HIPAA TEAM

 

Hear Again Center, LLC executes HIPPA compliance requirements on an ongoing basis, with leadership responsibilities assigned to the following team members:

 

1.        Compliance Plan Extension Filing: TeriLee Boulanger

2.      Policies & Procedures Development: TeriLee Boulanger

3.      Privacy Officer/ Office Manager: TeriLee Boulanger/Connie Taylor

a.       Monitor daily procedures

b.      Provide new hires with all compliance materials

c.      Provide new & established patients with privacy information

and policies

  

4.     Policies & Procedures Implementation ­ all employees are responsible for adhering to privacy policy and other HIPAA compliance regulations both in and away from the office.

 

5.      Records Management ­

a.       Office Manager

b.      Office Staff

c.      Bookkeeper

d.      Audiologists

e.      Dispensers

 

           

 

 

 

Privacy Policy

 

Introduction

 

HIPAA (Health Insurance Portability and Accountability Act of 1996) was passed to achieve two objectives:

a.       To improve claims processing ­ reducing errors and thereby reducing costs through electronic claims processing

b.      To provide for the privacy of patient health information.

 

The Hear Again Center is committed to electronic claims processing and is working with our software vendors to ensure that this objective is maintained.

We also are committed to making every effort to ensure the privacy of our patients’ health information.

 

Patients must be presented with a copy of the Notice of Privacy Practices and must acknowledge that they have been presented with a Notice. They are entitled to their own copy of the Notice and a supply will be available at the Front Desk.

 

Privacy Officer

TeriLee Boulanger has been appointed as the Privacy Officer for Hear Again Center, LLC. The Privacy Officer is responsible for the following:

a.       helping our practice comply with ensuring the privacy of patient

health information

b.      designing, and implementing, a privacy training program

c.      dealing with outside vendors who may have access to patient information

d.      dealing with changes in government rulings and implementing changes within the practice

e.      establish reporting mechanisms and reports of privacy infractions

f.        handling all questions & issues from staff & specialists

g.      maintaining all HIPAA files & documents

 

 

 

 

 

 

Training & Education

All specialists and staff members will be involved in training and programs designed to protect our patients’ health information. No individual is exempt from protecting the health information of our patients. Re-training in regard to Hear Again Center’s privacy practices and procedures will be conducted at least once per year for all specialists and staff. Suggestions to maximize patient privacy are welcome at any time.

 

Reporting

Any specialist or staff member who is aware of any possible violation of compliance with our Privacy Policies is expected to report this to the Privacy Officer. It is understood that these reports will be treated with the highest degree of confidentiality. All efforts will be made to conceal the identity of the reporting individual and no action will be taken against the reporting individual.

 

To report an incident:

a.       Complete a Privacy Incident Report Form. All specialist and staff will be provided with this document.

b.      In a sealed envelope, leave the incident report on the desk of the Privacy Officer or mail to her attention.

 

The Privacy Officer is authorized to investigate any reports regarding alleged breaches of Patient Health Information. It is anticipated that the Privacy Officer will investigate these reports.

 

In the process of these investigations, we expect all specialists and staff will fully cooperate with the Privacy Officer. These investigations will be conducted as discreetly as possible. Depending on the infractions, the Privacy Officer will make recommendations regarding the disposition of these cases. Our primary goal is to take actions, which will prevent similar infractions from being repeated.

 

Cases may result in:

            Verbal warning

            Written warning

            Suspension

            Termination

 

 

 

Patient Complaints about Privacy

Our practice is interested in maintaining the privacy of our patients’ health information. Obviously, if any patient registers a complaint, regarding what is considered to be a violation of their privacy, this merits careful attention. All complaints should be acknowledged with concern, appreciation and respect.  The attitude of the staff member or specialist receiving the complaint is extremely important for the outcome of a complaint.

 

 

Each staff member and specialist is expected to determine the severity of the alleged infraction. Different levels of severity merit different actions. The individual hearing the complaint will use his/her own judgment in dealing with the complaint. What follows are some general guidelines:

 

Low-level Complaint

            If the patient is simply pointing out a perceived privacy infraction, the individual hearing the complaint should express concern ­ then point out that this incident will be investigated and that the practice has a review procedure for all these reports. If this satisfies the patient then this action will suffice. However, a Privacy Incident Report should be provided to the Privacy Officer.

 

Mid-level Complaint

            Staff and specialists should use their discretion and assist the patient in meeting with an office manager or Privacy Officer in a private setting. A complete record of the complaint should be provided to the Privacy Officer. It is important that the patient recognize that the practice acknowledges the complaint and has a protocol for dealing with it. It is assumed that this will satisfy the patient and will be thoroughly reviewed by the Privacy Officer.

 

High-level Complaint

            This more severe complaint merits all the steps outlined in the med-level complaint procedure. However it would also involve a verbal and/or written report for the patient, provided by the Privacy Officer. 

 

 

           

 

 

   Notice of Privacy Practices

To Our Patients:  This notice describes how health information about you as a patient of this practice, may be used and disclosed, and how you can get access to your health information. This is required by the Privacy Regulations created as a result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

 

Our Commitment To Your Privacy:

Our practice is dedicated to maintaining the privacy of your health information. We are required by law to maintain the confidentiality of your health information.  We realize that these laws are complicated, but we must provide you with the following important information:

Use and disclosure of your health information in certain special circumstances

The following circumstances may require us to use or disclose your health information:

1.        To public health authorities and health oversight agencies that are authorized by law to collect information.

2.      Lawsuits and similar proceedings in response to a court or administrative order.

3.       If required to do so by a law enforcement official.

4.      When necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. We will only make disclosures to a person or organization able to prevent the threat.

