NOTICE OF PRIVACY PRACTICES
April 2003

This notice describes how medical information about you or your child may be used and disclosed and how you can access this information. Please review it carefully.

We have summarized our responsibilities and your/your child's rights on this first page.

For a complete description of our privacy practices, please review this entire notice.

Our Responsibilities
Broward Children's Center is required to:
 

1. Maintain the privacy of your/your child's health information

2. Provide you/your parent with this notice of our legal duties and privacy practiceswith respect to information we collect and maintain about you/your child

3. Abide by the terms of this notice

Your Rights
As a client of our program, you/your parents have several rights with regard to your health information, including the following:
 

1. The right to request that we not use or disclose your/your child's health information in certain ways

2. The right to request to receive communications in an alternative manner or location

3. The right to access and obtain a copy of your/your child's health information

4. The right to request an amendment to you/your child's health information

5. The right to an accounting of disclosures of your/your child's health information.

We reserve the right to change our privacy practices and to make new provisions effective for all health information we maintain. Should our privacy practices change we will post the changes on the bulletin boards in our facilities, as well as our web site. A copy of the revised notice will be available after the effective date of the changes upon request.

We will not use or disclose your/your child's health information without your authorization, except as described in this notice. If you have any questions and would like additional information, you may contact the facility's privacy officer, Maureen O'Keeffe at (954) 941-1228 #113.

Understanding Your Health Record Information
Upon admission to a CompCare program your/your child's health information is compiled into a medical record/chart. The content of an individual's medical record varies between CompCare programs depending upon the type of medical services provided.

Typically, this record contains your/your child's symptoms, examinations, diagnoses, test results, treatment, and a plan for your/your child's future care or treatment. This information serves as a:
 

• basis for planning your/your child's care and treatment

• means of communication among the many health professionals who contribute to
  your/your child's care

• legal document describing the care you/your child received

• means by which you/your parent or a third party payer can verify that services billed were actually provided

• a tool in educating health professionals

• a source of data for medical research

• a source of information for public health officials who oversee the delivery of health care in the United States

• a source of data for facility planning and marketing

• a tool with which we can assess and continually work to improve the care we
  render and the outcomes we achieve

Understanding what is in your/your child's record and how your health information is used helps you/your parent to: ensure its accuracy, better understand who, what, when, and why others may access your health information, and make more informed decisions when authorizing disclosure to others.

How Will We Use or Disclose Your Health Information
 

1. Treatment. We will use or disclose your/your child's health information for treatment purposes, including the treatment activities of other health care providers. 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 child. Your/your child's physician will provide orders for care to be delivered to you/your child while in a CompCare program. Members of the healthcare team will then record the actions they took and their observations. In that way your/your child's response to treatments will be documented. We will provide your/your child's physician or a subsequent healthcare provider with copies of your/ your child's various reports that should assist him/her in treating you/your child once you/your child is discharged from a CompCare program.

2. Payment. We will use or disclose your/your child's health information for payment, including for the payment activities of health care providers or payers. For example, a bill may be sent to you/your parent or a third party payer, including Medicare or Medicaid. The information on or accompanying the bill may include information that identifies you/your child, as well as the diagnosis, procedures, and supplies
   used.

3. Health Care Operations. We will use or disclose your/your child's health information for our regular health operations. 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/your child's health record to assess the care and outcomes in your/your child's case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the health care and services we provide. In addition we will disclose your/your child's health information for certain health care operations of other entities. However, we will only disclose your/your child's
   information under the following conditions:
   (a) the other entity must have or have had in the past, a relationship with you/your child;
   (b) the health information used or disclosed must relate to that other entity's relationship with you/ your child; and (c) the disclosure must only be for one of the following purposes:
   (i) quality assessment and improvement activities;
   (ii) population-based activities relating to improving health or reducing health care costs; (iii) case management and care coordination; (iv) conducting training programs;
   (v) accreditation, licensing, or credentialing activities; or
   (vi) health care fraud and abuse detection or compliance.

4. Business Associates. There are some services provided in our organization through the use of outside people and entities. Examples of these "business associates" include our accountants, consultants, student interns and attorneys. We may disclose your/ your child's health information to our business associates so that they can perform the job we've asked them to do. To protect your/your child's health information, however, we require the business associates to appropriately safeguard your/your child's information.

5. Directory. Unless you notify us that you object, we may use your/ your child's name, location in our organization, general condition, and religious affiliation for directory purposes. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you/your child by name. We may also use your nameplate next to or on your door, if you/your child resides in one of our residential programs, unless you notify us that you object.

