It is the policy of our practice that all our physicians and staff preserve the integrity and the
confidentiality of protected health information (PHI) pertaining to our patients. The purpose of this
policy is to ensure that our practice and its physicians and staff have the necessary medical and
PHI to provide the highest quality medical care possible while protecting the confidentiality of the
PHI of our patients to the highest degree possible. Patients should not fear about providing
information to our practice and its physicians and staff for purposes of treatment, payment and
health care operations (TPO). To that end, our practice and its physicians and staff will --
- Adhere to the standards set forth in the Notice of Privacy Practices.
- Collect, use and disclose PHI only in conformance with state and federal laws and current
patient covenants and/or authorizations, as appropriate. Our practice and its physicians
and staff will not use or disclose PHI for uses outside of practice's TPO, such as marketing,
employment, life insurance applications, etc., without an authorization for the patient.
- Use and disclose PHI to remind patients of their appointments only within their consent.
- Recognize that PHI collected about patients must be accurate, timely, complete and
available when needed. Our practice and its physicians and staff will implement reasonable
measures to protect the integrity of all PHI maintained about patients.
- Recognize that patients have a right to privacy. Our practice and its physicians and staff
respect the patient's individual dignity at all times. Our practice and its physicians and staff
will respect patient's privacy to the extent consistent with providing the highest quality
medical care possible and with the efficient administration of the facility.
- Act as responsible information stewards and treat all PHI as sensitive and confidential.
Consequently, our practice and its physicians and staff will --
- Treat all PHI data as confidential in accordance with profession ethics, accreditation
standards, and legal requirements
- Not disclose PHI data unless the patient (or his or her authorized representative) has
properly consented to or authorized the release or the release is otherwise authorized
by law.
- Recognize that, although our practice "owns" the medical record, the patient has a right to
inspect and obtain a copy of his/her PHI. In addition, patients have a right to request an
amendment to his/her medical record if he/she believes his/her information is inaccurate or
incomplete. Our practice and its physicians and staff will --
- Permit patients access to their medical records when their written request is approved
by our practice. If we deny their request, then we must inform the patients that they
may request a review of our denial. In such cases, we will have an on-site health care
professional review the patient's appeals.
- Provide patients an opportunity to request the correction of inaccurate or incomplete
PHI In their medical records in accordance with the law and profession standards.
- All physicians and staff of our practice will maintain a list of all disclosures of PHI for
purposes other than TPO for each patient. We will provide this list to patients upon request,
as long as their requests are in writing.
- All physicians and staff at our practice will adhere to any restrictions concerning the use or
disclosure of PHI that patients have requested and have been approved by our practice.
- All physicians and staff of our practice must adhere to this policy. Our practice will not
tolerate violations of this policy. Violation of this policy is grounds for disciplinary action, up
to and including termination of employment and criminal or professional sanctions in
accordance with our practice's personnel rules and regulations.
- Our practice may change this privacy policy in the future. Any changes will be effective upon
the release of a revised privacy policy and will be made available to patients upon request.
Privacy Policy: Our practice recognizes and respects the fact that the patient has a right to inspect
and obtain a copy of his/her Protected Health Information (PHI).
Privacy Procedures to accomplish this Privacy Policy
- The Privacy Officer will provide the front office staff with an original form for patients to
complete when the patient desires to inspect and copy his/her PHI.
- The front office staff will photocopy and make available to patients the form to Inspect and
Copy PHI.
- The front office staff will respond to patients' requests and questions concerning inspecting
and copying their PHI. In additions, the front office staff will distribute the form to the patients
upon their request.
- Once the patient completes the form, the front office staff should forward the form to the
Policy Officer for review.
- Once the patient has submitted his/her request in writing (usually the practice's form is
optional), the front office staff must verify that the patient's signature matches his/her
signature file.
- The Privacy Officer must review the patient's request and respond to the patient within 30
days from the date of the request. The Privacy Officer can request an additional 30-day
extension as long as the request is made to the patient in writing with the reason for the
delay clearly explained.
- When the patient has requested to inspect their PHI and his/her request has been accepted,
the Privacy Officer or other authorized practice representative should accompany the patient
to a private area to inspect his/her records. After the patient inspects the record, the
Privacy Officer will note in the record the date and time of the inspection, and whether the
patient made any requests for amendments or changes to the record.
- When the patient's request to copy his/her PHI has been accepted, medical records should
copy his/her record within 30 days at no charge for one copy.
East Lansing Orthopedic Association
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2009 East Lansing Orthopedic Association PC. All Rights Reserved
Updated: 12/02/09
Privacy Policy & Procedures
3394 E Jolly Road, Suite A Lansing, MI 48910 * Phone (517) 394 - 3200 * Fax (517) 394 - 4250