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Privacy Policy

OUR RESPONSIBILITY TO YOU
Circle Home, Inc. ("Circle Home" or "we") is committed to respecting your privacy and confidentiality. We are required by law to protect the privacy of your health information and provide you with this Notice of Privacy Practices ("Notice") which outlines our legal duties and privacy practices regarding your protected health information ("PHI").

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. Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy. The Notice will be provided to you when the first home visit occurs. You may also obtain the most current version of this Notice on our website at www.circlehomehealth.org. We reserve the right to change this Notice. The revised or changed Notice will be effective for information we already have about you as well as any information we receive in the future. Each time you are referred to CIRCLE HOME for services, we will offer you a copy of the current Notice in effect.

WHAT IS PHI?
PHI is any information about your past, present or future health care, or payment for this care.

HOW WE MAY USE AND DISCLOSE YOUR PHI
We use and disclose PHI for many different reasons. For some of these uses or disclosures, we need your written authorization. Below we describe the different categories of our uses and disclosures and give you some examples of each category. Except when disclosing PHI relating to your treatment, payment or health care operations, we must use or disclose only the minimum necessary PHI to accomplish the purpose of the use or disclosure.

HOW CIRCLE HOME MAY USE OR DISCLOSE YOUR HEALTH INFORMATION
A. Uses and Disclosures that may be made for treatment, payment and operations
Except where prohibited by state or federal law, CIRCLE HOME may legally use and share your PHI for treatment, payment and health care operations. We do not need to obtain your written authorization to take such actions, as explained below.

For treatment: CIRCLE HOME may use or disclose your PHI to manage, coordinate and provide your health care treatment and/or services. For example, your CIRCLE HOME health care provider, such as a nurse, physical therapist, occupational therapist, or other person providing health services to you, may obtain, for the purpose of planning your care and treatment, your medical history and other records from the health care agency that referred you to CIRCLE HOME. CIRCLE HOME may also disclose your PHI to other non-CIRCLE HOME health care providers, including but not limited to your primary care physician or a laboratory.

For payment: CIRCLE HOME may use or disclose your PHI to others for purposes of receiving payment for treatment and services that you receive. For example, a bill that contains PHI may be sent to a third party payer, such as an insurance company or health plan.

Health care Operations: CIRCLE HOME may use and disclose your PHI for operational purposes. For example, your PHI may be disclosed to members of our staff for purposes of evaluating the performance of our staff, assessing the quality of care and outcomes in your case and similar cases, learning how to improve our services, and determining how to continually improve the quality and effectiveness of the health care services we provide.

Business Associates: We contract with third parties, or "business associates," to help us provide our services. An example would include a vendor that mails patient satisfaction surveys or stores our hardcopy medical records. We may disclose your health information to our business associates so that they can perform the job we have asked them to do. To protect your PHI, we require our business associates to appropriately safeguard your PHI. We require any subcontractors that work for our business associates to also take steps to safeguard your information.

Health-Related Services or Benefits: CIRCLE HOME may use or disclose your PHI to provide you with appointment notification or reminders. We may also use your PHI for purposes of providing you with information about other kinds of treatment or other health-related benefits and services that may be of interest to you.

Fundraising: Members of our community relations and development staff may contact you or your caregivers/emergency contacts for fundraising purposes. The money raised is used to support our programs and operations. If you do not want CIRCLE HOME to contact you or your caregivers/emergency contacts for fundraising efforts, you have the right to opt out of receiving such communications. Your decision not to be contacted for fundraising purposes will not change your ability to receive services from CIRCLE HOME.

B. Uses and Disclosures That May be Made Without Your Authorization or Opportunity to Object
CIRCLE HOME may also legally use and disclose your PHI to others for certain purposes that are not treatment, payment or health care operations, without your written authorization. Such examples include but are not limited to: when disclosures are required by law (e.g., law enforcement, mandated reporting of abuse and neglect, etc.); for public health activities; to funeral directors or coroners related to decedents; for the Circle Home bereavement program; for organ/tissue donation; to correctional institutions; for research purposes; for health and safety; for specific government functions; and for workers compensation.

C. Other Uses and Disclosures That You May Ask to Limit, or Request Not To Be Made
Individuals involved in your care or payment for your care: Unless you object, CIRCLE HOME may disclose your PHI to a friend, family member or other person who you identify is involved in your care or payment of your care. In addition, we may disclose your PHI to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location. In this case we will determine whether the disclosure is in your best interest and, if so, only disclose information that is directly relevant to participation in your care.

