HIPAA Privacy Notice

POLICY:

IT IS THE COMPANY’S POLICY TO PROVIDE PATIENTS WITH THE NOTICE OF PRIVACY WHEN THEY FIRST RECEIVE SERVICES OR EQUIPMENT THROUGH STEPPING STONES EARLY INTERVENTION INC.

PURPOSE:

THE PURPOSE OF THIS POLICY IS TO EXPLAIN:

1. THE PATIENT’S RIGHT TO A NOTICE

2. THE RELEVANT PROCEDURES THE COMPANY MUST FOLLOW WHEN PROVIDING ITS NOTICE TO PATIENTS.

3. REQUIREMENTS FOR DOCUMENTATION OF AND REVISIONS TO THE COMPANY’S NOTICE

RIGHT TO A NOTICE OF PRIVACY PRACTICES

A. PATIENT’S RIGHT TO NOTICE.
PATIENTS HAVE A RIGHT TO ADEQUATE NOTICE OF:

1. THE USES AND DISCLOSURES OF PHI THAT THE COMPANY MAY MAKE.

2. THE PATIENT’S RIGHTS WITH RESPECT TO PHI AND

3. THE COMPANY’S LEGAL OBLIGATIONS REGARDING PHI.

B. BASIC NOTICE REQUIREMENTS.
THE NOTICE MUST BE WRITTEN IN PLAIN LANGUAGE AND CONTAIN SPECIFIC ELEMENTS.

2. PROVISION OF THE NOTICE TO PATIENTS

A. GENERAL RULES.
THE COMPANY MUST FOLLOW THESE RULES FOR PROVIDING A PAPER COPY OF THE NOTICE TO PATIENTS AND THE PUBLIC IN GENERAL:

1. THE COMPANY MUST MAKE AVAILABLE UPON REQUEST TO ANY PERSON, EVEN IF THEY ARE NOT CURRENT PATIENTS.

2. THE COMPANY MUST PROVIDE THE NOTICE TO THE PATIENT NO LATER THAN THE DATE OF THE FIRST SERVICE TO THE PATIENT.

3. DOCUMENT COLLECTION, RETENTION REQUIREMENTS, DISCLOSURE AND DISPOSAL OF MEDICAL INFORMATION.
THE COMPANY MUST RETAIN A COPY OF EACH NOTICE FOR ITS ISSUES AND OTHER MEDICAL DOCUMENTATION FOR A PERIOD OF 6 YEARS IN A LOCKED CABINET OR LOCKED OFFICE WHICH IS ACCESSIBLE ONLY TO STEPPING STONES EARLY INTERVENTION. AFTER WHICH IT WILL BE SHREDDED.
THIS INFORMATION CAN BE SHARED WITH THE CHILD’S PHYSICIAN, SERVICE COORDINATORS, AND TEAM MEMBERS LISTED ON THE IFSP. THIS INFORMATION MAY BE RECEIVED VIA MAIL AND FACSIMILE TRANSMISSION WITH THE USE OF A CONFIDENTIALITY STATEMENT AND THESE WILL ALSO BE ACCESSIBLE TO SSEI INC. ONLY.

GENERAL USE AND DISCLOSURE

POLICY:
SSEI INC WILL USE AND DISCLOSE PHI ONLY AS SPECIFICALLY PERMITTED OR REQUIRED BY THE PRIVACY RULES IN ACCORDANCE WITH THE COMPANY’S POLICIES AND PROCEDURES. THE PURPOSE BEING TO EXPLAIN THE BASIC STANDARDS THAT MUST BE MET WHEN USING AND DISCLOSING PHI.

PERMITTED USES AND DISCLOSURES:

1. TO THE PATIENT

2. TO CARRY OUT TREATMENT, PAYMENT, OR HEALTHCARE OPERATIONS.

3. IN COMPLIANCE WITH A VALID AUTHORIZATION.

4. PURSUANT TO A VERBAL AGREEMENT FROM A PATIENT THAT PERMITS DISCLOSURE TO A CAREGIVER.

TREATMENT:
TREATMENT INCLUDES ACTIVITIES PROVIDED BY A HEALTH CARE PROVIDER, OFFICE STAFF, AND OTHER PROFESSIONALS COORDINATING AND MANAGING CARE WITH THIRD PARTIES AND CONSULTATIONS WITH AND BETWEEN HEALTH CARE PROVIDERS.

HEALTH CARE OPERATIONS:
INCLUDES THE NECESSARY BUSINESS AND ADMINISTRATIVE FUNCTIONS OF THE OFFICE.

