JOINT NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Care Plus NJ, Inc. is a private, not-for-profit organization that provides a multitude of health, social and behavioral services, and also provides primary medical services. Various laws and regulations regarding the confidentiality of your health care information may apply depending on the type of service you receive.
Integrity Inc. is a not-for-profit organization providing integrated substance abuse treatment to individuals and families with its primary place of business located in Newark, New Jersey.
Both Care Plus NJ and Integrity, Inc. are considered covered entities under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), as amended by the Health Information Technology for Economic and Clinical Health (“HITECH”) Act, which govern how protected healthcare information about you may be shared.
Unless otherwise noted, Care Plus NJ and Integrity, Inc. shall collectively be referred to as the “Health Care Provider” or “we”.
This document describes the type of information that we gather about you, with whom that information may be shared and the safeguards we have in place to protect it. You have the right to the confidentiality of your health information and the right to approve or refuse the release of specific information, except when the release is required by law. If the practices described in this notice meet your expectations, there is nothing you need to do. If you prefer that we not share information we may honor your written request in certain circumstances described later on in this notice. If you have any questions about this Notice, please contact either the Privacy Officer at Care Plus NJ or Integrity, Inc. at the address given at the end of this notice.
Organized Health Care Arrangement
Care Plus NJ and Integrity, Inc. participate in a clinically integrated care setting in which clients may receive health care from more than one health care provider. This arrangement is called an Organized Health Care Arrangement (or OHCA) under the federal laws governing the privacy of patient health information. This means both entities can share information as necessary for purposes of providing joint treatment, payment and healthcare operations relating to the OHCA. This also means that when you receive services at Care Plus NJ or Integrity, Inc., you may receive certain professional services from doctors, nurses, clinicians, and/or individual staff who are the joint employees or agents of either entity which are both licensed affiliated facilities that have agreed to participate under the OHCA. As covered entities both Care Plus NJ and Integrity, Inc. are bound by all federal and state laws governing the privacy and confidentiality of records practices. Therefore, the clinicians and individual staff of the Health Care Provider have agreed to abide by the terms of this Notice when providing services at/or on behalf of Care Plus NJ or Integrity, Inc.
This Joint Notice applies to both Care Plus and Integrity, Inc. in regards to all of your health information that is created or received as a result of being a joint client of both entities.
If you so object, you can opt out of participating by contacting the Privacy Officer at either Care Plus or Integrity, Inc., whose contact information is listed at the end of this Notice.
Use of Health Information Exchanges
We reserve the right to participate in Health Information Exchanges (HIE). Unless you object, Health Care Provider staff may participate in the HIE in order to securely access and share your vital medical information electronically, improving speed, quality, safety and costs of care. Information obtained through an HIE may be incorporated into the Health Care Provider documented records. If you so object, you can opt out of participating by contacting the Care Plus Privacy Officer, whose contact information is listed at the end of this Notice. In the case of Integrity, Inc., with regard to the Jersey Health Connect HIE only, if you do not wish to allow otherwise authorized doctors, nurses and other clinicians involved in your care to electronically share your medical information with one another through the Jersey Health Connect HIE, you can complete, sign and submit the Jersey Health Connect HIE Opt-Out form to your provider as instructed on that form, and any Opt-Out selection that you make will be honored. The Jersey Health Connect HIE Opt-Out form can be obtained directly from any of your providers participating in the Jersey Health Connect HIE, or you can download the form from jerseyhealthconnect.org. If you Opt-Out of the Jersey Health Connect HIE, your medical information will continue to be accessed, used and released, electronically or otherwise, as needed to provide treatment to you, but it will not be made available for such purpose through the Jersey Health Connect HIE network.
Understanding your Medical / Healthcare Record Information
Each time you visit or receive a service provided by Health Care Provider, we make a record of your visit. Typically, the record contains your health history, current symptoms, psychiatric evaluations, examination and test results, diagnoses treatment, and a plan for future care or treatment. This information, often referred to as your medical record, serves as a:
- Basis for planning your care and treatment.
- Means of communication among the many health professionals who contribute to your care.
- Legal document describing the care you received.
- Means by which you or a third-party payer can verify that you actually received the services for which we bill.
