Skills of Central PA, Inc.
Overview of Notice of Privacy Practices (HIPAA)

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.

Effective Date: 4/14/03

I.

Our Legal Duties
 
  1. We are required by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) to give you this Notice of Privacy Practices regarding our legal duties and your rights concerning your Protected Health Information (PHI).
  2. Skills will inform you of these practices prior to the delivery of the first day of Services. Skills will follow the terms of the notice that is currently in effect.
  3. Skills will take reasonable steps to limit the use of PHI to the minimum necessary to accomplish normal business practices.
  4. Skills will follow the terms of the notice that is currently in effect.
   
II. Uses and Disclosures of PHI
  Skills will collect, use, and disclose PHI in order to administer services and supports effectively and/or to manage our business. The following activities describe different ways that we may use and disclose your PHI. It should be noted that Skills will request you to sign an authorization/consent to use or disclose your PHI for any reason other than Treatment, Payment or Healthcare Operations (TPO).
 
   
A. Uses and Disclosures of PHI for Treatment, Payment, and Program Operations
   
  Treatment
  We may use your PHI to provide you with medical treatment or services. We may disclose PHI about you to doctors, nurses, technicians, direct care staff, and/or other medical and Skills’ Personnel who may be involved in taking care of you. For example, Residential Support Staff working in your community group home may need to tell the doctor at the hospital that you have diabetes when treating you at the emergency room for a broken arm.
   
  Payment
  We may use and disclose PHI about you so that the treatment and services you receive may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health insurance plan information about your emergency room visit/treatment in order to receive payment or reimbursement for services.
   
  Programming
  We may use and disclose your PHI to assist in planning your care and specialized needs for daily living. We may disclose PHI about you to direct care staff, nurses, doctors, therapists, technicians, other human service providers, insurance companies, support coordinators, The Commonwealth of Pennsylvania’s Health and Human Services Programs such as DPW, Office of Mental Retardation, Office of Mental Health, and Department of Aging, to name a few, and other Skills’ personnel as necessary to perform their job duties in carrying out normal business operations.
   
  For Business Operations
  We may use and disclose PHI about you for Skills’ Operations. These uses and disclosures are necessary to run Skills and make sure all of our individuals receive cost effective quality care. For example, we may use your PHI to review and evaluate the performance of our staff in caring for you and to evaluate your changing needs. We may use and disclose your PHI to Quality Improvement Review Committees (QIRC) to ensure the highest quality of care to our individuals.
   
B. Uses and Disclosures of Protected Health Care Information to Other Entities
  Skills may use and disclose PHI to other covered entities, business associates or individuals (as permitted by the HIPAA Privacy Rule) who assist us in administering our programs and perform various functions on our behalf. For example, we may disclose PHI for licensure, inspections, audits, attorneys, contractors, and union representatives.
   
III. Other Possible Uses and Disclosures of Protected Health Information (PHI)
  In addition to the uses and disclosures for treatment, payment, programming and program operations, we may use and disclose your PHI for the following purposes:
 
  Legal Proceedings
  We may disclose your PHI in the course of any judicial or administrative proceedings, in response to a subpoena, or in response to an order of a court. For example, we may disclose your PHI in response to a subpoena for such information.
   
  Required by Law
  We may use or disclose your PHI to the extent that federal or state law requires the use or disclosure. For example, we must disclose your PHI to the US Department of Health upon request for the purposes of tracking communicable diseases.
   
  Fund-raising/Marketing
 

As a non-profit organization, Skills on occasion will conduct private fund-raising to help support our mission. We may use portions of your PHI such as demographic information to contact you in an effort to raise money for the Skills Foundation. For example, the Annual Appeal letter that is sent out.

At times Skills will participate in Provider and Job Fairs in an effort to recruit potential consumers and employees. We may use or disclose portions of your PHI, such as demographic information and photographs in our marketing brochures and literature. We would have you sign a release form before using any photograph of you. If you do not want Skills to use your photograph you have the right to decline.
   
  Family Members
  We may use and disclose your PHI to communicate with your family. Unless you specifically object our staff may disclose to a family member, relative, close friend, or any other person you identify PHI relevant to that person’s involvement in your care or payment related to your care. We may also disclose PHI to these people in notifying them of your location and general condition in case of an emergency.
   
  Union Representatives/Officials
  We may disclose PHI in the course of reaching a resolution regarding a discipline grievance or unfair labor practices filed by a labor union. For example, we may have to disclose specific details of an allegation of abuse that required medical treatment to justify disciplinary action up to, and including termination of employment of the staff involved.
   
