Effective: January 24, 2017
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.
This Notice will tell you about the ways in which we may use and disclose medical information about you. It also describes your rights and certain obligations that we have regarding the use and disclosure of your medical information.
Workit Health, Inc. (“Workit Health” or the “Company”) provides you with health care by working with nurses, health coaches, and other health care providers. By law, Workit Health is required by law to maintain the privacy of your health information, give you notice of our privacy practices with respect to your medical information, and follow the terms of this Notice. This Notice applies to all of the records generated and maintained by any health care provider who provides services to you at or on behalf of Workit Health (including our health coaches), our organization, and our employees, contractors, and volunteers, all of whom may need to share your medical information as necessary in order to carry out your treatment, obtain payment for the services provided to you or operate our business.
We are committed to maintain your privacy. If you have any questions about this Notice, please see our contact information on the last page of this Notice.
HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU: The following categories describe different ways that we may use and disclose your medical information. These are examples and, therefore, not every permitted use and disclosure is listed.
- Disclosure at your request. We may disclose information when requested by you. This disclosure at your request may require written authorization by you.
- For Treatment. We may use and disclose medical information about you to a physician or health care provider to provide treatment and other services to you. For example, we may disclose medical information about you to doctors, nurses, health coaches, technicians, or other personnel who are involved in your care or in providing services to you. In addition, we may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.
- Payment. We may use and disclose medical information about you to obtain payment for services that we provide to you. For example, we may need to give your health insurance company/plan information about services you received so your insurer will pay us or reimburse you for the services. We may also tell your insurer about a treatment that you are going to receive in order to obtain prior approval or to determine whether the insurer will cover the treatment. We may also disclose your medical information to other healthcare providers so that they can bill for health care services that they provided to you.
- Health care operations. We may use and disclose your medical information for our health care operations, which include internal administration and planning and various activities that improve the quality and cost effectiveness of the care that we deliver to you. Examples are using information about you to improve quality of care, for disease management programs, patient satisfaction surveys, compiling medical information, de-identifying medical information and benchmarking.
- Business associates. We may disclose medical information about you to our business associates who need that information in order to provide a service to us or on behalf of us. Examples of business associates include accreditation agencies, management consultants, quality assurance reviewers, and billing and collection services. To protect your medical information, we require our business associates to sign a contract or written agreement stating that they will appropriately safeguard your information.
- Appointment reminders. We may use and disclose your medical information to contact you as a reminder that you have an appointment for a consultation or other service.
- Treatment alternatives. We may use and disclose your medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
- Health-related products and services. We may use and disclose your medical information to tell you about our health-related products or services that may be of interest to you.
- Involved With or Concerned About Your Care. We may release information about your condition or treatment to a friend or family member relevant to his/her involvement in your care or payment for your care. We may also disclose your location and condition to assist or notify a family member or personal representative who is involved in your care. We may also disclose your information in a disaster relief effort so that your family can be notified about your condition and location.
- Employers or Potential Employers. If authorized by you and requested by your employer or potential employer, we may disclose medical information about you created or obtained by Workit Health. For example, if a “return to work” test is performed, the results of the test will be released to your employer but only with your prior authorization. Please note that it is the policy of Workit Health to not perform any test, medical examination, or services without first obtaining your written authorization if the sole purpose of the test, medical examination, or services is to create information for disclosure to your employer or potential employer.
- 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 received one medication to those who received another, for the same condition. Research projects 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 patients’ need for privacy of their medical information.
- 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 the health and safety of the public or another person.
- As Required by Law. We will disclose medical information about you when required to do so by federal, state or local law.
- Workers’ Compensation. We may release medical information about you for workers’ compensation or similar programs that provide benefits for work-related injuries or illness.
- Public Health Activities. We may disclose medical information about you for public health activities such as the prevention or control of disease, injury or disability and reporting of reactions to medications or problems with products and to fulfill requirements of the U.S. Food and Drug Administration.
