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Notice of Privacy Practices

Effective Date: April 14, 2003
Revised: December 15, 2003

FOR YOUR PROTECTION: 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.

Our committment to your privacy

HealthEast Care System (HealthEast) is dedicated to maintaining the privacy of your protected health information. "Protected health information" (referred to in this document as "health information") is information that identifies you and relates to your past, present or future physical or mental health conditions, the provision of health care to you, and payment for health care services you receive.

We are required by law to maintain the privacy of your health information and to provide you with this notice. This notice will tell you how HealthEast may use and disclose your health information. It also describes your rights and certain obligations we have regarding the use and disclosure of your health information.

HealthEast creates a record of the care and services you receive at facilities within the HealthEast Care System. These records are necessary to provide you with quality care and to comply with certain legal requirements. We have policies, controls over our computers and other systems which access and store your health information, and ongoing education for our employees relating to the protection of the privacy of your health information.

HealthEast provides a wide variety of health care services through various separate, legal entities. A list of these legal entities is included at the end of this notice. These legal entities are considered part of a "single covered entity". When we refer to HealthEast in this notice, we are referring to HealthEast and each of these legal entities. To facilitate the provision of high quality health care to you, we share your health information among different parts of HealthEast, when appropriate.

This notice applies to all of your health information maintained by HealthEast, whether created by our employees or your personal physician or other health care provider while they are treating you at HealthEast, or received from such physicians or other providers. Your physician or other health care provider may not be an employee of HealthEast, however, when they are providing care to you in one of our facilities, they are part of an organized health care arrangement and will be following the provisions of this notice. Your personal physician or other health care provider may have different policies or notices regarding their use and disclosure of your health information maintained in their office or clinic.

How we use and disclose your information

The following categories describe different ways that we use and disclose your health information without your authorization. Not every use or disclosure in a category will be listed, however, all of the ways we are permitted to use and disclose information will fall into one of these categories. In some situations, you may have additional rights under Minnesota law, or as a patient who is receiving substance abuse or mental health services. In those situations, we will comply with those laws prior to releasing your health information.

For treatment
We may use and disclose your health information to provide health treatment or services, including mental health or substance abuse services. We may disclose health information to doctors, nurses, technicians, medical students or residents, or other persons who are involved in your care. Examples: Your personal physician or caregiver may need to discuss your treatment plan with a dietitian to ensure you receive meals appropriate for your health condition. The social worker managing your case may need to talk to another health care provider (hospital or nursing home) to arrange for you continuing care at that facility. Your health information may be shared with a specialist who is consulted regarding your care. We provide your personal physician or other health care provider with copies of reports that assist him/her in treating you once you leave HealthEast.

Minnesota law generally requires us to obtain your written consent to release your health records to health care facilities and providers outside of HealthEast for treatment purposes. Your consent is not required in the case of an emergency or when otherwise authorized by law.

For payment
We may use and disclose your health information to submit bills and receive payment for the health care services you receive at HealthEast. Examples: Your health plan may require information about the services, diagnosis or supplies used during your visit in order for payment to be collected. Your health plan may need to be contacted prior to your treatment to determine if they will cover the planned services. We may release your health information to workers' compensation or similar programs. We may also release your information to other health care providers who may be entitled to receive payment for services provided to you.

Minnesota law requires us to obtain your written consent to release your health records to your insurance company or others in connection with payment for services.

For health care operations
We may use and disclose your health information, as necessary, to operate our facilities and to ensure high quality care. Examples: Physicians and other health care providers may review your health information to evaluate the performance of our staff in caring for you. We may review health information from many patients to decide what additional services we should offer and whether certain new treatments are effective. We may use and disclose your health information in connection with patient satisfaction or other surveys completed by you or other communications made regarding your visit at our facility. In some circumstances, we may disclose health information about you to other health care providers with whom you have had a relationship, for certain health care operations of that provider.

Minnesota law requires us to obtain your written consent to release your health records to persons who are not acting on our behalf, such as your insurance company or to other providers for their own health care operations.

