Privacy

Covenant Care’s Notice of Privacy Practices

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.

USE AND DISCLOSURE OF HEALTH INFORMATION

Covenant Care, hereinafter referred to as “Covenant,” may use your health information for purposes of providing your treatment, obtaining payment for your care, and conducting healthcare operations. Your health information may be used or disclosed only after Covenant has obtained your written consent. In many cases, written consent is obtained upon admission to our services. Covenant has established a policy to guard against unnecessary disclosure of your health information.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED AFTER YOU HAVE PROVIDED YOUR WRITTEN CONSENT:

TO PROVIDE TREATMENT

Covenant may use or disclose health information to aid in your treatment or the coordination of your care. For example, we may disclose information to your physicians, members of the Covenant Interdisciplinary Group (physicians, nurses, social workers, chaplains, aides and volunteers), hospitals and other health care professionals who assist Covenant in coordinating the care and services we provide. For example, a physician involved in your care may need to know your current medications and information about your symptoms in order to prescribe appropriate treatment. Covenant may also disclose your health care information to individuals outside of the organization who are involved in your care. These individuals may include pharmacists, suppliers of medical equipment, or other health care professionals that Covenant uses in order to provide the full range of services and coordinate your care. Covenant may also disclose your health information to those most closely involved in your care, such as family members or clergy whom you have designated, unless you request that we do not do so.

TO OBTAIN PAYMENT

Covenant may use or disclose health information to obtain payment for healthcare services. For example, we may include certain health information in invoices to collect payment for the care you receive from third parties, such as Medicare/Medicaid or other health insurance providers. For example, Covenant may be required by your insurer to provide information regarding your healthcare status for reimbursement to you or to Covenant. We may also need to obtain prior approval from your health insurance provider and may need to explain your need for care and for the services we will be providing to you.

TO CONDUCT HEALTHCARE OPERATIONS

Covenant may use and disclose healthcare information within the organization to facilitate internal functions and as necessary to provide quality care to you and other patients. Internal functions include, but are not limited to activities such as:

• Performance Improvement Activities
• Activities designed to improve healthcare overall or to reduce healthcare costs
• Protocol development, case management, and care coordination
• Contacting healthcare providers and patients with information about treatment alternatives and other related issues that do not include treatment
• Professional review and performance evaluation
• Training programs, including those in which students, trainees, or other practitioners in health care learn under supervision
• Training of non-healthcare professionals
• Accreditation, certification, licensing, or credentialing activities
• Review and auditing, including compliance reviews, medical reviews, legal services, and compliance programs
• Business planning and development, including cost management and planning related analyses and formulary development
• Business management and general administrative activities of Covenant
• Fundraising for the benefit of the organization with certain marketing activities

For example, Covenant may use your health information in combination with other Covenant patients’ information during a survey by the Joint Commission; in the evaluation process to see if Covenant is providing the quality of care we expect from our staff; to evaluate the care and services we provide in order to decide how to serve all Covenant patients more effectively; to contact you to schedule visits according to your needs; or to contact you or your family as part of community information mailings (unless you tell us you do not want to be contacted).

COVENANT INPATIENT HOSPICE FACILITIES

While you are in one of Covenant’s Inpatient Hospice Facilities, they may disclose certain information about you, including your name, your general health status, your religious affiliation, and your location to people who ask for you by name. Please inform us if you do not want such information disclosed.

FOR FUNDRAISING AND OUTREACH ACTIVITIES

We may use certain information about you and the services you received, such as demographic information (including name and mailing address) and the dates that you received treatment to contact you or your family for fundraising activities. You and your legal representative have the right to opt out of fundraising communications from Covenant. If you would prefer not to receive fundraising notifications from Covenant, please advise our Development and Communications Department at 850.438.9714. We will not condition treatment on you agreeing to receive such communications.

FOR BEREAVEMENT SERVICES/REMEMBRANCE CELEBRATIONS

At your request, Covenant may use your name to recognize you as part of our Memorials and Remembrance Celebrations. If you do not wish to be recognized, please notify our Bereavement Department at 850.433.2155.

WHEN LEGALLY REQUIRED

Covenant will disclose your health information when it is required to do so by any Federal, State or local laws.

IN THE EVENT OF A BREACH OF PROTECTED HEALTH INFORMATION

We may use your contact information to provide legally-required notices of unauthorized access, acquisition, use or disclosure of your health information.

