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Understanding Healthcare Information and Your Rights to Privacy & Confidentiality

Each time you visit your campus healthcare professional a record of that visit is made. It typically includes an evaluation of your symptoms and details of the treatment you received. The record serves a number of purposes. First, it allows for continuity of medical services by recording your medical history and treatment. The record also contains information on insurance and payments for the services you received. It may also serve other purposes such as a source of data for medical peer review and performance improvement activities.

The medical record is a legal document and cannot be changed but in certain circumstances may be amended. You have the right to access and review your record (with a few limitations) and to control to whom your information is sent. Understanding your record and how your health information is used helps you to ensure its accuracy, better understand who may access your health records and under what circumstances, and to make informed decisions when authorizing disclosure to others.

Our Pledge Regarding the Privacy and Confidentiality of Your Health Information

The privacy and confidentiality of your personal and health information is of paramount importance to us. Two federal acts, the Health Information Portability and Accountability Act 1996 (45 CFR Parts 160, 162, and 164, as amended) better known as HIPAA and the Family Education Rights and Privacy Act (20 U.S.C. § 1232g; 34 CFR Part 99) or FERPA are the primary legal means protecting your rights to the privacy and confidentiality of your medical and educational records. You may view the specific content of these federal acts by clicking on http://www.hhs.gov/ocr/hipaa/ for HIPAA and http://www.ed.gov/policy/gen/guid/fpco/ferpa for FERPA. Please understand that there are differences in the level of protections afforded by HIPAA and FERPA.

In order to protect the confidentiality of your healthcare information, Student Health Services (SHS) will release or disclose information only with your signed authorization or as required or allowed by law. Our Notice of Privacy Practices explains fully the various circumstances under which we may release or disclose protected information without your authorization.

Please read the Notice of Privacy Practices carefully and if you have questions about its content contact Keith L. McCrary, Assistant Director for Compliance, University of North Carolina Greensboro Student Health Services (336) 334-3147 or at klmccrar@uncg.edu .

Your Student Health Services pledges to comply will all applicable federal, state, and University regulations, laws, and guidelines in place to protect the privacy of your healthcare information.

Notice of Privacy Practices

This notice describes how medical information about you may be used and disclosed and how you may obtain access to this information. Please review carefully. This Notice of Privacy Practices describes how we may use and disclose your Protected Health Information (PHI) to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law.

It also describes your rights to access and control your Protected Health Information. PHI is information about you, including demographic information that could potentially identify you. PHI can include information about your past, present, and future physical or mental health conditions and related health care services.

All employees of UNCG Student Health Services are required to protect the privacy of your health information and to abide by the terms of this Notice of Privacy Practices. This notice describes our legal duty to protect the privacy of your healthcare information and the policies and procedures SHS has in place to do so.

We may change the terms of our notice at any time. The new notice will be effective for all PHI that we maintain at that time. We will provide you with a copy of any substantially revised Notice of Privacy Practices.

How we may use and disclose protected health information

The following categories describe different ways in which we may use and disclose protected health information. The use of PHI occurs within Student Health Services while disclosure of PHI is to a person or entity not directly affiliated with Student Health Services. These examples are not meant to be exhaustive, but to describe the types of uses and disclosures that may be made by our office.

• For Treatment: We will use and disclose PHI about you to provide, coordinate or manage your health care treatment and related services. This may include communicating with health care providers within or outside of our clinic who may be involved in your treatment. As a general rule and even though not required by HIPAA, we make every attempt to obtain your authorization to disclose information to an outside provider. Example of Internal Use of PHI: Front desk staff may use PHI when setting up an appointment. The provider will likely use PHI when reviewing a patient’s condition and ordering a blood test. The lab technician wil1 use PHI when processing or reviewing blood test results.
• For Payment: We can disclose PHI about you in order to receive payment or help you obtain reimbursement for your health care services. This may include certain activities which your health insurance plan undertakes before it approves or pays for the health care services we provided or recommended for you. Example: We will disclose information that you received services from our office, the date of those services and the amount owed for those services to the University Cashiers Office if you request that charges be billed to your University account. The details of the services you received are not included in the disclosure. Upon your authorization, we may disclose your PHI to your insurance company, as needed, for you to obtain reimbursement for the payment for your health services. This will be limited to the minimum necessary amount of information required to facilitate payment.