  Business Associate Agreement
  Agreements will be signed with business associates for other covered entities and the use and disclosure of PHI be adhered to. For example, we would sign a business associate agreement with local hospitals when our consumers are treated at their facilities.
   
  Abuse or Neglect
  We may disclose your PHI to a government authority that is authorized by law to receive reports of abuse or neglect. For example, we may disclose your PHI to the Area Agency on Aging in accordance with Act 28, Neglect of Care for Dependent Persons.
   
  Law Enforcement
  We may also disclose your PHI to law enforcement officials. For example, we may disclose to a police officer conducting a criminal investigation while trying to locate or identify a suspect, witness, or missing person.
   
  Coroners, Medical Examiners, Funeral Directors
  We may disclose PHI to a coroner or medical examiner for purposes of determining a cause of death. We may also disclose, as authorized by law, to funeral directors so that they may carry out their duties.
   
  Workers' Compensation
  We may disclose PHI about you for workers’ compensation claims. For example, benefits may be due to an employee for a work related injury or illness.
   
  Disclosure to You
  We are required to disclose to you most of your PHI that is in a “designated record set” when you request access to this information.
   
  * Designated record set is defined as a set which contains medical and billing records, and other records that are used to make decisions about your programming and health care. However, you may not inspect or copy psychotherapy notes.
   
IV. Your Individual Rights
  The following is a description of your rights with respect to your PHI.
 
  Right to Access
 

You have the right to look at or get copies of your PHI in a designated record set.

You may request that we provide copies in a format other than photocopies. We will use the format you request unless we cannot practically do so. You must make a request in writing to obtain access to your PHI.

To inspect and/or copy your PHI, we may charge you a reasonable cost based fee for responding to your request. Likewise, if you request an alternative format we will charge a cost based fee for that format also.

Skills may deny your request to inspect or copy your PHI in certain circumstances. If we denied you access to your PHI, you may request a review. A licensed health care professional chosen by us will review your request and denial. The person performing the review will not be the same person who denied your initial request. Skills reserves the right under certain conditions that your denial is not reviewable. We will inform you in writing if this should be the case.

You may request access to your PHI by sending us a letter or by the contact information listed at the end of this notice.
   
  Right to an Accounting
 

You have the right to an accounting of certain disclosures of your PHI that are for reasons other than treatment, payment, programming, or programming operations.

An accounting will include the date(s) of disclosure, to whom we made the disclosure, the purpose of the disclosure, and a brief description of information disclosed.
   
  Right to Request a Restriction
  You have the right to request a restriction on the PHI we use or disclose for treatment, payment, programming, and programming operations. Skills is not required to agree to these restrictions, however, if we agree to your request for restriction of your PHI, Skills will abide by our agreement unless the information is needed to provide emergency treatment to you.
   
  Right to Request Confidential Communications
 

If you believe that a disclosure of your PHI may cause you undue problems or endanger you, you have the right to request that we communicate with you in confidence by alterative means or locations. For example, you may ask that we only contact you at your home or send all written correspondence to a Post Office Box verses your home address.

All requests for Confidential Communications must be in writing. Your request must state that the information could endanger you if not communicated in confidence. Skills must accommodate your request if it is reasonable and it continues to permit us to use your PHI for treatment, payment, programming and programming operations.
   
  Right to Amendment
 

If you believe that your PHI is incorrect or incomplete, 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.

Skills may deny your request if we did not create the information you want amended. If we deny your request you may respond with a statement of disagreement to be appended to the PHI you want amended.
   
  Right to Paper Copy of this Notice
  You have the right to receive this notice in written form.
   
V. Questions and Complaints
 

If you have questions about our privacy policies or practices or want additional information, please contact us using the information listed below.

If you are concerned that we may have violated your privacy rights, or disagree with a decision we made about access, amending, accounting, or confidential communication of your PHI, you may complain to us by using the contact information listed below.

You also may submit a written complaint to the US Department of Health and Human Services. Skills will provide you with the address to file your complaint with the US Department of Health and Human Services upon request.

Skills supports and respects your right to protect the privacy of your PHI information. We will not retaliate in any way if you choose to file a complaint with us or with the US Department of Health and Human Services.
   
Contact Information
  Skills Privacy Officer
  Stephen Martynuska
Telephone: (814) 238-3245
Fax: (814) 238-5117
Address: 341 Science Park Road, Suite 6
  State College, PA 16803