Privacy Practices

Victory Home Health & Hospice 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.

This Notice is effective September 23, 2013.

USE AND DISCLOSURE OF YOUR HEALTH INFORMATION

Victory Home Health & Hospice may use and disclose your health information for the purpose of providing you treatment, obtaining payment for your care, conducting health care operations, or as permitted by law. Your health information may be used or disclosed only after Victory Home Health & Hospice has obtained your written authorization, or as authorized by state or federal law. Victory Home Health & Hospice has established a policy to guard against unnecessary disclosure of your health information.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:

To Provide Treatment. Victory Home Health & Hospice may use your health information to coordinate care and treatment within Victory Home Health & Hospice and with others involved in your care and treatment activities, such as: your attending physician, members of Victory Home Health & Hospice Interdisciplinary Team consisting of hospice physicians, social workers, chaplains, nurses, home health aides, volunteers, or other health care professionals who have agreed to assist Victory Home Health & Hospice in coordinating your care. Victory Home Health & Hospice may disclose your health care information to individuals outside of Victory Home Health & Hospice involved in your care and treatment activities including family members, designated clergy, pharmacists, suppliers of medical equipment, or other health care professionals that Victory Home Health & Hospice uses to coordinate your care.

To Obtain Payment. Victory Home Health & Hospice may disclose your health information to collect payment from third parties for the care you receive from Victory Home Health & Hospice. For example, Victory Home Health & Hospice may be required by your health insurer to provide invoices or information regarding your health care status so that the insurer will reimburse you or Victory Home Health & Hospice. Victory Home Health & Hospice may need to obtain prior approval from your insurer and may need to explain to the insurer your need for care and the services that will be provided to you. Victory Home Health & Hospice may also disclose your health information to a health care provider outside of Victory Home Health & Hospice for that health care provider’s payment activities.

To Conduct Health Care Operations. Victory Home Health & Hospice may use and disclose your health care information for its own operations in order to facilitate the function of Victory Home Health & Hospice and as necessary to provide quality care to all of Victory Home Health & Hospice patients. Health care operations include activities such as:

- Quality assessment and improvement activities.

- Activities designed to improve health or reduce health care costs.

- Protocol development, case management and care coordination.

- Contacting health care providers and patients with information about treatment alternatives and other related functions that do not include treatment.

- Professional review and performance evaluation.

- Training programs including those in which students, trainees, or practitioners in health care learn under supervision.

- Training of non-health care 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, planning-related analysis, and formulary development.

- Business management and general administrative activities of Victory Home Health & Hospice.

- Fundraising for the benefit of Victory Home Health & Hospice and certain marketing activities.

Victory Home Health & Hospice may disclose your health information to another health care provider for the health care operations of that health care provider if Victory Home Health & Hospice and that health care provider has or had a relationship with you. The information disclosed will relate to that relationship and is for very limited purposes as permitted by law.

Victory Home Health & Hospice may use your health information to evaluate staff performance, combine your health information with other patients in evaluating how to more effectively serve all patients, disclose your health information to staff and contracted personnel for training purposes, use your health information to contact you as a reminder regarding a visit to you, or contact you or your family as part of general fundraising and community information mailings. Please inform us in writing at the address listed at the end of this document if you do not want to be contacted.

For Victory Home Health & Hospice Directory Purposes and to Family and Friends. Victory Home Health & Hospice may disclose certain information to people inquiring about you by name, including your name, your general health status, your location in our facility or your location while you are under our care, or your religious affiliation. Your religious affiliation will only be provided to members of clergy and clergy do not have to ask for you by name. This information will be maintained in the Victory Home Health & Hospice directory. Please inform us if you do not want your information to be given to others.

For Fundraising Activities. Victory Home Health & Hospice may use information about you including your name, address, phone number, and the dates you received care at Victory Home Health & Hospice in order to contact you or your family to raise money. Victory Home Health & Hospice may also release this information to a related foundation. If you do not want Victory Home Health & Hospice to contact you or your family, notify the contact person identified at the end of this document and indicate that you do not wish to be contacted.

USE AND DISCLOSURE OF YOUR PROTECTED HEALTH INFORMATION WITHOUT YOUR PERMISSION:

Federal privacy rules allow Victory Home Health & Hospice to use or disclose your health information without your permission or authorization for the following reasons:

When Legally Required. Victory Home Health & Hospice will disclose your health information when it is required to do so by any Federal, State, or local law.

When There Are Risks to Public Health. Victory Home Health & Hospice may disclose your health information for public activities and purposes in order to:

- Prevent, control, or report disease, injury, or disability, vital events such as birth or death, and the conduct of public health surveillance, investigations, and interventions.

- To report adverse events, 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. Victory Home Health & Hospice is allowed to notify government authorities if Victory Home Health & Hospice believes a patient is the victim of abuse, neglect, or domestic violence. Victory Home Health & Hospice will make this disclosure only when specifically required or authorized by law, or when the patient agrees to the disclosure.

To Conduct Health Oversight Activities. Victory Home Health & Hospice may disclose your health information to a health oversight agency for activities including audits, civil, administrative, or criminal investigations, inspections, licensure, or disciplinary action. Victory Home Health & Hospice, however, may not disclose your health information 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. Victory Home Health & Hospice 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, but only when Victory Home Health & Hospice makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information or as permitted by law.

