Jewish Association on Aging
Notice of Privacy Practices

Effective Date: April 14, 2003

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.

For purposes of this Notice, the Jewish Association on Aging includes the Assisted Living Residence at Weinberg Village, Charles M. Morris Nursing and Rehabilitation Center, Council Care Adult Day Services, ElderLink, LHAS Arbor at Weinberg Village, Mollie’s Meals, Neighbors, Sivitz Jewish Hospice, and Weinberg Terrace.  These entities may share protected health information with each other as necessary to carry out treatment, payment or health care operations relating to the organized health care arrangement.

Purpose of the Notice

The Jewish Association on Aging is committed to preserving the privacy and confidentiality of your health information that is created and/or maintained at our facility.  State and federal laws and regulations require us to implement policies and procedures to safeguard the privacy of your health information.  This Notice provides you with information regarding our privacy practices and applies to all of your health information created and/or maintained at our facility, including any information that we receive from other health care providers or facilities.  The Notice describes how your health information may be used and/or disclosed as well as your rights and our obligations concerning such uses or disclosures.

The Jewish Association on Aging abides by the terms of this Notice, including any future revisions that we may make as required or authorized by law.  We reserve the right to change this Notice and make the revised or changed Notice effective for current health information as well as any information we receive in the future.  A copy of the current Notice identifying its effective date is posted in our facility and on our website at www.jaapgh.org.  You may request a paper copy of this Notice at any time.  Copies are available at the reception desk in Assisted Living Residence at Weinberg Village, Charles M. Morris Nursing and Rehabilitation Center, Sivitz Jewish Hospice, and Weinberg Terrace.

The privacy practices described in this Notice are followed by:

1.                  Any health care professional authorized to enter information into your medical record created and/or maintained at our facility.

2.                  All employees, students, and other service providers who have access to your health information at our facility; and

3.                  Any volunteer authorized to help you while receiving services at our facility.

The individuals identified above may share your health information with each other for purposes of treatment, payment and health care operations, as further described in this Notice.

Uses and Disclosures of Health Information for Treatment, Payment and Health Care Operations

The following section describes different ways that we may use and disclose your health information for purposes of treatment, payment, and health care operations.  We have not listed every type of use or disclosure, but the ways in which we use or disclose your information will fall under one of these purposes.

Treatment.  We may use your health information to provide you with health care treatment and services.  We may disclose your health information to doctors, nurses, nursing assistants, medication aides, technicians, medical and nursing students, rehabilitation therapy specialists, or other personnel who are involved in your health care. 

For example: Information obtained by a nurse, physician or other member of your healthcare team will be recorded in your record and used to determine the course of treatment that should work best for you. Your physician will document in your record the expectations of the members of your healthcare team. Members of your healthcare team will then record the actions taken and their observations. In that way, the physician will know how you are responding to treatment. We will also provide your physician or a subsequent healthcare provider with copies of various reports to assist in treating you once you are discharged from this facility/program.

Payment.  We may use or disclose your health information so that we may bill and receive payment from you, an insurance company, or another third party for the health care services you receive from us.  We also may disclose health information about you to your health plan in order to obtain prior approval for the services we provide to you, or to determine your health plan will pay for the treatment.

For example: A bill may be sent to you or a third party payer. The information on or accompanying the bill may include identifying information, as well as your diagnosis, procedures and supplies used.

Health Care Operations.  We may use or disclose your health information in order to perform the necessary administrative, educational, quality assurance and business functions of our facility. 

For example: Members of the medical staff, the risk or quality improvement manager, or members of the quality improvement team may use information in your health record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and service we provide.

Uses and disclosures of health information in special situations

We may use or disclose your health information in certain special situations as described below.  For these situations, you have the right to limit these uses and disclosures as provided for in the section of this document titled, Your Rights Regarding Your Health Information.

1.      Treatment Alternatives & Health-Related Products and Services.  We may use or disclose your health information for purposes of discussing with you treatment alternatives or health-related products or services that may be of interest to you.  For example, if you are a resident of our facility for purposes of a post-surgical hip replacement, we may talk with you about a gait training program that we offer at our facility to improve your walking and balance.  We may also use or share your health information to remind you of your appointment for treatment or medical care.  For example, if your doctor has sent you for a test, the place where the testing will be done may call you to remind you of your scheduled date.