Appointment scheduling and reminders
We may contact you to obtain registration information or remind you of an appointment.

Health related services and treatment alternatives
We may use and disclose health information to tell you about treatment alternatives or other health related benefits and services that may benefit or be of interest to you. Example: Newsletters informing you of services available.

Fundraising
We may share limited information, such as your address, with the HealthEast Foundation for fundraising activities. When, and if, the HealthEast Foundation or we contact you for a voluntary donation, you can opt out of any future fundraising contacts. If you do not want to be contacted, notify the HealthEast Foundation in writing at University Park Medical Building, 1690 University Ave. W, Suite 250, St. Paul, MN 55104.

Patient directory
We may include limited information about you in the directory while you are a patient or resident at one of our hospitals or nursing homes. This information may include your name, location (room number), your general condition (e.g. fair, good, etc.) and your religious affiliation. This is so your family, friends, community religious leaders (clergy) and anyone who asks for you by name, can visit you and generally know how you are doing.

You have the right to request that we do not include or provide this information in the directory. If you have requested not to be listed in the directory, we will not provide any information to any person(s) inquiring about your presence in the facility, including family or friends; and mail or flowers may not be delivered to you.

If you have told us your religion, it will be included in the directory. Then your name, general condition and location in the facility, can be given to a community religious leader (clergy), such as a priest, minister, rabbi, or other spiritual advisor, even if they do not ask for you by name. Your information will only be given to community religious leaders (clergy) of the listed religious affiliation you provided.

Individuals involved in your care or payment for your care
With your permission, we may release health information about you to a family member or friend who is involved in your health care while you are a patient at one of our facilities. If your condition prevents you from being able to give your permission for such communications, we will use our professional judgment to determine with whom we should communicate. Minnesota law generally requires us to obtain your written consent to release health records to family or friends, except in the case of an emergency. You may limit the health information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. When asked, we may also tell your family or friends your condition and your location at a HealthEast facility (see Patient Directory). In addition, we may disclose health information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.

Research
By performing research using health information, we learn new or better ways to diagnose and treat illnesses. In most cases, use of your health information for research purposes will be reviewed and approved by an Institutional Review Board (IRB). An IRB is a federally mandated board that ensures that human research subjects are protected. In some cases, HealthEast may permit access to your health information by individuals that are preparing to conduct research. HealthEast follows all of the federally mandated requirements for research activities.

In the event that you participate in a research project that involves treatment, you will be asked to sign a research authorization. Since most clinical trials require that the patient not know which treatment they are receiving, your right to access such health information may be denied during the research project. Your right to access the information will be reinstated upon completion of the research project.

Minnesota law requires us to use reasonable efforts to obtain your written authorization before we may release your health records to an external researcher.

As required by law
We will disclose your health information when required to do so by federal, state or local law.

Special situations

In some of the following Special Situations, Minnesota law or federal law requires or authorizes us to release your health records without your consent. We have provided examples of those situations below. Unless we are required or permitted by federal or Minnesota law to release your health records in a Special Situation, we will obtain your written consent before making the release.

To avert a serious threat to health or safety
We may use and disclose your health information when necessary to prevent a serious threat to your health and safety, or the health and safety of the public or another person. HealthEast providers are permitted by Minnesota law to release your health records in the case of a health or safety threat under certain conditions.

Organ and tissue donation
We may release health information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary, to facilitate your organ or tissue donation and transplantation. Federal law requires hospitals to have an agreement with organ procurement organizations to facilitate transplants.

Military and veterans
We may release health information about you as required by military command authorities or the Department of Veterans Affairs. We may also release health information about foreign military personnel to the appropriate foreign military authority.

Public health activities
We may disclose your health information to public health authorities for certain public health activities. Examples include:

To prevent or control disease, injury or disability;
To report births and deaths;
To report child abuse or neglect;
To report reactions to medications or problems with products;
To notify people of recalls of products they may be using;
To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
To notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required by law.

