New Avenues to Independence, Inc.                Providing services for individuals with disabilities since 1952.

THIS NOTICE DESCRIBES HOW CONFIDENTIAL INFORMATION ABOUT CLIENTS MAY BE DISCLOSED AND HOW THEY CAN GET ACCESS TO THIS INFORMATION.

This Notice tells clients how we may use and disclose protected health information about them.  Protected health information means any health information about clients that identifies them or for which there is a reasonable basis to believe the information can be used to identify clients.  In the header above, that information is referred to as “medical information.”  In this Notice, we simply call all of that protected health information, “health information.”

This Notice also tells clients about their rights and our duties with respect to health information about them.  In addition, it will tell clients how to complain to us if they believe we have violated their privacy rights.

Who We Are

This Notice describes the privacy practices of New Avenues to Independence, Inc. and the privacy practices of:

• All of our nurses, medical business associates, and other health care professionals authorized to enter information about clients into their records.

• All of our departments, including but not limited to, our Medical Records, Business Office, Nursing Department, Residential and Community Services, Section 8, and Volunteer Services.

• All of our New Avenues to Independence service sites.

• All of our employees, staff, consultants, volunteers and other personnel who work for us or on our behalf.

Our Pledge REGARDING CONFIDENTIAL HEALTH INFORMATION

We understand that health information about clients and the health care clients receive is personal.  We are committed to protecting clients personal health information.  When clients receive treatment and other services from us, we create a record of the services clients received.  We need this record to provide clients with quality care and to comply with legal requirements.  This Notice applies to all of our records about clients care, whether made by our health care professionals or others working in our agency, and tells clients about the ways in which we may use and disclose their personal health information.  This Notice also describes their rights with respect to the health information that we keep about clients and the obligations that we have when we use and disclose their health information.

We are required by law to:

• Make sure that health information that identifies clients is kept private in accordance with relevant law.

• Give clients this Notice of our legal duties and privacy practices with respect to their personal health information.

• Follow the terms of the Notice that is currently in effect for all of their personal health information.

How We May Use and Disclose Clients Health Information

The following categories describe different ways that we use and disclose health information.  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 within one of the categories.

For Treatment:  We may use health information about clients to provide clients with health care treatment or services or to facilitate health treatment or services by other providers.  We may disclose health information about clients to the doctors, nurses, technicians, and others who are involved in their care.  They may work at New Avenues or other health care provider to whom we may refer clients for treatment, consultation, lab tests, prescriptions or other health care service.  They may also include doctors and other health care professionals who work at New Avenues, or elsewhere, whom we consult about their care.  For example, New Avenues may disclose to an emergency room doctor who is treating clients for a sprained ankle that clients have diabetes, because diabetes may affect their body’s healing process.  Likewise, we might disclose information about them prior to giving prescriptions to a pharmacist to determine if a pending prescription is contraindicative to prior prescriptions.

For Payment:  We may use and disclose health information about clients to bill and collect payment from clients, their insurance company, including Medicaid and Medicare, or other third party that may be available to reimburse us for some or all of their health care.  We may also disclose health information about clients to other health care providers or to their health plan so that they can arrange for payment relating to their care.  For example, if clients have health insurance, we may need to share information about their office visit with their health plan in order for their health plan to pay us or reimburse clients for the visit.  We may also tell the clients health plan about treatment clients need to obtain their health plan’s prior approval or to determine whether their plan will cover the treatment.

For Health Care Operations:  We may use and disclose health information about clients for our day-to-day operations, and may disclose information about clients to other health care providers involved in their care or to their health plan for use in their day-to-day operations.  These uses and disclosures are necessary to run New Avenues to Independence and to make sure that all of our clients receive quality care, and to assist other providers and health plans in doing so as well.  For example, we may use health information to review the services that we provide and evaluate the performance of our staff in serving clients.  We may also combine health information about our clients with health information from other health care providers to decide what additional services New Avenues should offer, what services are needed, whether new treatments are effective or to compare how we are doing with others and to see where we can make improvements.  We may remove information that identifies clients from this set of health information so others may use it to study health care delivery without learning who our clients are.