2.      Facility Directory.  We may use or disclose certain limited health information about you in our facility directory.  This information may include your name, your assigned unit and room number, your religious affiliation, and a general description of your condition.  Your name, assigned unit and room number, and a general description of your condition may be given to people who ask for you by name.  Your religious affiliation may be given to a member of the clergy, even if they do not ask for you by name.  This is so your family, friends, and clergy can visit you and generally know how you are doing.

3.      Family Members and Friends.  We may disclose your health information to individuals, such as family members and friends, who are involved in your care or who help pay for your care.  We may make such disclosures when:  (a) we have your verbal agreement to do so; (b) we make such disclosures and you do not object; or (c) we can infer from the circumstances that you would not object to such disclosures.  For example, we will share information about you with your spouse or other family member after giving you an opportunity to agree or object.

We also may disclose your health information to family members, friends or your legal representative in instances when you are unable to agree or object to such disclosures, provided that we feel it is in your best interests to make such disclosures and the disclosures relate to that person’s involvement in your care.  For example, if your medical condition prevents you from either agreeing or objecting to disclosures made to your family or friends, we may share information with the family member or friend visiting you at our facility or during a home based visit, but we will share only the information which relates to their involvement in your care.

4.      Fundraising Activities.    We may use or disclose a limited amount of your health information for purposes of contacting you to raise money for our facility and its operations.  We also may disclose your health information to a foundation related to our facility so that the foundation may contact you to raise money for our facility.  The information we use or disclose will be limited to your name, address, phone number and dates for which you received treatment or services at our facility. 

Other Permitted or Required Uses and Disclosures of Health Information

There are certain instances in which we may be required or permitted by law to use or disclose your health information without your permission.  These instances are as follows:

1.      Business Associates:  We may share your health information with others who perform services on our behalf that we call “Business Associates”.   When these services are contracted, we may disclose your health information to our business associate to assist in performance of their job we have asked of them and to bill us, you, or your third party payer for services rendered. So that your health information is protected, however, we require the business associate to appropriately safeguard your information.  For example, we may share your health information with a billing company for the services we provide.

2.      As Required by Law.  We may disclose your health information when required by federal, state, or local law to do so.  For example, we are required by the Department of Health and Human Services (HHS) to disclose your health information in order to allow HHS to evaluate whether we are in compliance with the federal privacy regulations.  Federal law makes a provision for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a workforce member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public

  1. Public Health Activities.  We may disclose your health information to public health authorities that are authorized by law to receive and collect health information for the purpose of preventing or controlling disease, injury or disability; to report births, deaths, suspected abuse or neglect, reactions to medications; or to facilitate product recalls.
  1. Health Oversight Activities.  We may disclose your health information to a health oversight agency that is authorized by law to conduct health oversight activities, including audits, investigations, inspections, or licensure and certification surveys.  These activities are necessary for the government to monitor the persons or organizations providing health care to individuals and to ensure compliance with applicable state and federal laws and regulations.
  1. Judicial or Administrative Proceedings.  We may disclose your health information to courts or administrative agencies charged with the authority to hear and resolve lawsuits or disputes.  We may disclose your health information pursuant to a court order, a subpoena, a discovery request, or other lawful process issued by a judge or other person involved in the dispute, but only if efforts have been made to (i) notify you of the request for disclosure or (ii) obtain an order protecting your health information.
  1. Worker’s Compensation.  We may disclose your health information to worker’s compensation programs when your health condition arises out of a work-related illness or injury.
  1. Law Enforcement Official.  We may disclose your health information in response to a request received from a law enforcement official to report criminal activity or to respond to a subpoena, court order, warrant, summons, or similar process.
  1. Coroners, Medical Examiners, or Funeral Directors.  We may disclose your health information to a coroner or medical examiner for the purpose of identifying a deceased individual or to determine the cause of death.  We also may disclose your health information to a funeral director for the purpose of carrying out his/her necessary activities.
  1. Organ Procurement Organizations or Tissue Banks.  If you are an organ donor, we may disclose your health information to organizations handling organ procurement, transplantation, or tissue banking for the purpose of facilitating organ or tissue donation or transplantation.
  1. Research.  We may use or disclose your health information for research purposes under certain limited circumstances.  Because all research projects are subject to a special approval process, we will not use or disclose your health information for research purposes until the particular research project for which your health information may be used or disclosed has been approved through this special approval process.  However, we may use or disclose your health information to individuals preparing to conduct the research project in order to assist them in identifying patients with specific health care needs who may qualify to participate in the research project.  Any use or disclosure of your health information which is done for the purpose of identifying qualified participants will be conducted onsite at our facility.  In most instances, we will ask for your specific permission to use or disclose your health information if the researcher will have access to your name, address or other identifying information.
  1. To Avert a Serious Threat to Health or Safety.  We may use or disclose your health information when necessary to prevent a serious threat to the health or safety of you or other individuals.
  1. Military and Veterans.  If you are a member of the armed forces, we may use or disclose your health information as required by military command authorities.
  1. National Security and Intelligence Activities.  We may use or disclose your health information to authorized federal officials for purposes of intelligence, counterintelligence, and other national security activities, as authorized by law.
  1. Inmates.  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may use or disclose your health information to the correctional institution or to the law enforcement official as may be necessary (i) for the institution to provide you with health care; (ii) to protect the health or safety of you or another person; or (iii) for the safety and security of the correctional institution.
  1. Food and Drug Administration (FDA): We may disclose to the FDA health information relative to adverse events with respect to food, supplements, product and product defects or post marketing surveillance information to enable product recalls, repairs or replacement.

