BAINBRIDGE DIRECT PRIMARY CARE, PLLC
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. Our practice is committed to safeguarding the privacy and confidentiality of your health information. Although our practice is not directly subject to the federal Health Insurance Portability and Accountability Act (“HIPAA”), as we operate on a cash-based model and do not conduct HIPAA-standard electronic transactions, we have voluntarily adopted privacy practices consistent with many of HIPAA’s standards and underlying principles. This Notice outlines our practices, our legal duties, and your rights concerning your health information ("PHI"). We voluntarily commit to follow the privacy practices described in this Notice, which may be amended from time to time. For more information about our privacy practices, or to obtain additional copies of this Notice, please contact us using the information listed at the end of this Notice.
I. USES AND DISCLOSURES OF PHI
A. Permissible Uses and Disclosures Without Your Written Authorization. We may use and disclose PHI without your written authorization for certain purposes as described below. The examples provided in each category are not meant to be exhaustive but instead are meant to describe the types of uses and disclosures that are legally permissible.
1. Treatment: We may use and disclose PHI to provide treatment to you. For example, we may disclose PHI to other health care providers to provide you with appropriate care and treatment.
2. Payment: We may use or disclose PHI for the purposes of determining coverage, billing, claims management, and reimbursement. For example, we may disclose your PHI for the purpose of billing you for our health care services.
3. Health Care Operations: We may use and disclose PHI in connection with our health care operations. For example, we may use PHI to evaluate the performance of our staff.
4. Required or Permitted by Law: We may use or disclose PHI when we are required or permitted to do so by law. For example, we may disclose PHI to appropriate authorities if we reasonably believe that you are a possible victim of abuse, neglect, or domestic violence or the possible victim of other crimes. In addition, we may disclose PHI to the extent necessary to avert a serious threat to your health or safety or the health or safety of others. Other disclosures permitted or required by law include the following: disclosures for public health activities; health oversight activities including disclosures to state or federal agencies authorized to access PHI; disclosures to judicial and law enforcement officials in response to a court order or other lawful process; disclosures for research when approved by an institutional review board; disclosures for workers’ compensation claims; and disclosures to military or national security agencies, coroners, medical examiners, and correctional institutions.
B. Permissible Uses and Disclosures That May Be Made Without Your Authorization, But For Which You Have An Opportunity to Object.
1. Family and Other Persons Involved in Your Care. We may use or disclose PHI to notify or assist in the notification of (including identifying or locating), a family member, your personal representative, or another person responsible for your care, of your location, your general condition, or death. If you are present, then we will provide you with an opportunity to object prior to such uses or disclosures. In the event of your incapacity or emergency circumstances, we will disclose PHI consistent with your prior expressed preference that is known to us, and in your best interest as determined by our professional judgment.
2. Disaster Relief Efforts. We may use or disclose protected PHI to a public or private entity authorized by law or its charter to assist in disaster relief efforts for the purpose of coordinating notification of family members of your location, general condition, or death.
C. Uses and Disclosures Requiring Your Written Authorization.
1. Psychotherapy Notes. If we obtain your psychotherapy notes, we must have your written authorization prior to disclosing your psychotherapy notes, subject to exceptions under applicable law.
2. Marketing Communications; Sale of PHI. We must obtain your written authorization prior to using or disclosing PHI for marketing or the sale of PHI, consistent with the related definitions and exceptions under applicable law.
3. Other Uses and Disclosures. Uses and disclosures other than those described in this Notice will only be made with your written authorization.
4. Records Subject to 42 CFR part 2. To the extent that we considered a legal holder of substance use disorder treatment records received from programs subject to 42 CFR part 2, we must have your written authorization prior to certain uses and disclosures of such information, subject to exceptions under applicable law.
5. Washington State Privacy Protections. Washington State law also governs the confidentiality and disclosure of health-care information, and we comply with those provisions as applicable. In accordance with Washington State law, we will not share your PHI with entities from other states for the purpose of enforcing out-of-state laws that impose penalties or liability related to healthcare services that are lawful in Washington.
6. Redisclosure. PHI disclosed in accordance with this Notice may be subject to redisclosure by the recipient and may no longer be protected by this Notice or by applicable privacy laws.
II. YOUR INDIVIDUAL RIGHTS
A. Right to Inspect and Copy. You may request access to your PHI maintained by us to inspect and request copies of the records. All requests for access must be made in writing. Under limited circumstances, we may deny access to your records. We may charge a cost-based fee for the costs of copying and sending you any records requested.
B. Right to Alternative Communications. We will accommodate any reasonable written request for you to receive PHI by alternative means of communication or at alternative locations.
C. Right to Request Restrictions. You have the right to request a restriction on PHI we use or disclose for treatment, payment or health care operations. You must request any such restriction in writing addressed to 213 Madison Ave N, Suite 200, Bainbridge Island, WA 98110. We are not required to agree to any such restriction you may request, except if your request is to restrict disclosing PHI to a health plan for the purpose of carrying out payment or health care operations, the disclosure is not otherwise required by law, and the PHI pertains solely to a health care item or service which has been paid in full by you or another person or entity on your behalf.
D. Right to Accounting of Disclosures. Upon written request, you may obtain an accounting of disclosures of PHI made by us in the last six years, subject to certain restrictions and limitations.
E. Right to Request Amendment: You have the right to request that we amend your PHI. Your request must be in writing, and it must explain why the information should be amended. We may deny your request under certain circumstances.
F. Right to Obtain Notice. You have the right to obtain a paper copy of this Notice by submitting a request to 213 Madison Ave N, Suite 200, Bainbridge Island, WA 98110, or (206) 309-5302.
G. Right to Receive Notification of a Breach. You have the right to be notified of any breach of your unsecured PHI in accordance with applicable federal or state law.
H. Questions and Complaints. If you desire further information about your privacy rights or are concerned that we have violated your privacy rights, you may contact us at 213 Madison Ave N, Suite 200, Bainbridge Island, WA 98110 or (206) 309-5302. Although our practice is not subject to the federal HIPAA complaint process, you may contact the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services for general information about federal privacy rights. We will not retaliate against you if you file a complaint with OCR or with our office.