object to the disclosure and you do not object; or (2) we reasonably infer you do not object to the disclosure. If you are not present for or unavailable prior to a disclosure (e.g., when we receive a telephone call from a family member or other caregiver), we may exercise our professional judgment to determine whether a disclosure is in your best interests. If we disclose information under such circumstances, we would disclose only information directly relevant to the person’s involvement with your care.
E. As Required by Law. We may use and disclose your PHI when required to do so by any applicable federal, state or local law, ruling, regulation, or court order.
F. Public Health Activities. We may disclose your PHI: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to a government authority authorized by law to receive such reports; (3) to report information about products under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance; and (vi) if we reasonably believe you are a victim of abuse, neglect or domestic violence to a government authority authorized by law to receive reports of such abuse, neglect, or domestic violence.
G. Clinical Trials and Other Research Activities. We may use and disclose your PHI for research purposes pursuant to a valid authorization from you or when an institutional review board or privacy board has waived the authorization requirement. Under certain circumstances, your PHI may be disclosed without your authorization to researchers preparing to conduct a research project, for research or decedents or as part of a data set that omits your name and other information that can directly identify you.
H. Health or Safety. We may use or disclose your PHI to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.
I. Specialized Government Functions. We may use and disclose your PHI to units of the government with special functions, such as the U.S. military or the U.S. Department of State under certain circumstances. J. Workers’ Compensation. We may disclose your PHI as authorized by and to the extent necessary to comply with state law relating to workers’ compensation or other similar programs.
IV. Uses and Disclosures Requiring Your Written Authorization
For any purpose other than the ones described above in Section III, we only use or disclose your PHI when you give us your written authorization.
A. Marketing. We must obtain your written authorization prior to using your PHI for marketing purposes. In addition, we may market to you in a face-to-face encounter and give you promotional gifts of nominal value without obtaining your written authorization.
B. Sale of Protected Health Information. We will not make any disclosure of PHI that is a sale of PHI without your written authorization.
C. Uses and Disclosures of Your Highly Confidential Information. Federal and state law requires special privacy protections for certain health information about you (“Highly Confidential Information”), including Alcohol and Drug Abuse Treatment Program records and other health information given special privacy protection under state or federal laws other than HIPAA. For us to disclose any Highly Confidential Information for a purpose other than those permitted by law, we must obtain your authorization
D. Revocation of Your Authorization. You may revoke your authorization, except to the extent we have taken action in reliance upon it, by delivering a written revocation statement to the Privacy Office identified below.
V. Your Individual Rights
A. For Further Information; Complaints. If you desire further information about your privacy rights, are concerned we have violated your privacy rights or disagree with a decision we made about access to your PHI, you may contact our Privacy Office.
B. Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of your PHI (1) for treatment, payment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction unless the disclosure is to a health plan for purposes of carrying out payment or health care operations and the information pertains solely to a health care item or service for which you have paid us out of pocket in full. If you wish to request additional restrictions, please obtain a request form from our Privacy Office and submit the completed form to the Privacy Office. We will send you a written response.
C. Right to Receive Communications by Alternative Means or at Alternative Locations. You may request, and we will accommodate, any reasonable written request for you to receive your PHI by alternative means of communication or at alternative locations.
D. Right to Inspect and Copy Your Health Information. You may request access to your medical record file and billing records maintained by us in order to inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. If you desire access to your records, please obtain a record request form from the Privacy Office and submit the completed form to the Privacy Office. If you request copies, we may charge you a reasonable copy fee.
E. Right to Amend Your Records. You have the right to request we amend your PHI maintained in your medical record file or billing records. If you desire to amend your records, please obtain an amendment request form from Health Information Management (Medical Records). We will comply with your request unless we believe the information would be amended is accurate and complete or other special circumstances apply.
F. Right to Receive An Accounting of Disclosures. Upon request, you may obtain an accounting of certain disclosures of your PHI made by us during any period of time prior to the date of your request provided such period does not exceed six years. If you request an accounting more than once during a twelve (12) month period, we may charge you a reasonable fee for the accounting statement.
G. Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice, even if you agreed to receive such notice electronically.
VI. Effective Date and Duration of This Notice This Notice is effective on 1/7/2020. We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all your PHI we maintain, including any information created or received prior to issuing the new notice. If we change this Notice, we will post the new notice on our Internet site at www.OnwardWellness.com. You also may obtain a new notice by contacting our Privacy Office.
VII. Privacy Office. You may contact the Privacy Office at: 1-888-509-0236 or at: firstname.lastname@example.org
Mail may be addressed to: Onward Wellness Privacy Office
P.O. Box 190437, Burton, MI 48519