WHEN THERE ARE RISKS TO PUBLIC HEALTH

Covenant may disclose your health information in order to:

• Prevent or control disease, injury or disability; report disease, injury, and vital events such as birth or death; and for the conduct of public health surveillance, investigations, and interventions.
• To report adverse events and product defects, to track products or enable product recalls, repairs, and replacements, and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
• To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
• To an employer about an individual who is a member of the workforce as legally required.

TO REPORT ABUSE, NEGLECT OR DOMESTIC VIOLENCE

Covenant is mandated by law to notify government authorities that are authorized by law to receive such information, if we believe you are a victim of abuse, neglect, or domestic violence. Covenant will make this disclosure only when specifically required or authorized by law or when you agree to the disclosure.

TO CONDUCT HEALTH OVERSIGHT ACTIVITIES

Covenant may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure, or disciplinary action. Covenant, however, may not disclose your health information without your written HIPAA authorization if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.

IN CONNECTION WITH JUDICIAL AND ADMINISTRATIVE PROCEEDINGS

Covenant may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request, or other lawful process. If the request is not court-ordered, we may disclose your health information only when Covenant makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information.

FOR LAW ENFORCEMENT PURPOSES

Covenant may disclose your health information to a law enforcement official for law enforcement purposes as follows:

• Required by law for reporting of certain types of wounds or other physical injuries pursuant to the court order, warrant, subpoena or summons, or similar process
• For the purpose of identifying or locating a suspect, fugitive, material witness, or missing person
• Under certain limited circumstances, when you are the victim of a crime
• To a law enforcement official if Covenant has a suspicion that your death was the result of criminal conduct, including criminal conduct at Covenant
• In an emergency in order to report a crime

TO CORONERS AND MEDICAL EXAMINERS

Covenant may disclose your health information to coroners and medical examiners for the purpose of identifying a deceased person, determining the cause of death or for other duties, as authorized by law.

TO FUNERAL DIRECTORS

Covenant may disclose your health information to funeral directors, consistent with applicable law, and if necessary, to carry out their duties with respect to your funeral arrangements. If necessary to carry out their duties, Covenant may disclose your health information prior to and in reasonable anticipation, of your death.

FOR ORGAN, EYE OR TISSUE DONATION

Covenant may disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes, or tissue for the purpose of facilitating the donation and transplantation.

FOR RESEARCH PURPOSES

Covenant may, under very select circumstances, use your health information for research. Before Covenant uses or discloses any of your health information for such research purposes, the project will be subject to an approval process. Any research study must meet federal privacy law requirements.

IN THE EVENT OF A SERIOUS THREAT TO HEALTH OR SAFETY

Covenant may, consistent with applicable law and ethical standards of conduct, disclose your health information if Covenant, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.

FOR SPECIALIZED GOVERNMENT FUNCTIONS

In certain circumstances, Federal regulations authorize Covenant to use or disclose your health information to facilitate specialized government functions relating to military and veterans, national security and intelligence activities, protective services for the President and others, medical suitability determinations, and inmates and law enforcement custody.

FOR WORKER’S COMPENSATION

Covenant may release your health information, as authorized by, or to the extent necessary to comply with, state workers compensation laws that govern job-related injuries or illness.

FOR BUSINESS ASSOCIATES

Covenant may disclose your health information to organizations and vendors that perform functions on our behalf or provide us with services if the information is necessary for such functions or services. Our business associates are required, under contract with us and pursuant to federal law, to protect the privacy of your information and are not allowed to use or disclose any information other than as specified in our contract and permitted by law.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION

Other than as stated above, Covenant will not use or disclose your health information other than with your written HIPAA authorization. For example, Covenant will not use or disclose psychotherapy notes about you, sell your health information to others or use or disclose your health information for marketing communications without your written authorization. If you or your legal representative authorizes Covenant to use or disclose your health information, you may revoke that authorization in writing at any time, except if we have already acted based on your authorization.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your health information that Covenant maintains:

RIGHT TO REQUEST RESTRICTIONS

You may request restrictions on certain uses and disclosures of your health information for treatment, payment or healthcare operations. You have the right to request a limit on Covenant’s disclosure of your health information to family members or to others involved in your care or the payment of your care. However, Covenant is not required to agree to your request, except as described below. You and your legal representative have the right to request a restriction of disclosure of your health information to a health plan, if the information relates to healthcare items or services for which you have paid in full. Covenant is required to agree to all such requests. If you wish to make a request for restrictions, please make your request in writing to our Privacy Official, Corporate Health Information department.

