Boston Health Care for the Homeless Program (BHCHP)/McInnis Health Group (MHG) keeps a record of the health care services provided to each patient. We are required by law to keep this health information private. We are also required to notify patients of our legal duties and privacy practices used to keep your health information private. BHCHP/MHG is required to obey the Notice of Privacy Practices currently in effect.
A. USE AND DISCLOSURE OF HEALTH INFORMATION WITHOUT AUTHORIZATION
1. Treatment: Your primary care doctors, consultant* doctors, nurse practitioners, physicians assistants, nurses, technicians, students of the health care professions, and mental health clinicians involved in taking care of you at BHCHP/MHG may use your health information to provide you with treatment or services. For example, a doctor treating you for an injury needs to know if you have diabetes because diabetes may slow the healing process. Different departments may share your medical information to coordinate your care, for example, your primary care clinician can inform your physical therapist if you have diabetes to enable the physical therapist to plan an appropriate program for you. * A consultant, for example, is a doctor outside of McInnis Health Group who we ask to see you to get another opinion or further treatment.
2. Payment: BHCHP/MHG may use your protected health information to bill for our services and to collect for our services. For instance, your insurance company or third party payor may request to see copies of your record to verify services which you received or when BHCHP/MHG is seeking to obtain prior approval for your treatment.
3. Health care operations: Health Care Operations are the functions that all health care facilities and agencies perform to verify that the delivery of care to patients is being properly performed and that the facility or agency is functioning properly. For example, reviews of patient charts are conducted to evaluate staff performance or may be conducted by the medical records department or the Medical Records Committee to verify that all records are completed according to legal requirements.
4. In medical emergencies: If you are in a situation which causes or may cause immediate jeopardy to your health or life and which requires immediate intervention, BHCHP may use or disclose your medical information without your consent.
5. As required by law or legal authorities: In accordance with applicable law, BHCHP/MHG is either permitted or required to disclose your health information to the following types of entities and for the following reasons, including but not limited to:
6. Appointment reminders: We may share your protected health information to contact you as a reminder that you have an appointment.
7. Treatment alternatives: We may share your protected health information to tell you about or recommend possible treatment alternatives.
8. Benefits and services: We may share your protected health information to tell you about health related benefits or services that may be of interest to you.
B. USES OR DISCLOSURES THAT MAY BE LIMITED OR YOU MAY REQUEST NOT BE MADE
1. Individuals involved in your care or payment for your care: We may exercise our professional judgment to share your health information, including your condition and the fact that you are being treated, with friends or family members who are involved in your care if you are over 18 years of age, unable to communicate, or in an emergency situation. In addition, we may need to disclose health information to notify a family member or any other person responsible for your care of your location, general condition or death. We may also disclose your health information to obtain payment for your care.
2. Disaster relief purposes: Including:
C. USE OR DISCLOSURES THAT REQUIRE WRITTEN AUTHORIZATION
Other uses or disclosures of your record will be made only with your written authorization. Disclosures requiring written authorization include drug and alcohol treatment records, mental health records, and AIDS/HIV and genetic testing information, sexual abuse history, sexually transmitted diseases, and domestic violence history. If you provide written authorization for us to share your health information, you may revoke that authorization, in writing, at any time. Once revoked, we will no longer share your health information for the purpose(s) covered in the written authorization; however, we are unable to take back any information we have already shared prior to the time your authorization was revoked. We are required to retain records of the care that we provided to you.
D. YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION
1. Right to inspect and copy: You have the right to inspect and copy health and billing information that may be used to make decisions about your care. This does not include psychotherapy notes, clinical laboratory data or information compiled in anticipation of or for use in a civil, criminal or administrative action or proceeding.
To inspect and copy your medical information, you must complete an Authorization for the Release and/or Discussion of Medical Records and submit it to the BHCHP/MHG Privacy Officer. If you request a copy of the information, we may charge a fee for the costs of copying, mailing, and supplies used.