Individuals Involved in Clients Care or Payment for Their Care:  We may release health information about clients to a friend or family member who is involved in their health care or the person who helps pay for their care, with prior authorization from clients.

Organ and Tissue Donation:  If clients are organ donors, we way disclose health information about them to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

As Required By Law:  We will disclose health information about clients when required to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety:  We may use and disclose health information about clients when necessary to prevent a serious threat to their health and safety or the health and safety of the public or another person.  Any disclosure, however, would only be to someone able to help prevent the threat.

Workers’ Compensation:  We may release health information about clients for workers’ compensation or similar programs.  These programs provide benefits for work-related injuries or illness.

Public Health Activities:  We may disclose health information about clients for public health activities.  These activities generally include the following:

• To prevent or control disease, injury or disability.

• To report births or deaths.

• To report child abuse or neglect.

• To report reactions to medications or problems with products.

• To notify people of recalls of products.

• To notify a person who may have been exposed to a disease or may be at risk for contracting and spreading a disease or condition.

• To notify the appropriate government authority if we believe a client has been the victim of abuse, neglect or domestic violence.  We will only make this disclosure if clients agree or when required or authorized by law.

Health Oversight Activities:  We may disclose health information about clients to a health oversight agency for activities authorizes by law.  These oversight activities include, for example, 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.

Lawsuits and Disputes:  We may disclose health information about clients in response to a court or administrative order.  We may also disclose health information about clients in response to a subpoena, discovery request or other lawful process that is not accompanied by a court or administrative order, but only if efforts have been made to tell clients about the request or to obtain an order protecting the information requested.

Law Enforcement:  We may release health information about clients if asked to do so by a law enforcement official: 

• In response to a court order, subpoena, warrant, summons or similar process.

• To identify or locate a suspect, fugitive, material witness or mission person.

• Under certain limited circumstances, about the victim of a crime.

• About a death we believe may be the result of criminal conduct.

• About criminal conduct at New Avenues to Independence.

• 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.

 Coroners, Health Examiners and Funeral Directors:  We may release health information about our clients to a coroner or health examiner.  This may be necessary, for example, to identify a deceased person or determine the cause of death.  We may also release health information to funeral directors as may be necessary for them to carry out their duties.

Clients Rights REGARDING theiR HEALTH INFORMATION

Clients have certain rights with respect to their personal health information.  This section of our Notice describes clients rights and how to exercise them:

Right to Inspect and Copy: Clients have the right to inspect and copy the personal health information in their medical and billing records, or in any other group of records that we maintain and use to make health care decisions about clients.  This right does not include the right to inspect and copy psychotherapy notes, although we may, at clients request and on payment of the applicable fee, provide clients with a summary of these notes.

To inspect and copy their personal health information, clients must submit their request in writing to our privacy contact person identified on the last page of this Notice.  If clients request a copy of the information, we may charge a fee for the copying and mailing costs, and for any other costs associated with their request.

We may deny clients request to inspect and copy in certain but very limited circumstances.  If their request is denied, clients may request that the denial be reviewed.  We will designate a licensed health care professional to review our decision to deny clients request.  The person conducting the review will not be the same person who denied their request.  We will comply with the outcome of this review.  Certain denials, such as those relating to psychotherapy notes, however, will not be reviewed.

Right to Amend:  If clients feel the health information we maintain about clients is incorrect or incomplete, clients may ask us to amend the information.  Clients have the right to request an amendment to any information that we maintain about clients.  To request an amendment, clients request must be must be made in writing, submitted to our privacy contact person identified on the last page of this Notice, and must be contained on one piece of paper legibly handwritten or typed.  In addition, clients must provide a reason that supports their request for an amendment.

We may deny clients request for an amendment if it is not in writing or does not include a reason to support the request.  In addition, we may deny clients request if they ask us to amend information that:

• Was not created by us, unless the person or organization that created the information is no longer available to make the amendment,

• Is not part of the health information kept by or for New Avenues,

• Is not part of the information which clients would be permitted to inspect and copy, or

• Is accurate and complete.

