Arcadia University Student Health Services Notice of Privacy Practices
Effective Date: March 26, 2020
We are required by law to protect the privacy of health information that may reveal your identity, and to provide you with a copy of this Notice of Privacy Practices (“Notice”) that describes the protected health information privacy practices of Arcadia University Student Health Services and any affiliated health care providers that jointly perform payment activities and business operations with our practice. Protected health information is any information about you that we have in your records, including demographic information, your social security number, and the medical contents of your chart. A copy of our current Notice will always be posted in our reception area. You will also be able to obtain your own copies by calling our office or asking for one at the time of your next visit.
All correspondence and requests pertaining to this Notice should be addressed to:
Arcadia University Student Health Services
Ground Floor, Heinz Hall
450 South Easton Rd.
Glenside, PA 19038
Requirement for Acknowledgement of Notice of Privacy Practices
We will ask you to sign a form that will serve as an acknowledgement that you have received this Notice of Privacy Practices.
Requirement for Written Agreement to Disclosure
Generally, we would not disclose health information about you without your written agreement. In order to authorize such a disclosure, you would have to complete an authorization for the Release of Confidential Information Form. Please note that parents and guardians will generally have the right to control the privacy of health information about minors unless the minors are permitted by law to act on their own behalf. And, you otherwise have the right to name a personal representative who may act on your behalf to control the privacy of your health information.
That said, there are some situations when we do not need your written authorization before using your health information or sharing it with others. They are outlined in detail in this Notice.
How We May Use and Disclose your Health Information Without your Written Authorization
The following are the ways we may use and disclose your health information on a routine basis without getting any special permission from you in order to treat you, to obtain payment for services provided, and to conduct our health care operations. In the routine cases below, we would disclose only the minimum necessary information to accomplish the specific task at hand.
We may disclose health information about you to provide you with medical treatment or services. This normally involves disclosing the information to doctors, nurses, technicians, office staff, or other personnel who are involved in taking care of your health, including those outside the University. For example, we may forward test results, specialist consultation notes, medical summaries, and other information to other doctors or healthcare personnel, as we deem appropriate for your medical care.
For Healthcare Operations and to Facilitate Payment
We may use and disclose protected health information about you in order to run the business activities of our office, including with respect to training and quality assurance. We may use a sign-in sheet and send messages about appointments or test results to your University email or leave them on the voicemail for your provided telephone number. During the normal course of operations, every effort is made to respect patient privacy. In order to facilitate payment for services rendered, a bill may be sent to you or a third-party payer and the information on the bill may include information that identifies you, as well as your diagnosis, procedures, and supplies used. Likewise, some services apart from billing may be provided through contacts with business associates, such as laboratory tests, or data management, and those vendors would also have access to your health information for the purposes of providing these services.
The following are additional ways we may use and disclose your health information without getting any special permission from you. Again, in such cases, we would disclose only the minimum necessary information to accomplish the specific task at hand.
Emergencies or Public Need
We may use your health information and share it with others in order to treat you in an emergency, ; to notify a family member or other person responsible for your care about your location and general condition in an emergency situation; or to meet important public needs, including averting a serious threat to health or safety. We will not be required to obtain your written authorization, consent, or any other type of permission before using or disclosing your information for these reasons. But, if this happens, we will try to obtain your consent as soon as we reasonably can after we treat you.
We may use and disclose your health information if we are unable to obtain your consent because of substantial communication barriers, and we believe you would want us to treat you if we could communicate with you.
As Required By Law and/or Governmental Function
We may use or disclose your health information if we are required by law to do so. This could include, for example, disclosure to a health oversight agency or for inclusion in an audit, investigation, inspection, or licensure-related activity; compliance with laws relating to worker’s compensation claims; compliance with subpoenas or court orders; to report a crime or for other law enforcement purposes; if you are a member of the militaries, to military command authorities; or otherwise if necessary for national security, intelligence, or protective services activities. We also will notify you of these uses and disclosures if notice is required by law.
Public Health Activities
We may disclose your health information to authorized public health officials (or a foreign government agency collaborating with such officials) so they may carry out their public health responsibilities. For example, we may share your health information with government officials that are responsible for controlling disease, injury, or disability, or with entities regulated by the Food and Drug Administration if necessary to report adverse events, product defects, or to participate in product recalls.
Victims of Abuse, Neglect, or Domestic Violence
We may release your health information to a public health authority that is authorized to receive reports of abuse, neglect, or domestic violence. We will make every effort to obtain your permission before releasing this information, but in some cases we may be required or authorized to act without your permission.