PAYMENT:
INCLUDES ACTIVITIES INVOLVED IN DETERMINING ELIGIBILITY FOR SERVICES, HEALTH PLAN COVERAGE, BILLING, AND RECEIVING PAYMENTS FOR HEALTH BENEFITS AND UTILIZATION MANAGEMENT ACTIVITIES WHICH MAY INCLUDE REVIEW OF HEALTH CARE SERVICES, JUSTIFICATION OF CHARGES, PRE-CERTIFICATION, AND PRE-AUTHORIZATION.

MINIMUM NECESSARY INFORMATION
THE MINIMUM NECESSARY STANDARD: WHEN USING OR DISCLOSING PHI, AND WHEN REQUESTING PHI FROM ANOTHER ENTITY, SSEI INC WILL MAKE REASONABLE EFFORTS TO USE, DISCLOSE, OR REQUEST THE MINIMUM AMOUNT OF PHI REASONABLY NECESSARY TO ACCOMPLISH THE INTENDED PURPOSE OF USE, DISCLOSURE, OR REQUEST.
THE COMPANY HAS PROCEDURES THAT LIMIT ACCESS TO ONLY IDENTIFIED PERSONS AND TO ONLY THE IDENTIFIED PHI. THESE ARE BASED ON REASONABLE DETERMINATIONS ABOUT PERSONS WHO REQUIRE PHI AND THE NATURE OF THE PHI FOR THEIR PARTICULAR JOB RESPONSIBILITIES.

DISCLOSURES TO RELATIVES AND FRIENDS
THE COMPANY MAY DISCLOSE TO A PERSON INVOLVED IN THE CURRENT HEALTH CARE OF THE PATIENT SUCH AS THE ABOVE OR WITH PAYMENT FOR THE PERSON’S HEALTH CARE.

ORAL COMMUNICATIONS
APPLICABILITY OF PRIVACY STANDARDS.
THE RULES APPLY TO PHI IN ALL FORMS—ELECTRONIC, WRITTEN, AND ORAL, OR ANY OTHER FORM. EMPLOYEES MAY COMMUNICATE PHI OVER THE TELEPHONE WITH THE PATIENT, PHYSICIAN, TEAM MEMBERS INVOLVED IN THE PATIENT’S HEALTHCARE, OR A FAMILY MEMBER.

PERSONAL REPRESENTATIVES
THE COMPANY MUST TREAT A PERSON AS THE PERSONAL REPRESENTATIVE OF A PATIENT IF THE PERSON IS, UNDER APPLICABLE STATE LAW, AUTHORIZED TO ACT ON BEHALF OF THE PATIENT IN MAKING DECISIONS RELATED TO HEALTH CARE.

TRACKING DISCLOSED INFORMATION
ALL DISCLOSURES MADE WILL BE RECORDED VIA COMMUNICATION/CONFERENCE NOTES IN THE PATIENT’S FILE.

OTHER USE AND AUTHORIZATION OF PHI
THE COMPANY WILL OBTAIN A SIGNED AUTHORIZATION FROM A PATIENT PRIOR TO DISCLOSING THE PATIENT’S PHI FOR PURPOSES NOT OTHERWISE PERMITTED BY A VERBAL AGREEMENT OR RULES THAT ALLOW DISCLOSURE WITHOUT THE PATIENT’S PERMISSION. THIS IS REQUESTED WHEN DISCLOSURES ARE REQUIRED FOR NON-ROUTINE PURPOSES BEYOND TREATMENT, PAYMENT, AND HEALTH CARE OPERATIONS SUCH AS CERTAIN MARKETING ACTIVITIES OR RESEARCH PURPOSES.

AMONG DISCLOSURES FOR WHICH AUTHORIZATIONS ARE NOT REQUIRED ARE:

1. TREATMENT, PAYMENT, AND HEALTHCARE OPERATIONS. CONSENT, PRESENT IN THE IFSP DOCUMENT, MAY BE USED FOR THESE PURPOSES OF PATIENTS THROUGH EARLY INTERVENTION.