- Health Oversight Activities. We may disclose medical information to a health oversight agency for activities allowed by law such as audits, investigations, inspections and licensure or disciplinary actions.
- Lawsuits and Disputes. We may disclose medical information about you in response to a court order, administrative order or certain subpoenas.
- Law Enforcement. We may release medical information to a law enforcement official about a death we believe may be the result of criminal conduct; and, in emergency circumstances, to report a crime, the location of a crime or victims, or the identity, description or location of the person who committed the crime.
- Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.
- National Security and Intelligence Activities. We may release medical information about you to authorized federal officials for intelligence and other national security activities authorized by law.
- Protective Services for the President and Others. We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
- Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or the law enforcement official.
OTHER USES OF YOUR MEDICAL INFORMATION: Other uses and disclosures of your medical information not covered by this Notice or required by the laws that apply to us will be made only with your written permission (your written permission is referred to as an Authorization). For example, we may disclose your medical information to your employer or potential employer as described earlier in this Notice. If you provide your 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 indicated in your written Authorization. You understand that we are unable to take back any disclosures that we made before we received your written notice revoking your Authorization.
YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU: You have the following rights regarding medical information we maintain about you:
- Right to request additional restrictions. You may request restrictions on our use and disclosure of your medical information (1) for treatment, payment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction, unless the request is regarding a disclosure to a health plan for a payment or health care operation purpose and the medical information relates solely to a health care item or service for which we have been paid out-of-pocket in full. This request must be in writing. We will send you a written response. If we agree with the request, we will comply with your request except to the extent that disclosure has already occurred or if you are in need of emergency treatment and the information is needed to provide the emergency treatment.
- Right to receive 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 can ask that we only contact you at work. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
- Inspection and copies. You may request access to your medical record file and billing records maintained by us. You may inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. If you are denied access to your medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by us will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review. If you request paper copies, we will charge you for the costs of copying, mailing, labor and supplies associated with your request.
- Right to amend your records. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. If you desire to amend your records, your request must be in writing. 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 us, 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 or for us;
- Is not part of the information which you would be permitted to inspect and copy; or,
- Is accurate and complete.
- Right to receive an accounting of disclosures. Upon written request, you may obtain an accounting of certain disclosures of your medical information made by us during any period of time six years prior to the date of your request. Your written request should indicate in what form you want the list (for example, on paper or electronically). If you request an accounting more than once during a twelve (12) month period, we will charge you for the costs involved in fulfilling your additional request. We will inform you of such costs in advance, so that you may modify or withdraw your request to save costs.
- Breach notification. You have a right to be notified following a breach of your unsecured medical information.
PAPER COPY. Upon request, you may obtain a paper copy of this Notice. Even if you have agreed to receive such notice electronically, you are still entitled to a paper copy of this Notice.
CHANGES TO THIS NOTICE. We may change our privacy practices from time to time. 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. If we make an important change, we will change our Notice. We will also post the new Notice on our website at [LINK]. If our Notice has changed, we will offer you a copy of the current Notice the next time you seek treatment or services from us.
COMPLAINTS. If you desire further information about your privacy rights, if you believe your privacy rights have been violated, or disagree with a decision that we made about access to your medical information, you may file a complaint with us, or you may send a written complaint to the U.S. Department of Health and Human Services, Office of Civil Rights. To file a complaint with us, you must submit your written complaint to the attention of our Privacy Officer (see contact information below). You will not be penalized for filing a complaint.
FOR FURTHER INFORMATION. If you would like more information about your privacy rights, please contact Workit Health by calling 734-255-0560 and ask to speak with the Privacy Officer. To the extent you are required to send a written request to Workit Health to exercise any right described in this Notice, you must submit your request to Workit Health at:
303 Detroit Street, Suite 100
Ann Arbor, MI 48104
CONSENT TO USE AND DISCLOSE INFORMATION