This policy describes how medical information about Sanvello patients is used and disclosed and how patients can get information to this information. This policy and notice of privacy attachment is pursuant to 45 CFR § 164.520. Please review it carefully
1. Sanvello Duties
2. Patients’ Complaints
Patients may complain to us and to the Secretary of the Department of Health and Human Services if patients believe that patients’ privacy rights have been violated. Patients may file a complaint with us by sending a certified letter addressed to Privacy Officer at firstname.lastname@example.org, stating what protected health information patients believe has been used or disclosed improperly. Patients will not be retaliated against for making a complaint. For further information patients may contact our Privacy Officer, at email@example.com.
3. Description and Examples of Uses and Disclosures of protected health information
By signing a Consent form regarding the use and disclosure of patients’ protected health information, patients agreed that Sanvello may use and disclose patients’ protected health information to carry out (i) treatment, (ii) payment, and (iii) health care operations.
Here are some examples of our use of patients’ protected health information.
(i) In connection with treatment, Sanvello will, for example, allow a physician associated with us to use patients’ medical history, symptoms, injuries or diseases to treat patients’ current condition.
(ii) In connection with payment, Sanvello will, for example, send patients’ protected health information to patients’ insurer or to a federal program, such as Medicare, that pays for patients’ treatment. This allows us to obtain payment for the services Sanvello rendered on patients’ behalf.
(iii) In connection with Health Care Operations, Sanvello will, for example, allow our auditors, consultants, or attorneys access to patients’ protected health information to determine if Sanvello billed patients accurately for the services Sanvello provided to patients.
4. Description of Uses and Disclosures Sanvello May Make Without Patients’ Consent
Even without patients’ consent, the privacy regulations, gives us the right to use and disclose patients’ protected health information:
(i) if patients are an inmate in a correctional institution;
(ii) if Sanvello has an indirect treatment relationship with patients,
(iii) if, in an emergency treatment situation, Sanvello attempts to obtain consent as soon as reasonably practicable after Sanvello delivered such emergency treatment;
(iv) if Sanvello is required by law to treat patients, and Sanvello tries but are unable to obtain such consent; or
(v) if Sanvello attempts to obtain consent from an individual who has substantial barriers to communicating, but Sanvello determines in our professional judgment, that patients’ consent to receive treatment is clearly inferred from the circumstances. The purposes for which Sanvello might use patients’ protected health information would be to carry out treatment, payment, and health care operations similar to those described in Section 3.
5. Other Uses and Disclosures Require Patients’ Authorization
Uses and disclosures other than those allowing us to carry out treatment, payment, and health care operations, and other than those for which patients consent is not required by law, will only be made by obtaining a written authorization from patients. Patients may revoke this authorization in writing at any time, except to the extent that Sanvello has taken action in reliance of patients’ authorization.
6. Uses of protected health information to Contact Patients
Sanvello may use patients’ protected health information to contact patients regarding appointment reminders or to contact patients with information about treatment alternatives or other health-related benefits and services that, in our opinion, may be of interest to patients. Sanvello may not use patients’ protected health information to contact patients in an effort to raise funds for our operations.
7. Disclosures of protected health information for Billing Purposes
Sanvello may disclose patients’ billing information to any person that calls our billing company with billing question after Sanvello verifies the identity of the person by requesting information such as patients’ social security number or health plan number.
8. Individual Rights
(i) Patients may request us to restrict the uses and disclosures of patients’ protected health information, but Sanvello does not have to agree to patients’ request.
(ii) Patients have the right to request that Sanvello communicates with patients regarding patients’ protected health information in a confidential manner or pursuant to an alternative means, such as by a sealed envelope rather than a postcard, or by communicating to a specific phone number, or by sending mail to a specific address. Sanvello is required to accommodate all reasonable requests in this regard.
(iii) Patients have the right to request that patients be allowed to inspect and copy patients’ protected health information as long as it is kept as a designated record set, and as long as patients pay in advance for the administrative time and costs to make arrangements to have the records inspected and copied. Certain records are exempt from inspection and cannot be inspected or copied, so each request will be reviewed by Sanvello in accordance with the standards published in 45 C.F.R. § 164.524.
(iv) Patients have the right to amend patients’ protected health information for as long as the protected health information is maintained in the designated record set. Sanvello may deny patients’ request for an amendment if the protected health information was not created by us, or is not part of the designated record set, or would not be available for inspection as described under section 45 C.F.R. § 164.524, or if the protected health information is already accurate and complete without regard to the amendment.
(v) Patients have the right to request, and thereafter receive, an accounting of the disclosures of patients’ protected health information for six years before the date on which patients request the accounting. An exception to this accounting are those disclosures not allowed by law pursuant to section 164.528. Each request for an accounting will be reviewed pursuant to the rules of section 164.528.
(vi) Patients also have a right to receive a copy of this Notice upon request.
9. Effective Date
The effective date of this Notice is October 1, 2019.