- Tool in medical/health care education.
- Source of information for public health officials charged with improving health of the regions they serve.
- Tool to assess the appropriateness and quality of care you received.
- Tool to improve the quality of healthcare and achieve better patient outcomes.
Understanding what is in your medical / healthcare records and how your health information is used helps you to:
- Ensure its accuracy and completeness.
- Understand who, what, where, why, and how others may access your health information.
- Better understand the health information rights detailed below.
Who will follow this Notice
This Notice describes Health Care Provider’s practices regarding the use of your health information and that of:
- Any health care professional authorized to enter information into your medical records.
- All departments of Health Care Provider providing services to you.
- Any member of a volunteer group or student we allow to help you or the department in which you receive care at Health Care Provider’s location
- All employees, staff and other personnel who may need access to your information.
- All entities, sites and locations of Health Care Provider. follow the terms of this Notice. In addition, these entities, sites and locations may share medical/mental information with each other for treatment, payment or health care purposes described in this Notice.
- Any clinician and/or individual staff of the Health Care Provider.
Health Care Provider Pledge Regarding Your Health Information
We understand that information about you and your health is personal. Protecting medical/mental health/substance abuse information about you is important. We create a record of the care and services you receive. We need this record to provide you with quality care and to comply with certain legal requirements. This Notice applies to all of the records of your care generated by the Health Care Provider, whether made by health care professionals or other personnel.
This Notice will tell you about the ways in which we may use and disclose medical/mental health/substance abuse (referred to also as medical / healthcare records or health information) information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of this information.
We are required by law to:
- Keep private health information that identifies you;
- Give you this Notice of our legal duties and privacy practices with respect to health information about you;
- Train our personnel concerning privacy and confidentiality
- Implement a policy to discipline those who breach privacy/ confidentiality or our privacy/confidentiality polices
- Notify affected individuals following a breach of unsecured PHI and Mitigate (lessen the harm of) any breach of privacy/confidentiality.
- Follow the terms of the Notice that is currently in effect.
How We May Use and Disclosure Health Information About You.
The following describes the purposes for which we are permitted or required by law to use or disclose your health information without your consent or authorization. Any other uses or disclosures will be made only with your written authorization by use of our Request/ Authorization to Release Information forms, and you may revoke such authorization in writing at any time.
Note for Mental Health and Substance Abuse Services: We are prohibited from releasing information to outside persons / entities without your written consent unless it is in response to a duly executed court order, in an emergency or otherwise required or allowed by law. For Substance Abuse Services, minors have the same rights as an adult. For counseling: Minors age 14 and older will be asked to sign authorizations.
Treatment. We may use or disclose your health information to provide you with medical/ mental health/ substance abuse treatment or services. For example, information obtained by our staff providing healthcare services to you will record such information in your record that is related to your treatment. This information is necessary to determine what treatment you should receive. Our staff will also record actions taken by them in the course of your treatment and note how you respond.
Payment. We may use or disclose your health information so that the treatment and services you receive may be billed for and payment may be collected from you, an insurance company or a third party. The claim form for payment will include information that identifies you, your diagnosis, and treatment or supplies used in the course of treatment. For Self Paid Services: You have the right to restrict disclosure of PHI to a health plan for specific services/health items you receive and for which you or someone other than a health plan pays in full, provided Health Care Provider is not otherwise required to disclose by law.
Healthcare Operations. We may use and disclose your health information for health care operations purposes. Health care operations include, but are not limited to, quality assessment and improvement, management and general administrative activities. For example, members of our quality assurance teams may use information in your health record to assess the quality of care that you receive and determine how to continually improve the quality and effectiveness of the services we provide.
Unless you object, Health Care Provider may enter your email address in the electronic health record in order to provide you access to the patient portal, which contains your personal health information. Once the email address is set up, you will receive an email containing a temporary password so that you may access the patient portal. This portal will afford you an opportunity to communicate privately with your provider(s) however; it should not be the means of communication regarding safety. Communication in the portal cannot be monitored regularly and should not replace direct communication with your provider. If you so object, in the case of Care Plus, you can opt out of participating by contacting the Care Plus Privacy Officer, whose contact information is listed at the end of this Notice. In the case of Integrity, Inc., you can opt out by following the instructions as described above under the heading “Use of Health Information Exchanges.”
