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.
Community Research Foundation’s (CRF) Notice of Privacy Practices describes how we may use and disclose your protected health information to carry out your treatment, arrange for payment for the services you receive, and/or to carry out CRF’s health care operations. It also tells you that we may also use and disclose your information for other permitted purposes and as required by law. You also have rights regarding the health information we maintain for you. These rights are outlined in this Notice.
Our responsibilities: Our main responsibility is to make sure the health information we create and maintain for you is safe. We must also provide you this Notice of Privacy Practices and follow the terms it describes.
Changes to this notice: CRF reserves the right to change this notice. We also reserve the right to make the revised Notice of Privacy Practices effective for all of your health information we already have and for any health information we receive in the future. We will post a copy of this Notice of Privacy Practices at our programs and on our website at www.comresearch.org. You may request a copy at 619-275-0822 or by asking for one any time you are at a CRF program.
Uses and Discloses of Your Health Information for Treatment, Payment, and Health Care Operations
CRF will use and disclose your health information without your authorization as described in each category listed below. We have not described all specific uses or disclosures for each category; only a representative sample of situations.
For Treatment: CRF will use and disclose your health information to provide, coordinate and manage your health care and related services. We may disclose your health information among our doctors, nurses and counselors and staff other than your primary counselor. For example, our staff may discuss your care at a case conference. In addition, CRF may disclose your health information without your authorization to another non-CRF health care provider (such as your primary care physician or a social worker at a hospital who is responsible for coordinating your discharge).
For Payment: CRF may use or disclose your health information to bill and collect payment for the services you receive at a CRF program. We may disclose your health information to permit your health plan, (such as County of San Diego Mental Health Plan, Department of Veterans Affairs, Medicare, Medi-Cal) to determine your eligibility and to obtain authorization for your treatment. CRF may also disclose your health information to another health care provider so that provider can bill you for services they provided to you, such as an ambulance service that transported you to a hospital.
For Health Care Operations: CRF may use and disclose health information about you for our health care operations. These activities may include quality assessment and improvement, client satisfaction and post-discharge follow-up calls, intern training, licensing, accreditation, business planning and development, client safety activities, and general administrative functions. CRF may contract with third party business associates to complete these operations. These business associates are required by law to safeguard your health information in the same way CRF is required to protect it. We may provide information about you to your health plan to assist them in their quality assurance and auditing activities. We may also use and disclose your health information to contact you to remind you of your appointment.
Uses and Disclosures of Your Health Information That May be Made without Your Authorization or the Opportunity to Object
For the following situations, state or federal law permits use and disclosure of your health information without your verbal or written authorization. These laws do not provide you with an opportunity to object to these uses and disclosures.
Emergencies: CRF may use and disclose your health information in an emergency treatment situation. For example, we may provide your health information to a paramedic who is transporting you in an ambulance.
Research: CRF may disclose your health information to researchers when an institutional review board or the County of San Diego has approved their research proposal and established protocols to protect the privacy of your health information.
To Avert a Serious Threat to Health or Safety: CRF may use and disclose health information about you when necessary to prevent a serious and imminent threat to your health or safety or to the health or safety of the public or another person. Under these circumstances, we will only disclose health information to someone who is able to help prevent or lessen the threat.
Organ, Eye and Tissue Donation: If you are an organ, eye or tissue donor, we may release your health information to an organization that conducts organ, eye or tissue procurement or transplantation.
Public Health Activities: CRF may disclose health information about you for public health activities including, by way of example, the following:
- To prevent or control disease, injury or disability;
- To report birth or death;
- Conduct public health surveillance or investigations;
- Report child abuse or neglect or domestic violence (with your agreement or if required by law to do so);
- Report reaction to medication, adverse events or problems with medications;
- Notify clients about FDA-initiated product recalls;
- Notify a person who may have been exposed to a disease or at risk of contracting or spreading a disease or condition.
Health Oversight Activities: CRF may disclose health information about you to a health oversight agency for activities authorized by law. These activities include investigations, licensure, certification and audits. These include government agencies that oversee the health care system, government benefit programs such as Medi-Cal, other government programs regulating health care and civil rights laws.
Disclosures in Legal Proceedings: CRF may disclose health information about you to a court or administrative agency when a judge or administrative agency orders us to do so. We also may disclose health information about you in legal proceedings without your permission or without a judge or administrative agency’s order when we receive a subpoena for your health information. We will not provide this information in response to a subpoena without your authorization if the request is for records we received from a federally assisted substance abuse program.
Law Enforcement Activities: CRF may disclose health information to a law enforcement official for law enforcement purposes when:
- A court order, subpoena, warrant, summons or similar process signed by a judge requires us to do so;
- To identify or locate a suspect, fugitive, material witness or missing person;
- We report a death that we believe may be the result of criminal conduct;
- We report criminal conduct occurring on the premises of our facility;
- We determine that you are a danger to yourself or another person;
- To identify a client as the victim of a crime, if under certain circumstances and when we are unable to obtain authorization.