For Health Care Operations. We may use and disclose PHI about you for Student Health Services operations. These activities include:

• Licensing, reviewing and evaluating the skills, qualifications, and performance of health care providers taking care of you;
• Providing training programs for students, trainees, health care providers or non-health care professionals to assist them in practicing or improving their skills;
• Cooperating with outside organizations that evaluate, certify, accredit or license health care providers, staff or facilities in a particular field or specialty;
• Planning future operations for our organization;
• Working with others (such as lawyers, accountants, and other providers) who assist us to comply with this Notice and other applicable laws;
• Quality improvement activities;
• Conducting and arranging for other business activities;
• "Business associates" that perform various activities for Student Health Services (e.g. transactions services, billing). We have a written contract with all business associates with whom we share your protected heath information that contains terms ensuring they will protect the privacy of your health information;
• Treatment Alternatives. We may use and disclose medical information to recommend possible treatment options or alternatives that may be of interest to you. We may also mail to you copies of your lab reports;
• Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at the Health Center; and
• 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 of PHI based upon your written authorization

Some use and disclosures of your PHI are made only with your written authorization unless otherwise permitted by law. You may revoke your authorization at any time except to the extent a disclosure has already been made in good faith based upon your authorization. Example: Psychotherapy notes will not be used or disclosed without a signed authorization from you.

Other permitted and required uses and disclosures that may be made with your authorization or opportunity to object

We may use and disclose your PHI in the following instances for which you have the opportunity to agree or object to the use and disclosure of all or part of your PHI: Individuals Involved In Your Care. We may disclose medical information about you to a relative, close personal friend or any other person you identify if that person is involved in your care and the information is relevant to your care or payment for your care. If you are unable to agree or object to such a disclosure we may disclose pertinent information if we feel it is in your best interest based on our professional judgment. We may use or disclose PHI to notify or to assist in notifying a family member, personal representative or any other person responsible for your care of your location, general condition or death. We may use or disclose your PHI to an authorized public or private entity to assist in disaster relief efforts and to coordinate uses and disclosures to family or other individuals involved in your care.

Emergencies. We may use and disclose your PHI in an emergency treatment situation. If this happens, your provider shall try to obtain your consent as soon as reasonable after the delivery of treatment. If your provider is required by law to treat you and the provider has attempted to obtain your consent but is unable to do so, he or she may still use or disclose your PHI to treat you. In any case, we will disclose only the information necessary to address adequately the emergency situation.

Communication Barriers. We may use and disclose your PHI if your provider attempts to obtain consent from you but is unable to do so due to substantial communication barriers. In order to do so, the provider must determine, using professional judgment that you intend to consent to the use or disclosure under the circumstances.

Disaster Relief. We may use or disclose PHI to a public or private agency that is authorized by its charter to assist in disaster relief efforts.

Other permitted or required uses and disclosure that may be made without your authorization or opportunity to object

• As Required by Law. We will use or disclose PHI about you when required to do so by federal or state statutes and regulations. The use or disclosure will be in compliance with the law and limited to the relevant requirements of the law. You will be notified, as required and when allowed by law, of any such disclosures.
• Workers' Compensation. We may disclose PHI about you to comply with Workers' Compensation laws and other similar legally established programs. These programs provide benefits for work-related injuries or illnesses.
• Public Health Activities. We may disclose your PHI for public health activities and purposes to a public health agency that is required by law to collect and receive the information. This disclosure will be:
• To prevent or control disease, injury or disability;
• For contacting individuals and preventing the spread of a disease;
• To notify the appropriate government authority about any suspected child abuse or neglect;
• We may disclosure your PHI, if directed by a public health authority to a foreign government that is collaborating with the public health authority;
• Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose PHI about you in response to a legally constituted mandate by a court or an administrative order;
• Law Enforcement. We may release PHI if asked to do so by a law enforcement official, as long as applicable legal requirements are met. These law enforcement purposes include:
• Legal processes and as otherwise required by law;
• Limited information requests for identification and location purposes;
• Pertaining to victims of a crime;
• Suspicion that death has occurred as a result of criminal conduct;
• In the event that a crime occurs on the premises of the Student Health Center;
• Medical emergency (not on the Health Center premises) and it is likely that a crime occurred;
• To Avert 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, and to the safety of the public or another person;
• Abuse, Neglect or Domestic Violence. We may disclose PHI to a social services authority that is authorized by law to receive reports of suspected abuse or neglect or to law enforcement. In addition, if we reasonably believe that you may be a victim of abuse, neglect or domestic violence, we may disclose your PHI to the government entity or agency authorized to receive such information. The disclosure will be made consistent with applicable state and federal laws;
• Food and Drug Administration. We may disclose your protected health information to a person or company required by the Food and Drug Administration to notify people of recalls of products they may be using and to report reactions to medications or problems with products;
• Coroners and Others. We may disclose PHI to a coroner, medical examiner, or funeral director or to organizations that help with organ, eye and tissue transplants;
• National Security and Intelligence Activities. We may release medical information for intelligence, counterintelligence, and other national security activities authorized by law;
• Military and Veterans Activities. For the activities deemed necessary by the appropriate military command authorities; for the purpose of determining your eligibility for benefits by the department of Veteran Affairs; and to a foreign military authority if you are a member of that foreign military service; and
• Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release PHI to the correctional institution or law enforcement official.