Business Associates. There may be instances where services are provided to our organization through contracts with third party “Business Associates”. Whenever a business associate arrangement involves the use or disclosure of your health information, we will have a written contract that requires the business associate to maintain the same high standards of safeguarding your privacy that we require of our own employees and affiliates.
Notification. Unless you object, in emergency or similar types of situations, we may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, your location, and general condition.
Communication with family. Unless you object, we may, using our best judgment, disclose to a family member, other relative, close personal friend or any other person you identify, health information relevant to that person’s involvement in your care or payment related to your care.
Research. Neither Care Plus NJ or Integrity, Inc. routinely participate in research studies. Any disclosure of information for research purposes shall be based on your written, informed consent, and assurances that the researchers shall comply with ethical standards for ensuring the confidentiality of your information.
Appointment Reminders. Unless you object, we may use and disclose health information to contact you as a reminder that you have an appointment for treatment or services.
Electronic Communication. With your consent, Health Care Provider may text your cell phone, email you at the email address you provide to Health Care Provider, or call your home or other alternative location and leave a message on voicemail.
Treatment Alternatives. Unless you object, we may use and disclose health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
Health-Related Benefits and Services. Unless you object, we may use and disclose health information to tell you about health-related benefits or services that maybe of interest to you.
Fund-raising. Neither Care Plus NJ or Integrity, Inc. routinely contact clients for fundraising. Unless you object, we may contact you as a part of a fund-raising effort. You have the right to request not to receive fund-raising materials. If you so object, you can opt out of participating by contacting either the Privacy Officer at Care Plus or Integrity, Inc., whose contact information is listed at the end of this Notice.
Food and Drug Administration (FDA): We may be required by law to disclose to the FDA health information relative to adverse effects/events with respect to food, drugs, supplements, product or product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.
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 established by law.
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.
Coroners, Medical Examiners and Funeral Directors. We may be required to disclose health information to a Corner or Medical Examiner. We may also disclose health information to funeral directors consistent with applicable law to carry out their duties.
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.
Correctional Institution. As required by law, should you be an inmate of a correctional institution, we may disclose to the institution or agents thereof health information necessary for your health and the health and safety of other individuals.
Law Enforcement. We may disclose health information purposes as requested by a law enforcement official as part of law enforcement activities; investigations of criminal conduct; in response to court orders (i.e. subpoenas); in emergency circumstances; or when required to do so by law.
Military and Veterans. If you are a member of the armed forces, we may be required by law to disclose health information about you as required by military command.
To Avert a Serious Threat to Health or Safety. Consistent with applicable federal and State laws, we may use and disclose health information 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, National Security and Intelligence Activities. We may disclose health information about you to authorize federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations or intelligence, counterintelligence, and other national security activities authorized by law.
Lawsuits and Disputes. We may disclose health information about you in response to a subpoena, discovery request, and other lawful orders from a court. For Mental Health and Substance Abuse services, Health Care Provider may only release health information about you under court order or unless Health Care Provider is directly involved as a defendant or plaintiff.
Health Oversight Activities. We may disclose health information to a health oversight agency for activities authorized by law, including audits, investigations, inspections and licensure.
The Federal Department of Health and Human Services (DHHS): Under the privacy standards, we must disclose your health information to DHHS as necessary for them to determine our compliance with those standards.
As Required by Law. We will disclose health information about you when required to do so by federal, state or local law.
Uses and Disclosures with Your Authorization.
We generally must obtain your prior authorization for the following uses and disclosures of your medical information:
(i) Psychotherapy Notes (however, we may use or disclose psychotherapy notes for treatment, payment or health care operations without authorization or as otherwise permitted or required by law);
(ii) marketing activities or communications (however, we may send you communications that relate to your treatment, case management or care coordination); and
(iii) activities where we receive money in exchange for your medical information, except where related to the treatment you receive, public health, or research purposes.
Your Rights Regarding Healthcare Information About You
Although your health records are the physical property of Health Care Provider, you have certain rights with regard to the information contained therein. The following describes your rights regarding the health information we maintain about you. To exercise your rights you must submit your request in writing to either the Privacy Officer at Care Plus NJ or Integrity, Inc. You have the:
- Right to request restriction on uses and disclosures of your health information. You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the healthcare information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.