Uses and Disclosures Pursuant To Your Written Authorization

Except for the purposes identified above, we will not use or disclose your health information for any other purposes unless we have your specific written authorization.  You have the right to revoke a written authorization at any time as long as you do so in writing.  If you revoke your authorization, we will no longer use or disclose your health information for the purposes identified in the authorization, except to the extent that we have already taken some action in reliance upon your authorization.

Your Rights Regarding Your Health Information

Although your health record is the physical property of the healthcare practitioner or facility that compiled it, the information belongs to you. You have the following rights about your health information. 

All requests must be in writing.  In some instances, we may charge you for the cost(s) associated with providing you with the requested information. Additional information regarding how to exercise your rights and the associated costs can be obtained from the Director of Health Information Management at (412) 521-4634.

1.   Right to Inspect and Copy.  You have the right to inspect and request a copy of health information used to make decisions about your care.  We may deny your request to review and copy your health information in certain limited circumstances.  If you are denied access to your health information, you may request that the denial be reviewed.

2.   Right to Amend.  You have the right to request an amendment of your health information that is maintained by or for our facility and is used to make health care decisions about you.  We may deny your request if it is not properly submitted or does not include a reason to support your request.  We may also deny your request if the information sought to be amended:  (a) was not created by us, unless the person or entity that created the information is no longer available to make the amendment; (b) is not part of the information that is kept by or for our facility/program; (c) is not part of the information which you are permitted to inspect and copy; or (d) is accurate and complete.

3.   Right to an Accounting of Disclosures.  You have the right to request an accounting of the disclosures of your health information made by us.  This accounting will not include disclosures of health information that we made for purposes of treatment, payment or health care operations or pursuant to a written authorization that you have signed.

4.   Right to Request Restrictions.  You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment, or health care operations.  You also have the right to request a limit on the health information we disclose about you to someone, such as a family member or friend, who is involved in your care or in the payment of your care.  For example, you could ask that we not use or disclose information regarding a particular treatment that you received.  We are not required to agree to your request.  If we do agree, that agreement must be in writing and signed by you and us.

5.   Right to Request Confidential Communications.  You have the right to request we communicate with you about your health care in a certain way or at a certain location.  For example, you can ask to be contacted by mail only.

6.   Right to a Paper Copy of this Notice.  You have the right to receive a paper copy of this Notice.  You may ask us to give you a copy of this Notice at any time.  Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy of this Notice.

For More Information or to Report a Problem

If you have any questions regarding this Notice or wish to receive additional information about our privacy practices, please contact our Privacy Officer at 412-521-4634.

If you believe your privacy rights have been violated, you may file a complaint with our facility or with the Secretary of the Department of Health and Human Services (HHS).  To file a complaint with our facility, contact our Privacy Officer at Charles M. Morris Nursing and Rehabilitation Center, 200 JHF Drive, Pittsburgh, PA 15217.  All complaints must be submitted in writing.  You will not be penalized for filing a complaint.