Privacy Practices

The transition to college life for both students and parents can be both exciting and frightening. It can be especially upsetting for parents when great distances separate you and your student and they phone home to say they are feeling ill. We understand your concern and are committed to doing all that we can to get your student feeling better quickly. Please note that because of federal privacy regulations, we will be unable to discuss your student’s Health Center visit without written authorization from the student.

On their first visit to the Health Center, all students are given a form which, if they choose, will give the Health Center permission to speak with their parents or guardians.

THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

WHO WILL FOLLOW THIS PRACTICE:

• The business office operations of the Valparaiso University Health Center;
• Any health care professional authorized to enter information into your Health Center record;
• All employees, staff, or other Valparaiso University Health Center personnel and any residents or student trainees at Valparaiso University Health Center;
• Any member of a volunteer group we allow to help you while you are at the Health Center

Individuals and entities will share your medical information as necessary to carry out treatment, payment, and health care operations relating to the uses and disclosures of Valparaiso University Health Center as described more specifically in this notice.

OUR PLEDGE REGARDING MEDICAL INFORMATION

We understand that medical information about you and your health is personal. We are committed to protecting your information. We create a record of the care and services you receive at the Health Center. We need this record to provide you with quality care and to comply with certain legal requirements. This notice is effective August 14, 2008, and applies to all protected health information as defined by federal regulations.

This notice applies to all records of your care generated by the Health Center.

This notice will tell you about the ways in which we may use and disclose your medical information. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.

We are required by law to:

• Maintain the privacy of medical information that identifies you;
• Give you this notice of our legal duties and privacy practices with respect to medical information about you; and
• Follow the terms of this notice that is currently in effect.

HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU

The following categories describe different ways that we use and disclose medical information. For each category of uses and disclosures, we will explain what we mean and provide some examples. This notice does not describe every possible use or disclosure of your health information; however, any use or disclosure we make of your health information will fall into one of the following general categories.

Treatment

Example: The information obtained by a nurse, nurse practitioner, physician, or other members of your health care team will be recorded in your record and used to determine the course of treatment that should work best for you. Your health care provider will document in your health record his or her prescribed treatments for your condition; i.e., medications, lab testing, etc. Members of the health care team will then record the actions they took and their observations. In that way, the health care provider will know how you are responding to treatment.

With your written authorization, we will also provide your physician or a subsequent health care provider with copies of various reports that should assist him or her in treating you once you are no longer a patient at the Student Health Center.

Payment

Example: A bill may be sent to you or an insurance company. The information on or accompanying the bill may include information that identifies you as well as your diagnosis, procedures, and supplies used. The Health Center will bill your student insurance for some of the procedures, tests, or immunizations that we may give. The Health Center will also provide you with a receipt for services rendered.

Regular Health Center Operations

Example: Members of the medical staff and/or members of the quality improvement team may use information in your health record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and service we provide.

Incidental Uses and Disclosures

We may occasionally inadvertently use or disclose your medical information when such use or disclosure is incident to another use or disclosure permitted by law. For example, while we have safeguards in place to protect against others overhearing conversations that take place between our physicians, nurse practitioners, and other Valparaiso University Student Health Center staff, there may be times when such conversations are overheard by others. Please be assured, however, that we have appropriate safeguards in place to avoid such situations, and others, as much as possible.

Appointment Reminders/Follow-Up Phone Calls

We may use medical information to contact you as a reminder that you have an appointment for treatment or medical care or to inquire as to your progress as the result of treatment or medical care at the Valparaiso University Student Health Center.

Third Parties

We may disclose your medical information to third parties with whom we contract to perform services on our behalf. If we disclose your information to these entities, we will have an agreement with them to safeguard your information.

Disaster Relief Effort

We may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, and location.

Research

Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who receive one medication to those who receive another for the same condition.

All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with the patients’ need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process.

As Required By Law

We will disclose medical information about you when required to do so by federal, state, or local law.

To Avert a 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 or to the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat or to law enforcement authorities in particular circumstances.

Disclosure to You

Upon a written request by you, we may use or disclose your medical information in accordance with your written request.

Limited Data Sets

We may use or disclose certain parts of your medical information, called a “limited data set,” for purposes such as research, public health reasons, or our health care operations. We would disclose a limited data set only to third parties who have provided us with satisfactory assurances that they will use or disclose your medical information only for limited purposes.

Disclosures to the Secretary of Health and Human Services/US Department of Education

We may be required by law to disclose your medical information to the Secretary of the Department of Health and Human Services, his/her designee, or the U.S. Department of Education in the case of a compliance review to determine whether we are complying with privacy laws.

De-Identified Information

We may use your medical information, or disclose it to a third party whom we have hired, to create information that does not identify you in any way. Once we have de-identified your information, it can be used or disclosed in any way according to law.

Disclosure By Members of Our Work Force

Members of our workforce, including employees, volunteers, trainees, or independent contractors, may disclose your medical information to a health oversight agency, public health authority, health care accreditation organization, or attorney hired by the workforce member to report their belief that we have engaged in unlawful conduct or that our care or services could endanger a patient, workers, or the public. In addition, if a workforce member is a crime victim, the member may disclose medical information to a law enforcement official.

Disclosure of Records Containing Drug or Alcohol Abuse Information

Because of federal law, we will not release your medical information if it contains information about drug or alcohol abuse without your written permission, except in very limited situations.

Disclosure of Medical Information of Minors

Under Indiana law, we cannot disclose the medical information of minors to noncustodial parents if a court order or decree is in place that prohibits the noncustodial parent from receiving such information. However, we must have documentation of the court order prior to denying the noncustodial parent such access.

Suspected Abuse or Neglect

If we believe that a person is a victim of child or adult abuse or neglect, we are required by law to report certain information to public authorities.