BHCHP/MHG may deny your request to inspect and copy your record in certain, very limited, circumstances. If BHCHP/MHG denies your request, you may request that we release copies of your record for inspection to you through another physician of your choice or you may request that we release copies of your medical record to you through your attorney. Another licensed health care professional chosen by our organization will review your request and the denial. The person conducting the review will not be the person who denied your request.
To request information about the steps you must take to inspect and copy health information that may be used to make decisions about your care, contact the Privacy Officer.
2. Right to request an amendment: If you feel that health information we have about you is inaccurate or incomplete, you have the right to request an amendment to your record. You have the right to request an amendment for as long as the information is kept by (or for) BHCHP/MHG.
BHCHP/MHG has the right to deny your request for amendment of your medical records if it is not in writing or if it does not include a reason to support your request. BHCHP/MHG may also deny your request if you ask us to amend the following types of information:
To request information about the steps to be taken if you wish us to amend your record or if you wish to submit an amendment, you must submit your request in writing to the Privacy Officer.
3. Right to an accounting of disclosures (shared information): You have the right to request an accounting of disclosures, which is a list of the health information about you which we have shared.
To request a list of accounting of disclosures (shared information), submit your request in writing to the Privacy Officer. Requests for an accounting of disclosures may not be for a period of longer than six years and requests may not include requests for information released (shared) before February 26, 2003. Your request should indicate if you prefer to receive the list on paper or electronically. The first list you request within a 12-month period will be free. For additional lists, we may charge you. We will notify you of the cost involved and you may choose to withdraw or modify your request before any costs are incurred.
4. Right to request restrictions: You have the right to request a restriction or limitation on the health information we share about you for treatment, payment, or health care operations. The right to request restrictions does not apply to uses and disclosures required by law. You do have the right to request a limit on the health information we share about you to someone who is involved in your care or payment for your care, like a family member or friend. For example, you could ask that we not share information about a surgery you had.
To request restrictions, contact the Privacy Officer. In your request you must tell us 1.) what information you want to limit and 2.) to whom you want the limits to apply, for example, sharing information with a spouse. We are not required to agree to your request. If we do agree, we will comply with your request. We may use or disclose restricted information for emergency treatment.
5. Right to request confidential communications: You have the right to request that we communicate with you about health information in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail.
To request confidential communications, contact the Privacy Officer. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
6. Right to a paper copy of this notice: You have the right to obtain a paper copy of this Notice. You may obtain a copy of this Notice at our website (www.bhchp.org) or by other electronic means (e-mail). Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy of this Notice.
You may obtain a paper copy of this Notice on admission, on your first visit after the effective date, or you may contact the Privacy Officer for a copy of this Notice at any time.
7. Right to complain: If you feel that your privacy rights have been violated, you may file a complaint with BHCHP/MHG by notifying the Director of Clinical Operations (for clinic) or the Director of Respite (for Respite) by filing a Grievance in accordance with the BHCHP/MHG Grievance Procedure. If the complaint/grievance is about a violation of privacy, it will be forwarded to the Privacy Officer.
You may also file a complaint with the Secretary of the Department of Health and Human Services.
You will not be penalized for filing a complaint. BHCHP/MHG will not retaliate against you for filing a compliant.
E. BHCHP’S RESPONSIBILITY TO RETAIN MEDICAL RECORDS
Effective July 10, 2009, BHCHP/MHG will maintain medical records for a period of no longer than 20 years from a patient’s last date of service.
Patient access to medical records will not change with this change in the law. Patients will continue to have the right to inspect his/her medical records upon request at any time during the 20 year period for which we are required to maintain medical records.
When records are 20 years old or older, BHCHP/MHG is required to notify the Department of Public Health, 30 days prior to the intended date of destruction, of our intention to destroy the records. Destruction of records which are 20 years old or older is done by a vendor who has signed an agreement to transport and destroy the records in a manner which protects confidentiality at all times.
You may obtain a full copy of the Boston Health Care for the Homeless Program’s Records Retention and Destruction Policy by contacting the Privacy Officer at 857-654-1078.