 Any amendment we make to clients health information will be disclosed to the health care professionals involved in their care and to others to carry out payment and health care operations, as previously described in this Notice.

Right to Receive an Accounting of Disclosures:  Clients have the right to receive an accounting of certain disclosures of their health information that we have made.  Any accounting will not include all disclosures that we make.  For example, an accounting will not include disclosures:

• To carry out treatment, payment and health care operations as previously described in this Notice.

• Pursuant to clients written authorization.

• To a family member, other relative, or personal friend involved in clients care or payment for their care when clients have given us permission to do so.

• To law enforcement officials.

To request an accounting of disclosures, clients must submit their request in writing to our privacy contact person identified on the last page of this Notice.  Clients request must state a time period which may not be more than six (6) years and may not include dates before April 14, 2003.  The first list clients request within a twelve (12) month period will be free.  For additional lists, we may charge clients for the cost of providing the lists.  We will notify clients of the cost involved and clients may choose to withdraw or modify their request at the time before any costs are incurred.  We will mail clients a list of disclosures in paper form within thirty (30) days of their request, or notify clients if we are unable to supply the list within that time period and by what date we can supply the list; this date will not exceed sixty (60) days from the date clients made the request.

Right to Request Restrictions:  Clients have the right to request a restriction or limitation on the health information we use or disclose about clients for treatment, payment or health care operations.  Clients also have the right to request a limit on the health information we disclose about clients to someone who is involved in their care or the payment for their care, such as a family member or friend.  For example, clients may request that we not disclose information about clients to certain doctor or other health care professional, or that we not disclose information to their spouse about certain care that clients received.

We are not required to agree to clients request for restrictions if it is not feasible for us to comply with their request or if we believe that it will negatively impact our ability to care for clients.  If we do agree, however, we will comply with their request unless the information is needed to provide emergency treatment.  To request a restriction, clients must make their request in writing to our privacy contact person identified on the last page of this Notice.  In their request, clients must tell us what information clients want to limit and to whom clients wan the limits to apply.

Right to Receive Confidential Communications:  Clients have the right to request that we communicate with clients about health matters in a certain way.  For example, clients can ask that we only contact clients at work or by mail to a specified address.

To request that we communicate with clients in a certain way, clients must make their request in writing to our privacy contact person identified on the last page of this Notice.  We will not ask clients the reason for their request.  Clients request must specify how or where clients wish to be contacted.  We will accommodate all reasonable requests.

Right to a Paper Copy of this Notice:  Clients have the right to receive a paper copy of this Notice at any time.  To receive a copy, please request it from our privacy contact person identified on the last page of this Notice. 

Changes to this Notice

We reserve the right to change this Notice and to make the changed Notice effective for all of the health information that we maintain about clients, whether it is information that we previously received about clients or information we may receive about clients in the future.  We will post a copy of our current Notice in our facilities.  Our Notice will indicate the effective date on the last page, in the top right-hand corner.  We will also give clients a copy of our current Notice upon request.

Complaints

If clients believe their privacy rights have been violated, clients may file a complaint with us or with the Secretary of the Department of Health and Humans Services.  Clients may file a complaint by mailing, faxing or e-mailing us a written description of their complaint or by telling us about their complaint in person or over the telephone:

Becky Seel

Privacy Officer and Contact Person

New Avenues to Independence

17608 Euclid Avenue

Cleveland, Ohio 44112

(216) 481-1909 x294

bseel@newavenues.net

Please describe what happened and give us the dates and names of anyone involved.  Please also let us know how to contact clients so that we can respond to their complaint.  Clients will not be penalized for filing a complaint.

Other Uses and Disclosures of Clients Protected Health Information

Other uses and disclosures of personal health information not covered by this Notice or applicable law will be made only with their written authorization.  If clients have us their written authorization to use or disclose their personal health information, clients may revoke their authorization, in writing, at any time.  If clients revoke their authorization, we will no longer use or disclose their personal health information for the reasons covered by their written authorization.  Clients understand that we are unable to take back any uses and disclosures that we have already made with their authorization, and that we are required to retain our records of the care that we have provided to clients.