St. Anthony Hospital
JOINT NOTICE OF PRIVACY PRACTICES
1601 SE Court Avenue
Pendleton, OR 97801
(541) 278-3216

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.
If you have any questions about this notice, please contact our Health Information Management Director at (541) 278-3216.

St. Anthony Hospital and affiliate Catholic Health Initiatives’ facilities are required by law to maintain the privacy of your health information; give you notice of our legal duties and privacy practices with respect to your health information; and follow the terms of this notice. This notice applies to all of your health records generated by St. Anthony Hospital, whether made by our personnel or your personal physician.

This notice will tell you about the ways in which we may use and disclose your health information in St. Anthony Hospital and with other entities. We also describe your rights and certain obligations we have regarding the use and disclosure of your health information.

Organized Health Care Arrangement St. Anthony Hospital is a clinically integrated health care setting. You receive health care services from your personal physician and other physicians who are members of the Medical Staff and practitioners who have clinical privileges to practice at St. Anthony Hospital and from St. Anthony employees. Your physician, practitioners and St. Anthony Hospital must be able to share your health information in order to provide you with quality health care, receive payment and conduct health care operations.

The members of the Medical Staff, practitioners and St. Anthony Hospital have agreed to follow uniform health information practices when using and disclosing your health information while you are at St. Anthony Hospital, either as an inpatient or for outpatient services. This arrangement is called an organized health care arrangement. This arrangement only applies when you receive the health care services at St. Anthony Hospital. It does not apply to the information practices at the physician’s office or other private practices.

The organized health care arrangement includes St. Anthony Hospital, the physicians and members of the Medical Staff, and the independent practitioners who have clinical privileges to practice at St. Anthony Hospital.

WHO WILL FOLLOW THIS NOTICE: The following individuals and clinically integrated health care settings share the St. Anthony Hospital’s commitment to protect your privacy and will comply with the Notice:

• All health care professionals authorized to enter information into your hospital medical records.
• All employees, volunteers, trainees, students, and other hospital personnel providing services at St. Anthony Hospital.
• All members of the Medical Staff and Practitioners with clinical privileges to practice at St. Anthony Hospital.

Clinically integrated health care settings including but not limited to are:

• Anesthesia Services
• Physician Emergency Room Services
• Pathology Services
• Radiology Services

HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION
For Treatment: We will use your health information to provide you with health care treatment and to coordinate or manager services with other health care providers, including third parties. We may disclose all or any portion of your health information to your health information to your attending physician, consulting physician(s), nurses, technicians, medical students, or other facility or health care personnel who have a legitimate need for such information in order to take care of you. Different departments of the facility will share your health information in order to coordinate the health care services you need, such as prescriptions, lab work and x-rays. We may disclose your health information to individuals that you or your legal representative authorizes who are involved in your care. We may also use and disclose your health information to contact you for appointment reminders, and to provide you with information about possible treatment options or alternatives, and other health-related benefits and services. We also may disclose your heath information to people outside the facility who may be involved in your health care after you leave the facility, such as other physicians involved in your care, specialty hospitals, skilled nursing care facilities and other health care-related services.

For Payment: We will use and disclose your health information for activities that are necessary to receive payment for our services, such as determining insurance coverage, billing, payment and collection, claims management, and medical data processing. For example, we may tell your health plan about a treatment you are planning in order to receive approval or to determine whether your plan will cover the proposed treatment. We may disclose your health information to other health care providers so they can receive payment for health care services that they provided to you, such as ambulance services. We may also give information to other third parties or individuals who are responsible for payment for your health care.

For Health Care Operations: We may disclose your health information for routine facility operations, such as, but not limited to, business planning and development, quality review of services provided, internal auditing, accreditation, certification, licensing or credentialing activities, medical research and education for staff and students, and to other healthcare entities that have a relationship with you and need the information for operational purposes.

Disclosures to Business Associates: St. Anthony Hospital contracts with outside companies that performs business services for us, such as billing companies, management consultants, quality assurance reviewers, accountants or attorneys. In certain circumstances, we may need to share your medical information with a business associate so it can perform a service on our behalf. St. Anthony Hospital will limit the disclosure of your information to a business associate to the amount of information that is the minimum necessary for the company to perform services for St. Anthony Hospital. In addition, we will have a written contract in place with the business associate requiring it to protect the privacy of you medical information.

Oregon Law: Oregon law provides additional confidentiality protections in some circumstances. Drug and alcohol records are especially protected and typically require your specific consent for release under both federal and state law. Mental health records are specially protected in some circumstances, as is genetic information.

In addition Oregon law requires a valid written authorization from the patient or legal guardian from any insurance company without a contractual agreement, enrollment procedure, or participating agreement with St. Anthony Hospital.

For more information on Oregon law related to these and other specially protected records, please contract St. Anthony Hospital’s Privacy Official at the above address, or refer to the Oregon Revised Statutes and the Oregon Administrative Rules. These documents are available on-line at www.oregon.gov.

Research: We may use and disclose your health information t researchers when the Institutional Review Board approves the research study and the use of your health information.

Providing Information from our Hospital Directory: Hospital directory information includes your name, location in the hospital, religious affiliation and general condition. We may release location and general condition information to individuals who ask for you by name. This may include your family and friends or even the media in some circumstances. We are allowed to release all hospital directory information to approved clergy members even if they do ask for you by name. If your do not want us to make these disclosures, you must complete the St. Anthony Hospital’s Facility Consent form to opt out.