6. Notification. We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for you/your child's care, of your/your child's location, and general condition. If we are unable to reach your family member or personal representative, then we may leave a message for them at the phone number that they have provided us, e.g., on an answering machine.

7. Communication with family. We may disclose to a family member, other relative, close personal friend or any other person involved in your or your child's health care, health information relevant to that person's involvement in your or your child's care or payment related to your or your child's care.

8. Research. We may disclose your/your child's information to researchers when certain conditions have been met.

9. Transfer of information at death. We may disclose health information to funeral directors, medical examiners, and coroners to carry out their duties consistent with the applicable law.

10. Organ procurement organizations. Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

11. Marketing. We may contact you/ your parent regarding your/your child's treatment, to coordinate your/your child's care, or to direct or recommend alternative treatments, therapies, health care providers, or settings. In addition we may contact you/your parent to describe a health-related product or service that may be of interest you/your parent, and the payment for such product or service.

12. Fund raising. We may contact you/ your parent as a part of a fund-raising effort.

13. Food & Drug Administration. We may disclose to the FDA, or a person or entity subject to the jurisdiction of 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.

14. Workers Compensation. We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers compensation or other similar programs.

15. Public Health. As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

16. Law Enforcement. We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena.

17. Abuse, Neglect, Domestic Violence. We may disclose health information as required by law to authorities and protective service agencies regarding disclosures regarding abuse, neglect, or domestic violence.

18. Reports. Federal law makes provision for your/your child's health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force 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 clients, workers, or the public.

Your Health Information Rights
Although your/your child's heath record is the physical, property of Broward Children's Center, the information in your/your child's health record belongs to you. You/your child has the following rights:
 

• You may request that we not use or disclose your/your child's health information to a particular reason related to treatment, payment, theorganization's general health care operations, and/or to a particular family member, other relative or close personal friend. We ask that such requests be made in writing on a form provided by our organization. Although we will consider your request, please be aware that we are under no obligation to
  accept it or to abide by it. For more information about this right, see 45 Code of Federal Regulations (CFR) 164.522(a).

• If you are dissatisfied with the manner in which or the location where you are receiving communications from us that are related to your/your child's health information you may request that we provide you with such information by alternative means or at alternative locations. Such a request must be made in writing to the Office of Social Services. We will attempt to accommodate all reasonable requests. For more information about this right see 45 C.F.R.164.522(b).

• You may request to inspect and/or obtain copies of health information about you/your child, which will be provided to you in the time frames established by law. You may make such requests orally or in writing; however, to better
  respond to your request we ask that you make such requests in writing on our organization's standard form. If you request to have copies made, we will charge you a reasonable fee. For more information about this right, see 45 C.F.R. 164.524.

• If you believe that any health information in your/your child's record is incorrect or if you believe that important information is missing, you may request that we correct the existing information or add the missing information. Such requests must be made in writing, and must provide a reason to support the amendment. We ask that you use the form provided by our organization to make such requests. For a request form, please contact the privacy officer, Maureen O'Keeffe, RN at (954) 941-1228 #113.

• You may request that we provide you with a written accounting of all disclosures made by us during the time period for which you request (not to exceed 6 years). We ask that such requests be made in writing on a form provided by our organization. Please note that an accounting will not apply to any of the following
  types of disclosures: disclosures made for reasons of treatment, payment, or health care operations; disclosures made to you or your legal representative, or any other individual involved in your care; disclosures to law enforcement officials; and disclosures for national security purposes. You will not be charged for your first accounting request in any 12 month period. However, for any requests that you make thereafter, you will be charged a reasonable cost-based fee. For more information about this right, see 45 C.F.R. 164.528.

• You have the right to obtain a paper copy of our Notice of Privacy Practices upon request. You may also access and print a copy of our notice from our this web site.

• You may revoke an authorization to use or disclose health information, except to the extent that the action has already been taken. Such a request must be made in writing.

For More Information or to Report a Problem
If you have questions and you would like additional information, you may contact the organization's privacy officer, Maureen O'Keeffe, RN at (954) 941-1228 # 113.
If you believe that your/your child's privacy rights have been violated, you may file a complaint with us. These complaints must be filed in writing on a form provided by
our organization. The complaint form may be obtained from the Office of Social Services and when completed should be returned to the Office of Social Services.

You may also file a complaint with the secretary of the federal Department of Health and Human Services. There will be no retaliation for filing a complaint.

Again, if you have any questions and would like additional information, you may contact the facility's privacy officer, Maureen O'Keeffe at (954) 941-1228 #113.