2. FOR INVOLVEMENT IN THE PATIENT’S CARE AND NOTIFICATION PURPOSES.

3. REQUIRED BY LAW

4. ABOUT VICTIMS OF ABUSE, NEGLECT, OR DOMESTIC VIOLENCE.

5. HEALTH OVERSIGHT ACTIVITIES

6. JUDICIAL AND ADMINISTRATIVE PROCEEDINGS.

7. FOR WORKER’S COMPENSATION.

8. TO THE PATIENT

9. TO THE DHS FOR ENFORCEMENT OF THE PRIVACY RULES.

10. FOR MARKETING COMMUNICATIONS THAT ARE MADE FACE-TO-FACE OR THAT INVOLVE PROMOTIONAL PRODUCTS OF NOMINAL VALUE.

INCIDENTAL DISCLOSURES
These may occur as a by-product of a use or disclosure otherwise permitted UNDER THE PRIVACY RULES, SO LONG AS THE COMPANY HAS APPLIED REASONABLE SAFEGUARDS AND IMPLEMENTED THE MINIMUM NECESSARY STANDARD, WHERE APPLICABLE.

RIGHT TO ACCESS RECORDS AND DISCLOSURE OF ACCOUNTING
THE COMPANY WILL PROCESS A REQUEST TO ACCESS, INSPECT, AND OBTAIN A COPY OF PHI INCLUDING ASSESSMENTS, PROGRESS NOTES, DISCHARGE SUMMARIES, AND INFORMATION NEEDED TO MAKE DECISIONS ABOUT CLAIMS AND CASE MANAGEMENT RECORDS IF THE REQUEST IS MADE BY A PATIENT OR HIS/HER AUTHORIZED REPRESENTATIVE.
RIGHT OF ACCESS TO PHI WILL BE IN WRITTEN FORM AND THE COMPANY MUST PROVIDE ACCESS FOR 6 YEARS FROM THE TIME PHI WAS FIRST IN EFFECT.
A PATIENT HAS A RIGHT TO REQUEST A LIST OF INSTANCES IN WHICH SSEI INC DISCLOSED HEALTH INFORMATION FOR A PURPOSE, OTHER THAN FOR PAYMENT, HEALTH CARE OPERATIONS AND ACTIVITIES WITHIN THE LAST 6 YEARS BUT NOT BEFORE APRIL 14, 2003, WHEN SUBMITTED IN WRITING.

RIGHT TO AMENDMENT OF PROTECTED HEALTH INFORMATION.
A PATIENT HAS THE RIGHT TO HAVE SSEI INC. AMEND PHI ABOUT THE PATIENT FOR AS LONG AS THE COMPANY KEEPS RECORDS OF THE PHI. THE COMPANY MUST DOCUMENT TITLES OF PERSONS OR OFFICES RESPONSIBLE FOR RECEIVING AND PROCESSING REQUESTS FOR AMENDMENTS BY PATIENTS. SSEI INC WILL ALSO MAINTAIN DOCUMENTATION OF AMENDMENTS MADE FOR 6 YEARS FROM ITS CREATION.

PATIENT COMPLAINTS
IT IS THE COMPANY’S POLICY TO PROMPTLY RECEIVE, RESPOND, AND RESOLVE ALL PATIENT COMPLAINTS REGARDING IMPROPER USE OR DISCLOSURE OF PHI BY THE COMPANY OR ITS BUSINESS ASSOCIATES.

SUBJECT OF COMPLAINTS
AN INDIVIDUAL MAY LODGE A FORMAL COMPLAINT ABOUT THE COMPANY’S INFORMATION PRACTICES INCLUDING:

1. PRIVACY AND SECURITY OF PHI

2. USE AND DISCLOSURE OF PHI

3. PATIENT’S ACCESS TO AND AMENDMENT OF THEIR PHI

4. COMPANY’S MARKETING PRACTICES AND ACTIONS OF BUSINESS ASSOCIATES.

DOCUMENTATION OF COMPLAINTS
THE COMPANY MUST MAINTAIN RECORDS OF COMPLAINTS LODGED, ACTIONS TAKEN INCLUDING CHANGES IN POLICY, AND SANCTIONS AGAINST THE PERSONS CONCERNED. THESE RECORDS MUST BE MAINTAINED FOR A PERIOD OF 6 YEARS FROM THE DATE OF THEIR CREATION.

CONCERNED PARTIES MAY COMPLAIN USING THE INFORMATION LISTED BELOW.

PRIVACY OFFICER
SSEI INC, 14466 PINEWOOD DRIVE, ORLAND PARK IL 60467.

OTHER COMPLAINTS MAY ALSO BE SUBMITTED TO
REGION V, OFFICE OF CIVIL RIGHTS, U.S. DEPARTMENT OF HEALTH AND HUMAN SERVICES
233 N. MICHIGAN AVE, STE 240, CHICAGO, IL 60601