NOTICE OF PRIVACY PRACTICES

On-Site Anesthesia Services, Inc.
Posted: March 1st, 2007

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 more information about this Notice, or to report a problem: Please contact our office at (503) 655-3851.

On-Site Anesthesia Services, Inc.(“OSAS”) is required by law to maintain the privacy of your medical information. OSAS is also required to notify you of its legal duties and privacy practices regarding your medical information, and to abide by the practices described in this notice.

Your Health Information Rights

Although your health record is the physical property of the healthcare provider, the information belongs to you. You have the right to:

·         Obtain a paper copy of this Notice upon request, even if you have received it electronically or from our website at www.on-siteanes.com

·         Inspect and copy your health record by using a written request form. We may charge you a reasonable fee for copying the information and for postage

·         Complete a written request for an amendment of your health record. We are not obligated to make all requested amendments but we will give each request careful consideration

·         Obtain an accounting of certain disclosures of your health information. We may charge a reasonable fee for more than one accounting in a 12 month period

·         Make a written request for confidential communications of your health information by alternative means (e.g. fax versus mail) or at alternate locations (e.g. office versus home)

·         Request a restriction on certain uses and disclosures of your information by completing a request form. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate

·         Provide written authorization for uses and disclosures not otherwise permitted by law

·         Revoke your authorization to use or disclose health information except to the extent that action has already been taken.

Our Responsibilities

We are required to:
·         Maintain the privacy of your health information according to law
·         Provide you with this Notice of our legal duties and privacy practices with respect to information we collect and maintain about you
·         Abide by the terms of this Notice
·         Notify you if we are unable to agree to a requested restriction
·         Accommodate reasonable requests you may have to communicate health information by alternative means or alternative locations.
We reserve the right to change our practices and to make new provisions effective for all information we have about you.  We will post the current Notice in our offices and on our website at www.on-siteanes.com.  We will provide copies of the current Notice in effect upon your request.
We will not use or disclose your health information without your authorization, except as described in this Notice. We will also discontinue to use or disclose your health information after we have received a written revocation of the authorization according to the procedures included in the authorization.

How OSAS may use and disclose your medical information

OSAS and its anesthesia providers may share your medical information with appropriate hospital employees and other participants in the patient care system, such as affiliated clinics or hospitals, as necessary for your treatment, and to monitor and improve the quality of care. We may also disclose medical information to health plans, claims processors, plan administrators, and insurers to obtain payment for services provided. OSAS anesthesia providers may also disclose medical information to family or friends involved in your care, unless you object. Other uses require your specific authorization. The following describes how OSAS may use and disclose your information without express permission. Other parts of this notice describe uses and disclosures that require your authorization, and the rights you have to restrict or request restrictions on OSAS’s use and disclosure of your medical information.

Uses and disclosures without your express permission

This section discusses the requirements of federal privacy laws. Oregon law provides additional protections in some circumstances.
· Treatment. We are permitted to use and disclose your medical information as necessary to provide you with medical treatment and services. For example, OSAS anesthesia providers and other health professionals will document information about your treatment in your medical record. This record may be released to other health professionals to ensure that they are fully informed about your medical condition and treatment needs.
· Payment. We are permitted to use and disclose your medical information for our payment purposes or the payment purposes of other health care providers or health plans. For example, our billing department may release medical information to your health insurer to allow the insurer to pay us or reimburse you for your treatment. We also may release medical information to emergency responders to allow them to obtain payment or reimbursement for services provided to you.
· Health care operations. We are permitted to use and disclose your medical information for purposes of OSAS’s healthcare operations. “Healthcare operations” are administrative, business, and managerial activities of OSAS. For example, OSAS may use your medical information to monitor the record-keeping practices of its anesthesia providers, or to ensure that OSAS is complying with state and federal laws. We are also permitted to disclose your medical information to other health care providers or health plans for their healthcare operations concerning quality assurance, the qualifications of health care professionals or quality improvement programs. For example, the quality assurance department of a hospital may use your medical information to assess the quality of care provided in your case.
Oregon law: Oregon law provides additional privacy protections in some circumstances. For example, a health care provider in Oregon generally may not release the results of an HIV test without your consent and you must be notified of this right. Release of drug and alcohol treatment records also typically require your specific consent under both federal and state law. Mental health records are subject to special protections in some circumstances, as is genetic information.
For more information on Oregon law related to these and other specially protected records, please contact the Compliance Officer of Benefits and Billing. The Oregon Revised Statutes and the Oregon Administrative Rules that contain these laws are available on-line at www.oregon.gov.