USES AND DISCLOSURES THAT ARE REQUIRED OR PERMITTED BY LAW
Disaster Relief Efforts: We may disclose your health information to an entity assisting in a disaster relief effort so that your family can be notified about your condition and location.

Organ and Tissue Donation: If you are an organ donor, we may release your health information to organizations that handle organ procurement and transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

Public Health Activities: We may disclose your health information to public health officials for activities such as the prevention or control of communicable disease, injury or disability; to report births and deaths; to report suspected child and elder abuse or neglect, to report reactions to medications or problems with medical products.

Health Oversight Activities: We may disclose your health information to a health oversight agency for activities authorized by law. These oversight activities may include 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.

Judicial or Administrative Proceeding: We may disclose your health information in response to a court or administrative order, a valid subpoena, discovery request, civil or criminal proceedings, or other lawful process.

• Law Enforcement: We may release your health information if asked to do so by a law enforcement official:
• In response to a court order, subpoena, warrant, summons or similar legal process.
• Regarding a victim or death of a victim of a crime in limited circumstances.

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, including crimes that may occur at our facility.

Coroners, Medical Examiners and Funeral Directors: We may release health information to a coroner or a medical examiner. This may be necessary, for example, to identify a person who died or determine the cause of death. We may also release health information to help a funeral director to carry out his/her duties.

Workers’ Compensation: We may release your health information for workers’ compensation benefits or to a similar program that provides benefits for work-related injuries or illness.

To Avert a Serious Threat to Health or Safety: We may disclose your health information when necessary to prevent a serious threat to your health and safety or the health and safety of another person or the public.

National Security: We may disclose your health information to federal official(s) for national security activities and for the protection of the President and other Heads of State.

Military and Veterans: If you are a member of the armed forces, we may release your health information as required by military command authorities. We may also release health information about foreign military personnel t the appropriate foreign military authority.

Inmates: If you are an inmate of a correctional institution or in the custody of a law enforcement official, we may release your health information to the institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; or (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Incidental Disclosures: Certain incidental disclosures of your medical information may occur. For example, a visitor may inadvertently overhear a discussion about your care occurring at the nurses’ station. These incidental disclosures are permitted if the hospital applies reasonable safeguards to protect your medical information.

OTHER USES OF YOUR HEALTH INFORMATION
Other uses and disclosure of your health information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us with authorization to use or disclose your health information, you may revoke that authorization in writing at any time. When we receive your written revocation we will no longer use or disclose your health information for the purpose of that authorization. However, we are unable to retrieve any disclosures already made based on your prior authorization.

YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION
You have the following rights regarding your health information:
Right to Inspect and Copy: You have the right to inspect your health information and copy medical, billing or other records that may be used to make decisions about your care. The right to inspect and copy does not apply to psychotherapy notes that are maintained separately from the health record.

Submit your request on an "Access to Protected Health Information" form. We charge a fee for document requests to cover the costs of copying, mailing or other supplies.

In limited circumstances we may deny your request to inspect and copy your health information. If you are denied access to your information, you may request that the denial be reviewed. A licensed health care professional chosen by St. Anthony Hospital will review your request and the denial. The person who conducts the review will not be the same person who denied your request. We will comply with the outcome of the review.

Right to Amend: You have the right to request an amendment to your health information that you believe is incorrect or incomplete. You must submit your request in writing on a "Request for Amendment to Protected Health Information" form. Your request must include a reason for the amendment. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. We may also deny your request if you ask us to amend information that:

Was not created by St. Anthony Hospital unless the person or entity that created the information is no longer available to make the amendment.

• Is not part of the medical information kept by or for St. Anthony Hospital.
• Is not part of the information that you would be permitted to inspect and copy.
• Is accurate and complete information.

Right to an Accounting of Disclosures: We are required to maintain a list of disclosures of your health information. However, we are not required to maintain a list of disclosure that we made by acting upon your written authorizations. You have the right to request an accounting of disclosures that were not subject to your written authorization.

You must submit your request in writing on an "Accounting of Disclosure" form to St. Anthony Hospital Health Information Management Department. Your request must state a time, not longer than six years, and may not include dates before April 14, 2003. The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request before any costs are incurred.

Right to Request Restrictions: You have the right to request a restriction on the disclosure of your health information to someone who is involved in your care or payment for your care, such as family member or friend. We are not required to agree to your request. However, if we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment.

You must submit your request in writing, on a "Request for Restrictions to Protected Health Information" form. You must include: (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.

Right to Request Confidential Communications; You have the right to request that we communicate with you about health care matters in a certain way or at a certain location. For example, you can ask that we only contact you at an alternative location from you home address, such as work, or only contact you by mail instead of by phone.

You must make request in writing on a "Confidential Communications" form. Your request must specify how or where you wish to be contacted. We will accommodate all reasonable requests.

Right to a Paper Copy of This Notice: You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. You may obtain a copy of this notice at our Web Site, www.sahpendleton.org.To obtain a paper copy of any of the forms mentioned in the above section or of this notice, contact St. Anthony Hospital Health Information Management Department. The address is:

St. Anthony Hospital
Health Information Management Department
1601 SE Court Avenue
Pendleton, OR 97801
(541) 278-3216

CHANGES TO THIS NOTICE
We reserve the right to change this notice. We will post a copy of the current notice in the facility and on the web site at www.sahpendleton.org. The notice will state the effective date. Whenever the notice is revised, it will be available to you upon request.

Effective 2/15/08