Medical Examiners or Funeral Directors: We may provide health information about our clients to a medical examiner to assist in identifying deceased persons and to determine the cause of death in certain circumstances. We may also disclose health information about our clients to funeral directors as necessary to carry out their duties.
Military and Veterans: If you are a member of the armed forces, we may disclose your health information as required by military command authorities.
National Security and Protective Services for the President and Others: We may disclose medical information about you to authorized federal officials for intelligence, counter-intelligence, and other national security activities authorized by law. We may also disclose health information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or so they may conduct special investigations.
Inmates: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose health information about you to the correctional institution or a law enforcement official.
Workers’ Compensation: We may disclose health information about you to comply with the State’s Workers’ Compensation Law.
As Required By Law: CRF will disclose health information about you when required to do so by federal, state or local law.
Uses and Disclosures That May be Made without Your Authorization, but for which You Will Have an Opportunity to Object
Persons Involved in Your Care or Payment of Your Care:
Provided you have been informed in advance of the use or disclosure and you have had the opportunity to agree, prohibit, or restrict the use or disclosure, CRF may use or disclose your health information: 1) to notify or assist in the notification of a family member, your personal representative, a close personal friend or other person involved in your care of your location, your general condition, or your death; or 2) to disaster relief organizations to assist in disaster relief efforts.
Uses and Disclosures of Your Health Information which Require Your Permission
Uses and disclosures not described in this Notice of Privacy Practices will generally only be made with your written permission, called an “authorization.” You have the right to revoke the authorization under some circumstances. Uses and disclosures of protected health information for marketing purposes or the sale of protected health information require authorization. CRF, while a behavioral health provider, does not create psychotherapy notes for your medical records, however, if we did generate such notes, using them with in our own programs and disclosing them to others would require authorization. If you pay for your services yourself (out of pocket), you may restrict certain disclosures. Disclosure of protected health information that is genetic information for underwriting purposes is prohibited. An individual may opt out of receiving fundraising communications if the organization intends to make such communications.
Your Rights Regarding Your Health Information
Right to a copy of this notice: You may request a copy at 619-275-0822 or by asking for one any time you are at one of our programs. It may also be retrieved from CRF’s website, www.comresearch.org.
Right to inspect and copy your health record used to make decisions about your treatment and payment: Your request for inspection or copy of health information must be in writing and directed to the CRF program where services were provided last. A fee for copies will be charged. We may deny your request in certain limited circumstances. If we deny your request, you may have the denial reviewed by a licensed CRF health care professional not directly involved in the original decision. We will honor the decision made by the licensed health care professional.
Right to amend your health record if you believe the information is incorrect or incomplete: You must submit a written request to the facility where you last received services stating why the information is incorrect or incomplete. If we accept your request, please note that we are not required to delete any information from your record. We may deny your request if you ask us to amend health information that: was not created by us, is not part of the health or billing information we maintain to make decisions about your care; is not part of the health information that you would be permitted to inspect or copy; or is accurate and complete. If CRF denies your request to amend, we will send you a written notice of the denial, stating the basis for the denial and instructions offering you the opportunity to provide a written statement disagreeing with the denial.
Right to request an accounting of disclosures to others of your health information: The accounting will provide a list of disclosures for purposes other than treatment, payment, and health care operations, those excluded by law or those you authorized. You must submit your request in writing to the facility where your last services were provided. You may submit your request on a form called a “Request for Accounting.”
Right to request restrictions on certain uses and disclosures: You must request the restriction in writing addressed to the facility where your last services were provided. The Program Director will ask you to sign a request for restriction form, which you should complete and return to the Program Director. We are not required to agree to any restrictions you request. If we do agree, we will honor your request unless the restricted health information is needed to provide you with emergency treatment.
Right to request confidential communications: You have the right to request that we communicate with you about your health care only in a certain location or through a certain method. For example, you may request that we contact you only at work or by e-mail. We will accommodate all reasonable requests. Your request must be in writing to the facility where your last services were provided and must specify how or where you wish to be contacted.
Confidentiality of Substance Abuse Records: CRF does not create substance abuse records within our behavioral health programs. However, should we receive records that have been identified as coming from a federally assisted substance abuse program, we will protect them as substance abuse records and require your written authorization to disclose them.
Breach: Affected individuals have the right to be notified of a breach of their healthcare information.
Complaints: To complain about this notice or how any of our programs manage your health information, you may file a complaint with CRF or with the Secretary of the U.S. Department of Health and Human Services. To file a complaint with us, contact our Privacy Officer in writing at 1202 Morena Blvd, Suite 300, San Diego CA 92110. The Privacy Office will assist you with writing your complaint if you request such assistance. CRF will not retaliate against you for filing a complaint.
Community Research Foundation, Inc. is the only organization that will follow this Notice of Privacy Practices.
If you have any questions about this notice, contact our Privacy Officer at 619-275-0822.