Disclosure of Mental Health Records

If your records contain information regarding your mental health, we are restricted in the ways we may use and disclose them. We can disclose such records without written permission only in the following situations:

• If the disclosure is made to you (unless it is determined by a physician that the release would be detrimental to your health);
• To our employees in certain circumstances;
• For payment purposes;
• For data collection, research, and monitoring of managed care providers if the disclosure is made to the division of mental health;
• For law enforcement purposes or to avert a serious threat to the health and safety of you or others;
• To a coroner or medical examiner;
• To satisfy reporting requirements;
• To satisfy release of information requirements that are required by law;
• To another provider in an emergency;
• For legitimate business purposes;
• Under a court order;
• To the Secret Service if necessary to protect a person under Secret Service Protection; and
• To the Statewide waiver ombudsman

Special Situations

Organ and Tissue Donation

Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

Military and Veterans

We may disclose the health information of individuals who are members of the Armed Forces as required by appropriate military command authorities. Health Information may be disclosed for purposes of determining an individual’s eligibility for or entitlement benefits under appropriate military laws. We may also disclose the health information of foreign military personnel to the appropriate foreign military authority.

Workers’ Compensation

We may release medical information about you for worker’s compensation or similar programs. These programs provide benefits for work-related injuries or illnesses.

We may disclose medical information about you for public health activities. These activities generally include the following:

• Prevention or control of disease, injury, or disability;
• Reporting births or deaths;
• Reporting child abuse or neglect;
• Reporting reactions to medications or problems with products;
• Notifying people of recalls of products they may be using;
• Notifying a person that they may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;
• Notifying the appropriate government authority if we believe a patient has been the victim of abuse, neglect, or domestic violence. We will only make this disclosure if you agree or when required or authorized by law;
• Notifying your employer if we treat you and such notification is required by law.

Health Oversight Activities

We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes

We may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful processes by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

Law Enforcement

We may disclose health information for law enforcement purposes as required by law:

• In response to a court order, subpoena, warrant, summons, or similar process;
• To identify or locate a suspect, fugitive, material witness, or missing person;
• About the victim of a crime, if under certain limited circumstances we are unable to obtain the person’s agreement;
• About a death we believe may have been the result of criminal conduct;
• About criminal conduct at the Health Center; and
• In emergency situations to report a crime; the location of the crime or victims, or the identity, description, or location of the person who committed the crime.

In most cases, the information will be limited to demographic information.

Coroners, Medical Examiners, and Funeral Directors

We may disclose health information to coroners, medical examiners, and funeral directors consistent with applicable law to carry out their duties.

National Security and Intelligence Activities

We may disclose your health information to authorized federal officials for lawful intelligence, counterintelligence, and other national security activities as authorized by law.

Inmates

Should you be the inmate of a correctional institution, we may disclose to the institution or agents thereof health information necessary for your health and the health and safety of other individuals.

YOUR RIGHTS REGARDING MEDICAL INFORMATION:

Right to Inspect and Copy

You have the right to inspect and copy medical information that may be used to make decisions about your care. Usually, this includes medical and billing records but does not include psychotherapy notes.
To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to Valparaiso University Student Health Center, 55 University Drive, Suite 102, Valparaiso, IN, 46383.

If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request.

Right to Amend

If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by the Health Center.

To request an amendment, your request must be made in writing and submitted to Valparaiso University Student Health Center, 55 University Drive, Suite 102, Valparaiso, IN, 46383.

In addition, you must provide a reason that supports your request.

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 Valparaiso University Student Health Center, unless the person or entity that created the information is no longer available to make the amendment;
• Is not part of the medical information kept by the Health Center;
• Is not part of the information that you would be permitted to inspect and copy; or
• Is accurate and complete.

If we deny your request, you can submit a statement of your position for inclusion in your medical records.

Right to an Accounting of Disclosures

You have the right to request an “accounting of disclosures.” This is a list of the disclosures that we have made of your medical information.

To request this list or accounting of disclosures, you must submit your request in writing to: Valparaiso University Student Health Center, 55 University Drive, Suite 102, Valparaiso, IN, 46383.

Your request must state a time period which may not be longer than six years and may not include dates prior to August 14, 2008.

The first list you request within a 12-month period will be free. For additional lists, we may charge you the costs of providing the list. We will notify you of the cost involved, and you may choose to withdraw or modify your request at that time before any costs are incurred.

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 treatment, payment, or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.

We are not required to agree with your request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment.

To request restrictions, your must make your request in writing to: Valparaiso University Student Health Center, 55 University Drive, Suite 102, Valparaiso, IN, 46383.

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, e.g., disclosures to your parents.

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 may request that we contact you only by cell phone, or only by mail.

To request confidential communications, you must make your request in writing to: Valparaiso University Student Health Center, 55 University Drive, Suite 102, Valparaiso, IN, 46383.

We will not ask 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, or you may obtain a copy via our website.

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 at the Health Center and on the website.

The notice will contain on the first page, at the top of the page, the effective date. In addition, each time you register for care at the Health Center, you may request a copy of the current notice in effect.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with the director of the Health Center, the secretary of the Department of Health and Human Services, or the U.S. Department of Education. All complaints must be submitted in writing. 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. Please note that we are unable to take back any disclosures we have already made with your permission.

If you have questions or would like additional information, you may contact the Health Center director or her designee at 219.464.5060.

If you believe your privacy rights have been violated, you can file a complaint with the Health Center Director (219.464.5352), Privacy Compliance Officer (219.464.6702), or with the Office for Civil Rights, U.S. Department of Health & Human Services, or the Family Policy Compliance Office (202.260.3887). There will be no retaliation for filing a complaint with any of the previously mentioned offices.