Uses and disclosures that OSAS may make unless you object

· Family or friends involved in your care. OSAS anesthesia providers, using their best judgment, may disclose to a family member or close personal friend, or anyone else you identify, medical information relevant to that person’s involvement in your care. We also may give information to someone who helps pay for your care. If you do not want us to make these disclosures, you must notify the Associate Administrator.
· In the Event of a Disaster. We may disclose medical information about you to other health care providers and to an entity assisting in a disaster relief effort to coordinate care and so that your family can be notified about your condition and location. If you do not want us to make these disclosures, you must notify the Associate Administrator.
· Appointment Reminders. Your physician may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at the hospital.
· Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that OSAS offers that may be of interest to you.
· Health-Related Benefits and Services. We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

Uses and disclosures that do not require your authorization

We may use or disclose your medical information for the following purposes:
· Research when approved by an Institutional Review Board (or Privacy Board). Under certain circumstances, OSAS may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects involving patients are subject to a special approval process through an Institutional Review Board. Before OSAS may use or disclose medical information for research purposes without your authorization, the project must be approved through this research approval process.
· To organ procurement organizations, for purposes of organ and tissue donation. If you are an organ donor, OSAS may release medical information 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.
· To the military as required by military command authorities. If you are a member of the armed forces, OSAS may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
· As authorized by law in connection with the Workers’ Compensation Program. We may release medical information about you for workers’ compensation or similar programs providing benefits for work-related injuries or illness, but only to the extent authorized by law.
· To support public health activities. Public health activities typically involve reports to agencies like the Oregon Department of Human Services as required or authorized by state law. These reports may be:
· To prevent or control disease, injury or disability;
· To report births and deaths;
· To report child abuse or neglect;
· To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
· To notify the appropriate government authority of suspected abuse or neglect of an adult patient when required or authorized by law. We will promptly inform the patient of such a report, if made.
· To notify the Food and Drug Administration of adverse events concerning food, supplements, product and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.
· To state and federal regulatory agencies. We may disclose medical information to state and federal agencies overseeing the healthcare industry, as authorized by law. These oversight activities include billing audits, investigations and inspections, and enforcement of licensure requirements. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
· Pursuant to lawful subpoena or court order. If you are involved in a lawsuit or a dispute, OSAS may disclose medical information about you in response to a court or administrative order. We also may disclose medical information about you in response to a civil subpoena, discovery request, or other lawful process by someone involved in a civil lawsuit, but only if you are informed of the request or the party has attempted to obtain an order protecting the information requested.
· To law enforcement officials for certain law enforcement purposes. We may disclose your medical information to law enforcement officials as required by law or as directed by court order, warrant, criminal subpoena or other lawful process, and in other limited circumstances for purposes of identifying or locating suspects, fugitives, material witnesses, missing persons or crime victims.
· To coroners, medical examiners and funeral directors. We may release medical information to a coroner or medical examiner as necessary to identify a deceased person or to carry out their duties as required by law. Oregon law specifically requires us to report to the medical examiner an injury apparently resulting from a gunshot wound.
· For national security and intelligence activities. We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
· When required to avert a serious threat to health or safety. We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.
· Protective Services for the President and Others. We may disclose medical information about you to authorized federal officials so they may provide protection to the President or foreign heads of state, or to conduct special investigations.
· Inmates. If you are an inmate of a correctional institution or in the custody of a law enforcement official, OSAS may release medical information about you to the correctional institution or law enforcement official. Such release would be necessary (1) for the institution to provide you with health care; (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.
· As required by federal, state or local law. We may disclose medical information about you when required to do so by federal, state or local law.
· Incidental disclosures. Incidental disclosures of your medical information may occur as a byproduct of permitted uses and disclosures of your medical information. For example, a visitor may inadvertently overhear a discussion about your care at a nurses' station. OSAS must take reasonable measures to safeguard your medical information.
· Limited data set information. We may disclose limited health information to third parties for purposes of research, public health and health care operation purposes. This limited information includes only the following identifiers:
· Admission, discharge, and service dates;
· Dates of birth and, if applicable, death;
· Age (including age 90 or over); and
· Five-digit zip code or any other geographic subdivision, such as state, county, city, precinct and their equivalent geocodes (except street address).
Before disclosing this information, OSAS must enter into an agreement with the recipient of the information that limits who may use or receive the data and requires the recipient to agree not to re-identify the data or contact you. The agreement must contain assurances that the recipient of the information will use appropriate safeguards to prevent inappropriate use or disclosure of the information.

Uses and disclosures requiring your authorization

Uses and disclosures of your personal health information for purposes other than described above require your express authorization. For example, OSAS must obtain your authorization before disclosing your medical information to a life insurer or to an employer, except under special circumstances such as when disclosure to the employer is required by law. You have the right to revoke an authorization at any time, except to the extent OSAS has already relied on it in making an authorized use or disclosure. Your revocation of an authorization must be in writing.
If you choose to revoke an authorization, then we ask that you help us comply with your wishes by identifying the authorization in some way; e.g., by indicating who you authorized to receive information or the approximate time frame in which you signed the authorization.

Disclosures to Business Associates

OSAS contracts with outside companies that provide services for and to us, such as billing companies, management consultants, quality assurance reviewers, accountants or attorneys. In certain circumstances, OSAS may need to share your medical information with a business associate so it can perform a service on our behalf. OSAS will limit the disclosure of your information to a business associate to the amount of information that is the minimally necessary to perform services for OSAS. In addition, OSAS will have a written contract in place with the business associate requiring it to protect the privacy of your medical information. 		 
 

If you have further questions please contact us at onsite@on-siteanes.com