RIGHT TO RECEIVE CONFIDENTIAL COMMUNICATIONS

You have the right to request that Covenant communicate with you in a certain way. For example, you may ask that Covenant only send communications pertaining to your health information to a P.O. Box instead of your home address. If you wish to receive confidential communications, please make your request in writing to our Privacy Official, Corporate Health Information department.

Covenant will not request that you provide any reasons for your request and will attempt to honor your reasonable requests for confidential communications.

RIGHT TO INSPECT AND COPY YOUR HEALTH INFORMATION

You have the right to inspect and copy your health information, including billing records. If we maintain a copy of your health information electronically, you also have the right to ask for a copy of your health information in an electronic format. You can also request that we provide a copy of your information to a third party that you identify. All requests to inspect and copy records containing your health information, or to make them available to third parties, may be made in writing to our Privacy Official, Corporate Health Information department. If you request a copy of your health information, Covenant may charge a reasonable fee for copying and assembling costs associated with your request as allowable by law.

RIGHT TO AMEND HEALTH CARE INFORMATION

If you and your legal representative believe that your health information records are incorrect or incomplete, you may request that Covenant amend the records. That request may be made as long as the information is maintained by Covenant. A request for an amendment of records must be made in writing to Covenant’s Privacy Official. The Privacy Official may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if:

• Your health information records were not created by Covenant,
• The records you are requesting are not part of Covenant’s records,
• The health information you wish to amend is not part of the health information you or your legal representative are permitted to inspect and copy, or
• In the opinion of Covenant, the records containing your health information are accurate and complete.

RIGHT TO AN ACCOUNTING

You and your legal representative have the right to request an accounting of certain disclosures of your health information made by Covenant. This accounting will not include disclosures of information made: (i) for treatment, payment and healthcare operations purposes; (ii) to you or pursuant to your authorization; and (iii) other disclosures for which federal law does not require us to provide an accounting. The request for an accounting must be made in writing to Covenant’s Privacy Official. The request should specify the time period for the accounting. Accounting request may not be made for periods of time in excess of six years. Covenant will provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.

RIGHT TO A PAPER COPY OF THIS NOTICE

You and your legal representative have the right to a separate paper copy of this notice at any time, even if you or your representatives have received this notice previously. To obtain a separate paper copy, please contact our Privacy Official. You or your legal representative may also print this current version of Covenant’s Notice of Privacy Practices from this website.

DUTIES OF COVENANT

Covenant is required by law to maintain the privacy of your health information and to provide to you and your legally-appointed representative this notice of its duties and privacy practices. Covenant is required to abide by terms of this notice, as may be amended from time to time. Covenant reserves the right to change the terms of its notice and to make the new notice provisions effective for all health information that it maintains. If Covenant changes its notice, Covenant will provide a copy of the revised notice to you or your legally-appointed representative. You or your legally-appointed personal representative have the right to express complaints to Covenant and to the Secretary of Health and Human Services if you or your legally-appointed representative believes that your privacy rights have been violated. Any complaints to Covenant should be made in writing to our Privacy Official. Covenant encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.

CONTACT PERSON

You can contact our Privacy Official at our administrative office, 5041 North 12th Avenue, Pensacola, FL 32504, or by telephone at 850.433.2155.

OTHER APPLICABLE LAWS

Other federal privacy laws may apply and limit our ability to use and disclose your health information beyond what we are allowed to do under HIPAA. Florida and Alabama state laws may also limit our rights to use and disclose your health information beyond what we are allowed to do under HIPAA. Below is a list of the categories of health information that are subject to these more restrictive laws and a summary of those laws. These laws have been taken into consideration in developing our policies of how we will use and disclose your health information.

• Alcohol and Drug Abuse Information: We are allowed to use and disclose alcohol and drug abuse information only (1) in certain limited circumstances, and/or (2) disclose only to specific recipients.

• Medicaid Patient Information: We are allowed to disclose treatment information about Medicaid patients only (1) in certain limited circumstances and/or (2) to specific recipients.

• HIV/AIDS: We are allowed to disclose HIV/AIDS information only (1) in certain limited circumstances and/or (2) to specific recipients. We must notify recipients of each disclosure that the disclosed information is protected by state law.

• Sexually Transmitted Diseases: We are allowed to disclose sexually transmitted disease treatment information of minors only (1) in certain limited circumstances and/or (2) to specific recipients.
• Genetic Testing: We are allowed to disclose DNA testing results only (1) in certain limited circumstances and/or (2) to specific recipients.