We may use and disclose your health information as permitted by law for research and oversight by the Arcadia University Institutional Review Board (“IRB”). If any such research is conducted without your specific authorization, your privacy will be protected by the confidentiality requirements that are evaluated by the IRB. For example, the IRB could require the use of such information with only limited identifying information included.
We may release your health information to your employer when we have provided care to you at the request of your employer for purposes related to occupational health and safety. In such cases, we would endeavor to provide notice to you of the disclosure of such information.
In the Event of Death
We may release your health information to coroners, medical examiners, and/or funeral directors, and to arrange an organ or tissue donation or transplant.
We will not use or disclose your health information for purposes other than those identified in the previous sections without a specific, separate, written authorization from you.
Highly confidential information (information about HIV/AIDS, hepatitis, sexually transmitted infections, substance abuse, and mental health records) requires a special authorization from you, unless the disclosure is allowed by a court order or in limited and regulated other circumstances.
If you give us the authorization to disclose information about you, you may revoke that authorization by written notice at any time, but we cannot take back any disclosure already made with your permission up to that time.
Your Rights to Access and Control Your Health Information
We want you to know that you have the following rights to access and control your health information. These rights are important because they will help you control the way we use your information and share it with others, or the way we communicate with you about your medical matters. They may also help you make sure that the health information we have about you is accurate.
Right to Inspect and Copy Records
You have the right to inspect and obtain a copy of any of your health information that may be used to make decisions about you and your treatment for as long as we maintain such information in our records. This includes medical and billing records. If you request a copy of the information, we may charge a reasonable fee for the costs of copying, mailing, or other supplies we use to fulfill your request. Please note that you do not have the right to take the originals.
We ordinarily will respond to your request within thirty (30) days if the information is located in our facility, and within sixty (60) days if it is located off-site at another facility. If we need additional time to respond, we will notify you in writing within the time frame above to explain the reason for the delay and when you can expect to have a final answer to your request.
Under certain very limited circumstances, we may deny your request to inspect or obtain a copy of your information. If we deny part of or your entire request, we will provide a written denial that explains our reasons for doing so, and a complete description of your rights to have that decision reviewed and how you can exercise those rights.
The Right to Amend Records In the Event of Error
You can request the record be amended if you believe there is an error. All you have to do is write a written request to your health care provider or the Student Health Center generally. The request will be reviewed and the change made if there is agreement that there is an error. The health care provider does not have to make the change if the health care provider disagrees with the request or your assessment that there is an error.
Right to Request Confidential Communication
You have the right to request that we communicate with you about your medical matters in a certain way in order to enhance confidentiality. For example, you may ask that we contact you at home instead of at work, or by phone instead of by letter. To request specified alternate modes of communications, please write to Director of Student Health Services. We will not ask you the reason for your request, and we will try to accommodate all reasonable requests. Please specify in your request how or where you wish to be contacted, and, if affected, how payment for your health care will be handled if we communicate with you through this alternative method or location.
Right to Transfer Care and Restrict Use and Disclosure
You have the right to transfer your care to another health care provider. You can do this for any reason or for no reason at all. You have the right to request restrictions on the use and disclosure of your health information, but if the health care provider believes this would interfere with treatment, the health care provider is not required to agree. Under such circumstances, your information may still be disclosed if needed in an emergency situation, but in non-emergency situations, you could instead transfer your care to another health care provider.
Right to Notification of Breach
You have the right to be notified of any breaches of unsecured protected health information, as provided by law. Such notification shall be made to your last known address, unless you have indicated a preference for email.
Right to an Accounting
You have the right to an accounting of certain disclosures of your health information, as provided by law.
Right to a Paper Copy of this Notice
You have the right to receive a paper copy of this Notice at any time, even if you have agreed to receive this Notice electronically. To obtain a paper copy of this Notice, please request one from Student Health Services.
Questions or Concerns
If you believe your privacy rights have been violated, you may file a complaint with our office by contacting Theresa Smith, CRNP, Director of Student Health Services. You may do this by calling 215-572-2966 or by sending a written letter outlining the specifics of your complaint to our office. If you are not satisfied, you may also contact the Secretary of the Department of Health and Human Services, Office of Civil Rights. Retaliation for filing a complaint is prohibited.
We reserve the right to change our practices and to make the new provisions effective for all protected health information we maintain, including information created or received before the change. Should our practices change, we are not required to notify you, but will have the revised Notice available at Student Health Services and online.