5.       If you are a member of U.S. or foreign military forces (including veterans) and if required by appropriate authorities.

6.       To federal officials for intelligence and national security activities authorized by law.

7.       To correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official.

8.       For Workers Compensation and similar programs.

 

Your Rights Regarding Your Health Information:

1. Communications ­ You can request our practice communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than work. We will accommodate reasonable requests.
2. You can request a restriction in our use or disclosure of your health information for treatment, payment, or health care operations. Additionally, you have the right to request that we restrict our disclosure of your health information to only certain individuals involved in your care or the payment for your care, such as family members and friends. We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when information is necessary to treat you.

 

 

 

3. You have the right to inspect and obtain a copy of the health information that may be used to make decisions about you, including patient medical records and billing records. You must submit your request in writing to the address at the bottom of this document.
4. You may ask us to amend your health information if you believe it is incorrect or incomplete, and as long as the information is kept by or for our practice. To request an amendment, your request must be made in writing and submitted to the address at the bottom of this document. You must provide us with a reason that supports your request for amendment.
5. Right to a copy of this notice- You are entitled to receive a free copy of this Notice of Privacy Practices. You may ask us to give you a copy at any time. To obtain a copy of this notice, please see any of our office staff.
6. Right to file a complaint- If you believe your privacy rights have been violated, you may file a complaint with our practice or with the Secretary of the Department of Health and Human Services. To file a complaint with our practice, please contact Connie Taylor or TeriLee Boulanger at (860)646-7900.

All complaints must be submitted in writing. You will not be penalized for filing a complaint.

       7.    Right to obtain an authorization for other uses and disclosures- Our practice will                               obtain your written authorization for uses and disclosures that are not identified

                by this notice or permitted by applicable law.

 

If you have any questions regarding this notice or our health information privacy policies, please contact our office manager, Connie Taylor at (860)646-7900 or any specialist or staff member.

 

Hear Again Center, LLC

27 Hartford Turnpike

Vernon, CT 06066

(860)646-7900

 

 

 

 

Acknowledgement of Notice of Privacy Practices

 

 By signing below, I acknowledge that I have received a copy of the Hear Again Center’s Notice of Privacy Practices. I have read and understand the Notice and I have had an opportunity to ask questions about the use and disclosure of my health information, and other concerns regarding my health information.

 

 

_____________________________________________________                      ____________________

Signature of Patient (or Representative)                                              Date

 

_____________________________________________________

Printed Name of Patient (or Representative)

 

 

 

Please review the following special requests and initial any/all, which may apply:

 

___________ Do Not contact me at my place of business        

 

___________ Do Not leave phones messages at my home or business

 

___________ Do Not send me a client newsletter

 

___________ Do Not release information to my insurance carrier, PPO, HMO, or employer

                                that may be billed for charges

 

 

 

 

---------------------------------------------------------------------------------------------------------

OFFICE USE ONLY

 

Client named above is unwilling/unable to sign this acknowledgement.

 

 

_____________________________________________________                      ____________________

Specialist                                                                                                            Date

 

 

 

                                                                                                               

 

 

 

 

 

Privacy Incident Report

 

Was this incident related to (check all that apply)

            ______ Patient complaint

            ______ Specialist non-compliance

            ______ Staff member non-compliance

            ______ Facility/Equipment problem

            ______ Other

 

Describe the incident/non compliance event. Please include date, time, and individuals involved.

 

Please list anyone else who observed this incident

 

 

Today’s Date_____________________

 

Your Name (Optional)__________________________________________________

 

HIPAA TRAINING SESSIONS

 

 

October 22, 2002

 

March 27,  2003

 

April 24, 2003

 

 

 

MODIFICATION FOR HIPAA COMPLIANCE

 

1.        Fax Cover Sheet Disclaimer must be on any fax sent re: client info.

2.      Postcards must be sent in envelopes

3.      Shred any paperwork with client’s name

4.     No charts left out ­ desks, workstations, front counter

5.      NPP in place

6.      NPP acknowledgements in place

7.       BAA completed for:

a.       Bernafon       (mailed)

b.      Emtech         (mailed)

c.      Oticon           (done)

d.      Phonak          (mailed)

e.      Resound        (mailed)

f.        Rexton          (mailed)

g.      Siemens        (done)

h.      Starkey         (mailed)

i.        Unitron         (mailed)

j.        Widex          (done)

k.      Marlene Jung (mailed)

l.        Ford, Oberg, Manion & Houck  (mailed)

m.   A &S Collection    (mailed)

 

 

 

 

Employee Acknowledgement

 

By signing this document, I acknowledge receiving copies of the following:

 

a.       Hear Again Center Privacy Policy

b.      HIPAA Team assignment

c.      Fax Sheet Privacy Disclaimer

d.      Client Notice of Privacy Practices (NPP)

e.      Privacy Incident Report

 

 

 

Name_____________________________________________

 

Signature __________________________________________   Date ________________