For Law Enforcement Purposes. Victory Home Health & Hospice may disclose your health information to an official of the law for law enforcement purposes as follows:

- As required by law for reporting certain types of wounds or other physical injuries pursuant to the court order, warrant, subpoena, 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.

- If Victory Home Health & Hospice has a suspicion that your death was the result of criminal conduct, including criminal conduct at Victory Home Health & Hospice.

- In an emergency to report a crime.

To Coroners and Medical Examiners. Victory Home Health & Hospice may disclose your health information to coroners and medical examiners for purposes of determining your cause of death or for other duties as authorized by law.

To Funeral Directors. Victory Home Health & Hospice 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.

Victory Home Health & Hospice may disclose your health information prior to and in reasonable anticipation of your death.

For Organ, Eye, or Tissue Donation. Victory Home Health & Hospice may use or 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. Victory Home Health & Hospice may, under very select circumstances, use your health information for research. Victory Home Health & Hospice will ask your permission if any researcher will be granted access to your individually identifiable health information.

In the Event of a Serious Threat to Health or Safety. Victory Home Health & Hospice may, consistent with applicable law and ethical standards of conduct, disclose your health information if Victory Home Health & Hospice, 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 Specified Government Functions. In certain circumstances, Federal regulations authorize Victory Home Health & Hospice to use or disclose your health information to facilitate specified 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. Victory Home Health & Hospice may release your health information for worker’s compensation or similar programs.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION

Other than what is stated above, Victory Home Health & Hospice will not disclose your health information without your written authorization. If you, or your representative, authorize Victory Home Health & Hospice to use or disclose your health information, you may revoke that authorization in writing at any time.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your health information that Victory Home Health & Hospice maintains:

- Right to Request Restrictions. You may request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on disclosures of your health information to those who are involved in your care or the payment of your care. However, Victory Home Health & Hospice is not required to agree to your request. If you do not want certain information shared with others, you must make a request for a restriction. If you wish to make a request for restrictions, please contact the person listed at the end of this document.

- Right to Receive Confidential Communications by Alternative Means or Location. You have the right to request that Victory Home Health & Hospice communicate with you confidentially. For example, you may ask that Victory Home Health & Hospice only conduct communications pertaining to your health information with you privately, with no other family members present. If you wish to receive confidential communications, notify the contact person listed at the end of this document.  Victory Home Health & Hospice 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 obtain a copy of your health information, including billing records, maintained in your designated record set. A request to inspect and copy records containing your health information may be made to the contact person listed at the end of this document. If you request a copy of your health information, Victory Home Health & Hospice may charge the approved rate by the State of Oklahoma and any related mailing fees for your health records. In certain circumstances, we may deny your request to inspect and obtain a copy of your records.

- Right to Amend Health Care Information. If you, or your representative, believe that your health information records are incorrect or incomplete, you may request that Victory Home Health & Hospice amend the records. That request may be made as long as the information is maintained by Victory Home Health & Hospice.  A request for an amendment of records must be made in writing to the contact person listed at the end of this document. Victory Home Health & Hospice may deny the request if it is not in writing or does not include a reason for the amendment. The request may also be denied if your health information records were not created by Victory Home Health & Hospice, if the records you are requesting are not part of Victory Home Health & Hospice’s records, if the health information you wish to amend is not part of the health information you or your representative are permitted to inspect and copy, or if, in the opinion of Victory Home Health & Hospice, the records containing your health information are accurate and complete.

- Right to An Accounting. You, or your representative, have the right to request an accounting of disclosures of your health information made by Victory Home Health & Hospice for any reason other than for treatment, payment, or health operations. The request for an accounting must be made in writing to the contact person listed at the end of this document. The request should specify the time period for the accounting but may not include any periods prior to April 14, 2003. Accounting requests may not be made for periods of time in excess of six years. Victory Home Health & Hospice 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. This accounting will contain only the information as required by law.

- Right to a Paper Copy of This Notice. You, or your representative will be provided with a copy of this notice upon admission to Victory Home Health & Hospice, and also have a right to a separate paper copy of this Notice at any time, even if you or your representative have received this Notice previously. To obtain a separate paper copy, please contact our contact person listed at the end of this document. You or a representative may also obtain a copy of the current version of the Victory Home Health & Hospice Notice of Privacy Practices at our website, www.victoryhospice.com.

DUTIES OF Victory Home Health & Hospice

Victory Home Health & Hospice is required by law to maintain the privacy of your health information and to provide to you and your representative this Notice of its duties and privacy practices. Victory Home Health & Hospice is required to abide by terms of this Notice, as may be amended from time to time. Victory Home Health & Hospice 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 Victory Home Health & Hospice changes its Notice, Victory Home Health & Hospice will provide a copy of the revised

Notice to you or your appointed representative if you request a copy. A copy of our current notice is also posted in our main office at 714 E. Main, Tishomingo, OK. You, or your personal representative, have the right to express complaints to Victory Home Health & Hospice and to the Secretary of Health and Human Services if you, or your representative, believe that your privacy rights have been violated. Any complaints to Victory Home Health & Hospice should be made in writing to our contact person identified at the end of this document. Victory Home Health & Hospice 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

Victory Home Health & Hospice’s contact person for all issues regarding patient privacy and your rights under the Federal Privacy Standards is the Privacy Official at (580) 371-2002 or 714 E. Main, Tishomingo, OK 73460.