Health care providers are required under Minnesota law to make certain reports to the Department of Health and other agencies, including reports relating to certain communicable diseases and maltreatment of vulnerable adults or children.

Health oversight activities
We may disclose your health information to a health oversight agency, such as the Minnesota Department of Health for activities required by law. Examples of oversight activities include audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws. Under certain circumstances, health care providers are required under Minnesota law to release health records in connection with an investigation or other health oversight activity. In certain cases, only non-patient identifying information may be released.

Lawsuits and disputes
We may disclose your health information in response to a court, administrative order, subpoena, discovery request, or other lawful process if we have made, or we receive satisfactory assurance that someone else has made, reasonable efforts to notify you of the request and /or to secure a qualified protective order relating to the health information.

Law enforcement
When certain conditions are met, we may release your health information if asked to do so by a law enforcement official:

To report certain types of wounds, or physical injuries, as required by law;
in response to a court order, subpoena, warrant, summons or similar process;
To identify or locate a suspect, fugitive, material witness, or missing person;
To report the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement;
To report a death we believe may be the result of criminal conduct;
To report criminal conduct at HealthEast; and
In emergency circumstances to report a crime, the location of the crime or victims; or the identity, description or location of the person who committed the crime.

Minnesota law requires us to report certain types of wounds, such as gunshots or burns. Under certain conditions, HealthEast providers are permitted to report health or safety threats to law enforcement.

Coroners, medical examiners and funeral directors
We may release health information to a coroner or medical examiner to identify a deceased person or determine the cause of death. We may release health information about deceased individuals to funeral directors as necessary to carry out their duties. Minnesota law requires us to report certain deaths to a coroner or medical examiner.

National security and intelligence activities
We may release your health information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Inmates
If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release your health information to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Other uses and disclosures of health information

HealthEast will comply with all uses and disclosures mandated by law. Any other uses and disclosures not described in this notice will be made only with your written authorization. If you give us authorization to use or disclose your health information for other purposes not described in this notice, you may revoke that authorization, in writing, at any time. Except to the extent that action has already been taken, we will stop using and disclosing your health information for the reasons covered by your written authorization.

Your rights

Although the record we create is the physical property of HealthEast, the health information contained in it belongs to you. You have the right to:

Inspect and copy your health information
You have the right to inspect and make copies of the health information in your record. You should contact the Health Information Services/Medical Record department at the HealthEast facility that provided your treatment. We will ask you to make the request in writing. If you request a copy of any of the information in your record, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to inspect your health information in very limited circumstances. If you are denied access to your health information, you may request that the denial be reviewed. Another licensed health care professional chosen by us will review your request and the denial. The person conducting the review will not be the person who denies your original request. We will comply with the decision of the second reviewer.

Request confidential communications
You have the right to request that we communicate with you about health matters in a certain way or in a certain location. Example: you may ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to the HealthEast facility where the service is being or has been provided. Your request must specify how and where you wish to be contacted. We will not ask the reason for your request. We will accommodate all reasonable requests.

Request restrictions on the use and disclosure of your health information
You may request restrictions on who has access to your health information and the health information that may be shared with others. While HealthEast will consider your request, HealthEast is not required to agree to your requested restrictions. To request a restriction, you must make your request in writing to Health Information Services/Medical Record department at the HealthEast facility where your services were provided. In your request, you must tell us (1) what information you want to restrict; and (2) to whom you want the restrictions to apply, example limit disclosures of information to your family.

If we have agreed to a restriction concerning the disclosure of health information to another physician or health care provider, and if the restricted information would assist in treating you in an emergency situation, we will disclose the information necessary. We will request that the information not be further disclosed.