Your rights regarding medical information about you

You have the following rights regarding medical information we maintain about you:

• Right to Inspect and Copy. You have the right to inspect and request a copy of the medical information used to make decisions about your care. Usually this includes medical and billing records, but does not include psychotherapy notes. Copying information will be limited to only those documents created by the Student Health Service. You may inspect documents created by another entity but in most cases, you must obtain a copy of those documents from the originator. Immunization records may be copied. In order to inspect and receive a copy of your medical information that may be used to make decisions about you, you must submit your request in writing to the Health Information Manager. Forms are available at the Reception Desk and on the Student Health Center’s home page under the link for forms. We may deny your request to inspect and receive a copy in certain very limited circumstances. If you are denied access to your medical information, we will provide you with a written notice of the reason for denial and you may request that the denial be reviewed. A licensed health care professional chosen by Student Health Services will review your request and the denial. We will comply with the outcome of the review.
• Right to Amend. If you feel that the medical information we have about you is inaccurate or incomplete, you may request that we amend the information to indicate the problem and notify others who have copies of the inaccurate or incomplete information. You have the right to request an amendment for as long as the information is kept by or for Student Health Services. To request an amendment, your request must be made in writing and submitted to the Health Information Manager. In addition, you must provide a reason that supports your request. Forms are available at the Reception Desk and on our web site. 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 us to amend information that:
• Was not created by us, unless the person or the entity that created the information is no longer available to make the amendment;
• Is not part of the medical information kept by or for Student Health Services;
• Is not part of the information which you would be permitted to inspect and copy; and
• Is accurate and complete.
• Right to an Accounting of Disclosures. You have the right to an "accounting of disclosures." This is a list of the disclosures of medical information we may make without your authorization. To request a list of the accounting of disclosures, you must make a submission in writing to the Health Information Manager. Your request must state a time period, which may not be 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. Request forms are available at the Reception Desk and on our web site.
• Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for payment, treatment or health care operations. We are not required to agree to your request, especially if the requested restriction inhibits our ability to provide emergency treatment. If we agree, we will comply with your request until such a time that you decide to remove the restriction. To request restrictions, you must make your request in writing to the Health Information Manager. 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 medical 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. Unless specifically denied by you, we reserve the right to contact you by phone, leave a voice mail message or by e-mail. However, if we use these forms of communication, no specific medical information will be included in a message. For example, we may e-mail a reminder of an appointment but not indicate the purpose of the appointment or leave a voice mail asking that you contact the Student Health Center but not why. To request confidential communications, you must make your request in writing to the Health Information Manager. 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 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. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.

You may view or print a copy of this notice at our website, http://studenthealth.uncg.edu

You may obtain a paper copy of this notice from UNCG Student Health Services.

Changes to this Notice

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in our waiting area. The notice will contain on the first page, in the top right-hand corner, the effective date. Copies will be available upon request.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with the UNCG Student Health Services Compliance Officer or with the Secretary of the Department of Health and Human Services. All complaints must be submitted in writing. Please refer to the Department of Health and Human Services for instructions on how to file a complaint with the Office of Civil Rights.

You will not be penalized for filing a complaint.

Other uses of Medical Information

Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose medical information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. However, we are unable to retrieve any disclosures we have already made with your permission and we are required to retain our records of the care that we provided to you.

Page updated: 12-Oct-2007

Accessibility Policy