However, we do not have to agree to the restriction. If we do agree, we will comply with your request, unless the information is needed to provide you emergency treatment.
To request restrictions, you must make your request in writing to one of the respective Privacy Officers, whose addresses are at the end of this notice. In your request, you must tell us (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 healthcare matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.
To request confidential communications, you must make your request in writing to one of the respective Privacy Officers. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
- Right to Inspect and Copy your heath information upon request. You have the right to inspect and copy health information that may be used to make decisions about your care. Usually, this includes healthcare and billing records, but does not include psychotherapy notes.
To inspect and copy health information that may be used to make decisions about you, you must submit your request in writing to one of the Privacy Officers at Care Plus NJ or Integrity, Inc. at the address on the last page of this notice. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.
- We may deny your request to inspect and copy in certain very limited circumstances. If we deny your request, we will provide you with an explanation of our decision. If you are denied access to healthcare information, you may request that the denial be reviewed. Another licensed healthcare professional chosen by Health Care Provider will review your request and the denial. The matter will be reviewed and a decision made within 60 days. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.
If we grant access, we will tell you what, if anything, you have to do to get access. We reserve the right to charge a reasonable, cost-based fee for making copies.
- Right to Request Amendment/correction of your health information. If you feel healthcare information we have generated about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept.
In order to request an amendment, your request must be made in writing and submitted to one of the Privacy Officers at either Care Plus NJ or Integrity, Inc. In addition, you must provide a reason that supports your request.
We may deny your 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 your request if you ask to amend information that:
- Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
- Is not part of the healthcare information kept by Health Care Provider;
- Is not part of the information which you would be permitted to inspect and copy; or
- Is accurate and complete.
- Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures.” This means a list of certain disclosures we made of healthcare information about you. To request an accounting of disclosures, you must submit your request in writing to one of the Privacy Officers at either Care Plus NJ or Integrity, Inc.
- Right to Revoke an Authorization. You have the right to revoke the Release of your Protected Health information. Your decision to revoke must be made in writing and sent to one of the Privacy Officers at either Care Plus NJ or Integrity, Inc.
- Right to obtain a copy of this Notice of Privacy Practices. Although we have posted a copy in prominent locations throughout the Health Care Provider locations and on Care Plus NJ’s website, you have right to a hard copy upon request.
- To obtain a paper copy of this notice, please request one in writing from one of the Privacy Officers at Care Plus NJ or Integrity, Inc. at the address on the last page of this notice.
- You may obtain a copy of this notice on Care Plus NJ’s website: careplusnj.org
If you believe your privacy rights have been violated, you may file a complaint with Health Care Provider or with the Secretary of the Department of Human Services. To file a complaint with Health Care Provider one of the Privacy Officers at Care Plus or Integrity, Inc. at the address and phone number listed at the end of this notice.
You will not be penalized for filing a complaint.
Other Uses or Disclosures of Your Healthcare Information
Other uses and disclosures of your healthcare information not covered by this Notice or the laws that apply to use will be made only with your written permission. If you provide us permission to use or disclose healthcare information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, thereafter we will no longer use or disclose healthcare information about you for the reasons covered by your written authorization.
You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.
The Care Plus NJ, Inc. Privacy Officer is:
Director Quality Assurance/Privacy Officer
Care Plus NJ
40 Eisenhower Drive, Suite 209
Paramus, NJ 07652
Tel: 201-843-5218 ext. 5235
The Integrity, Inc. Privacy Officer is:
Director of Quality Improvement
103 Lincoln Park
Newark, NJ 07102
Tel: (201) 617-2760
Fax: (201) 583-7114
Changes To This Notice
HEALTH CARE PROVIDER RESERVES THE RIGHT TO CHANGE OUR PRACTICES AND TO MAKE THE NEW PROVISIONS EFFECTIVE FOR ALL OF OUR INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION PRACTICES. WE WILL MAIL A REVISED NOTICE TO THE ADDRESS YOU HAVE SUPPLIED US WHEN MATERIAL CHANGES
Created April 2016