Amend your personal information
If you feel that the health information we have is incorrect or incomplete, you may request that the information be amended. You have the right to request an amendment for as long as we keep the information at our facilities. To request an amendment, your request must be in writing, except in limited circumstances. The request should be delivered to the Health Information Services/Medical Record department at the HealthEast facility where your services were provided. The request must include a reason for the request. We may deny your request for an amendment:
If it is not in writing and does not provide a reason to support the request;
The information was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
Is not part of the health information kept by or for us;
Is not part of the information which you would be permitted to inspect and copy; or
We believe the information is accurate and complete.
We will notify you in writing if we deny your request.

Accounting of disclosures
Occasionally we are required by law to disclose your health information such as, reporting births, deaths, communicable disease, domestic or child abuse and vulnerable adult and children. You have a right to a listing of these types of disclosures. This list will not include disclosures related to treatment, payment, health care operations, or where we have obtained your authorization.

To request this list or accounting of disclosures, you must submit your request to Health Information Services/Medical Record department at the HealthEast facility where your services were provided. Your request must be made in writing and must state a time period. The time period cannot be longer than six (6) years and may not include dates prior to April 14, 2003. We will acknowledge your request within 60 days of the date we receive the request.

The first list you request in any 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or change your request at that time before costs are incurred.

Obtain a paper copy of this notice
If you have received this notice electronically, you have the right to a paper copy. To obtain a paper copy of this notice, send your request in writing to:

HealthEast Privacy Official
1700 University Ave. W.
St. Paul, MN 55104

Changes to this notice

We are required to abide by the terms of the Notice of Privacy Practices currently in effect. We reserve the right to make changes to the Notice of Privacy Practices. We reserve the right to make the revised or changed notice effective for health information that we already have about you, as well as any future information we may receive about you. We will post a copy of the current notice in our facilities, and on our website at www.healtheast.org. The notice will contain the effective date on the first page of the notice.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with HealthEast or with the Secretary of the Department of Health and Human Services. You will not be retaliated against for filing a complaint.

To file a complaint with HealthEast, submit your complaint in writing to:

HealthEast Privacy Official
1700 University Ave W.
St. Paul, MN 55104

Additionally, you may also call the HealthEast Information Privacy office at 651-232-5260 to discuss your complaint or ask questions.

You may also submit your written complaint directly to the:

Department of Health and Human Services - Office for Civil Rights
Hubert H. Humphrey Building
200 Independence Avenue SW
Room 509F HHH Building
Washington, D.C. 20201

HealthEast facilities covered under this notice

The entities covered by this notice are HealthEast, HealthEast Bethesda Hospital, HealthEast St. John's Hospital, HealthEast St. Joseph's Hospital, HealthEast Woodwinds Hospital, HealthEast Home Care, Inc., HealthEast Medical Research Institute, HealthEast Pharmacies, Inc., HealthEast Medical Laboratory, Inc., HealthEast Maplewood Outpatient Services, Inc., and HealthEast Medical Transportation, Inc.

Services are offered at or through the following facilities or companies (list is subject to change):

Hospitals and outpatient services
Bethesda Hospital
St. John's Hospital
St. Joseph's Hospital
Woodwinds Health Campus

Physician clinics
HealthEast Cottage Grove Clinic
HealthEast Downtown St. Paul Clinic
HealthEast Macalester/Groveland Clinic
HealthEast Maplewood Clinic
HealthEast Medical Care for Seniors
HealthEast Midway Clinic
HealthEast Oakdale Clinic
HealthEast Rice Street Clinic
HealthEast Roselawn Clinic
HealthEast Salud Integral
HealthEast Vadnais Heights Clinic
HealthEast Woodbury Clinic

Pillars Hospice Home

Other HealthEast Services
HealthEast Corporate Services
HealthEast Home Care, Inc.
HealthEast Maplewood Outpatient Services, Inc.
HealthEast Medical Imaging
HealthEast Medical Laboratory, Inc.
HealthEast Medical Transportation, Inc.
HealthEast Optimum Rehabilitation
HealthEast Pharmacies, Inc.
HealthEast Sleep Center
HealthEast Urgent Care
HealthEast Vascular Center
Midway Outpatient Center