G. CONTACT INFORMATION
If you have any questions about this Notice, please contact:
Boston Health Care for the Homeless Program
780 Massachusetts Avenue
Boston Massachusetts 02118
PROGRAMS/LOCATIONS OF CARE AND COLLABORATIONS
BOSTON HEALTH CARE FOR THE HOMELESS PROGRAM (BHCHP)/MCINNIS HEALTH GROUP (MHG)
A partial list of BHCHP programs/locations of care and collaborations includes the following:
1. 780 Albany Street (Admin. Offices)
2. Anchor Inn
3. Asian Task Force Against Domestic
4. Barbara McInnis House
5. Beacon Townhouse Inn #2
6. Beth Israel Hospital
7. Boston Medical Center
8. Boston Family Shelter
9. Boston Living Center
10. Brigham & Women’s Hospital
11. Brookview House
12. Cambridge Health Alliance/Cambridge Health Care for the Homeless
13. Cardinal Medeiros Center
14. Carolina Hills Shelter
15. Casa Esperanza Men’s Program
16. Casa Nueva Vida
17. Church of Advent
18. Crittenton Women’s Union
20. Day care and school outreach, including: Horizons for Homeless Children, Above and Beyond, and others
22. Entre Familia
23. Families in Transition
24. Father Bill’s Place
25. Finex House
26. Friends of the Homeless of the South
27. Hildebrand Family Shelter I, Dorchester
28. Hildebrand Family Shelter II, Dorchester
29. hopefound, including Stay-In Beds and Transitional Living Program
30. Housing Families, Inc.
31. Jean Yawkey Place Clinic (formerly BMC Homeless Primary Care)
32. Kingston House
33. Kitty Dukakis Women’s Treatment Center
34. Latinas Y Ninas
35. Lindemann Mental Health Center
36. Long Island Shelter
37. Margaret’s House
38. Massachusetts General Hospital
39. Massachusetts Mental Health Center
40. Millenium House #1
41. Millenium House #2
42. Nazareth Residence
43. Temporary Home for Women and Children (“New Chardon Street Shelter”)
44. New England Center for Homeless
45. North Beacon Inn
46. Pilgrim Shelter
47. Pine Street Inn Men’s Clinic
48. Pine Street Inn Women’s Clinic
49. Project Hope
50. Queen of Peace Shelter
51. Renewal House
52. Revision House
53. Rosie’s Place
54. Safe Harbor
56. Sojourner House
57. South End Community Health Center
58. St. Ambrose
59. St. Francis House
60. St. Mary’s Center for Women and Children, including Bridge Home, Margaret’s House.
61. St. Patrick Women’s Shelter
62. Tufts Medical Center
63. Transition House/Cambridge
64. Outreach, including:
-Scattered site apartments
-Motels (temporary placements)
-Van (Pine Street Inn, Needle Exchange)
-Boston Public Schools
65. Suffolk Downs (Eighth Pole)
67. Women’s Lunch Place
68. Woods Mullen Shelter
BHCHP/MHG works in close collaboration with health care clinics at area shelters, hospitals and other facilities, and agencies. Collaborative planning of health care occurs in an organized manner and some health information is entered into a shared record. BHCHP/MHG Is a Community Health Center member of Boston Health Net and may share information with Boston Medical Center or the other Community Health Center members of Boston Health Net for the purposes of treatment, payment, and health care operations. The Boston Health Net Collaboration includes:
Boston Medical Center
Boston Health Care for the Homeless Program
Codman Square Health Center
Dorchester House Multi-Service Center
East Boston Neighborhood Health Center
Geiger-Gibson Community Health
Greater Roslindale Medical and Dental Center
Harvard Street Neighborhood Health Center
Manet Community Health Center
Mattapan Community Health Center
Neponset Health Center
Roxbury Comprehensive Community Health Center
South Boston Community Health Center
South End Community Health Center
Upham’s Corner Health Center
Whittier Street Neighborhood Health Center