D. Uses or disclosures that require your written authorization
All other uses and disclosures of your PHI not otherwise or previously covered by this Notice, will require your written authorization, unless otherwise required by law. Examples of uses and disclosures that require your authorization include, but are not limited to, most uses and disclosures of psychotherapy notes, drug and alcohol abuse treatment records, and marketing purposes if the organization receives financial remunerations.

Further, CIRCLE HOME is prohibited from selling your PHI without your expressed written authorization. If you provide us with authorization to disclose such PHI, you can later revoke it in writing to prevent any future uses and disclosures of the PHI, except to the extent that CIRCLE HOME has already acted upon your previously provided consent.

YOUR HEALTH INFORMATION RIGHTS
You have the following rights with respect to your PHI:

Inspect and Copy: You have the right to inspect and copy your PHI, subject to state and federal laws. Usually, this includes medical and billing records, but does not include psychotherapy notes. We may deny your request to inspect and copy in very limited circumstances. If you are denied access to PHI, you may request that the denial be reviewed. Another licensed health care professional, chosen by CIRCLE HOME, 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. To inspect and copy PHI that may be used to make decisions about you, you must submit your request, in writing, to the Privacy Officer at the address below. If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other expenses associated with your request.

Amend: If you feel that PHI we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment during the time that the information is kept by Circle Home. To request an amendment, your request must be made in writing to the Privacy Officer and must include a reason that supports your request. (CIRCLE HOME can also provide you with a form to complete.) We may deny your request for an amendment if it is not in writing and does not include a reason to support the request. We may also deny your request for other reasons, including if the information: is accurate and complete; is not part of the PHI kept by or for CIRCLE HOME; was not created by CIRCLE HOME, unless the person or organization that created the information is no longer available to make the amendment; or is not part of the information you would be permitted to inspect and copy.

Request an Accounting of Disclosures: You have the right to request a list of the disclosures we made of your PHI. To request this list or “accounting of disclosures” you must submit your request in writing to the Privacy Officer. Your request must state a time period. You may request an accounting as far back as six years, except requests for electronic disclosures relating to treatment, payment or operations which are limited to three years. The accounting will not include (i) non-electronic disclosures relating to treatment, payment or operations; (ii) disclosures if you gave your written authorization to share the information; (iii) disclosures shared with individuals involved in your care; (iv) disclosure to you about your health condition; or (v) disclosures made for national security or intelligence purposes or to correctional institutions or law enforcement officials who have custody of you. Your request should indicate the form in which you want the list (for example, on paper, electronically). The first accounting provided in any 12-month period is 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.

Request Restrictions: You have the right to request a restriction or limitation on your PHI that we use or disclose for treatment, payment, or health care operations. You also have the right to request a limit on the PHI we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had. We are not required to agree to your request. If we do agree, we will comply with your request, to the extent authorized by law, unless the restricted PHI is needed to provide you emergency treatment. To request restrictions, you must make your request in writing to the Privacy Officer. Your request must include what information you want to limit; whether you want to limit our use, disclosure, or both; and what information is affected by the limits you select (for example, disclosures to your spouse).

Right to Restrict Disclosure: You have the right to restrict certain disclosures of PHI to a health plan if you pay out of pocket in full for the health care service.

Request Confidential Communications: You have the right to request that we communicate with you about your treatment in a certain manner or at a certain location. We will agree to the request to the extent that it is reasonable for us to do so. For example, you can ask that we use an alternate address for billing purposes. To request an alternate address or phone number for billing purposes, you must contact CIRCLE HOME billing department. Requests for restrictions, other than billing matters, should be sent in writing to the Privacy Officer.

Other Uses of PHI: Uses and disclosures of PHI not covered by this Notice will be made only with your written permission, unless otherwise required by law. If you provide us permission to use or disclose your PHI, you may revoke your authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose your PHI for the reasons covered by your written authorization, unless we have already acted upon your previously provided consent.

Notice of Breach: Individuals whose unsecured PHI has been breached will be notified in writing as required by law.

To File a Complaint: If you think your privacy rights have been violated, or you disagree with a decision we made about access to your PHI, you may file a complaint with our Privacy Officer as listed below. You will not be penalized for filing a complaint.

Circle Home, Inc.
Privacy Officer
847 Rogers Street, Suite 201
Lowell, MA 01852
Phone: 978-459-9343

You may also file a written complaint with the Secretary of the United States Department of Health & Human Services as follows:

Office of Civil Rights
U.S. Department of Health & Human Services
Government Center
JFK Federal Building, Room 1875
Boston, MA 02203
Phone: 617-565-1340

Effective: April 14, 2003
Updated: July 30, 2012, July 1, 2013, May 1, 2014, June 18, 2015