NOTICE OF PRIVACY PRACTICES

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.
At The Orthopaedic Surgery Center, we understand that your medical information is personal, and we are committed to protecting your privacy. We have summarized our responsibilities and your rights with respect to your medical record on this page. For a complete description of our privacy practices, please refer to the pages that follow.

Our Responsibilities
We are required to:

• Maintain the privacy and security of your health information
• Provide you with this notice of our legal duties and privacy practices
• Abide by the terms of this notice
• Not use or disclose your information without your authorization, except as described in this notice
• Notify you following a breach of your health information

Your Rights
You have the right to:

• View or obtain a copy of your paper or electronic medical record
• Request a correction to information in your medical record
• Request that we not use or disclose your health information in certain ways
• Request confidential communications
• Receive a list of disclosures we have made of your health information
• Request a paper copy of this notice
• Choose a personal representative to act on your behalf
• File a complaint if you believe that your privacy rights have been violated

Our Uses and Disclosures
We may use and disclose information in your medical record to:

• Treat you
• Run our organization
• Bill for your services
• Help with public health and safety issues
• Do research
• Comply with the law
• Respond to organ and tissue donation requests
• Work with a medical examiner or funeral director
• Address workers’ compensation, law enforcement, or other government requests
• Respond to lawsuits and legal actions

You have the opportunity to prohibit or restrict how we use or disclose your information to:

• Tell family and friends about your condition
• If applicable: Include you in a facility directory
• Provide disaster relief
• Market our services and sell your information

If you have questions and would like additional information, you may contact our Privacy Officer at
330.758.1065.

Understanding Your Health Record/Information
We create a record of your care and services to meet legal requirements and to provide you quality care. This information, often referred to as your health or medical record, serves as a basis for planning your care and treatment, means of communication among health professionals who contribute to your care, and source of information for public oversight and quality assurance purposes. This notice applies to your medical record that we maintain for services or items we provide to you at our center.

Our Responsibilities

• We are required by law to maintain the privacy and security of your health information, to provide you with this notice as to our legal duties and privacy practices, and to abide by the terms of this notice.
• We will not use or disclose your information without your authorization, except as described in this notice. If you authorize a disclosure, you may revoke that authorization at any time, except to the extent that action has already been taken. Requests to revoke an authorization must be made in writing.
• We will notify you in the event a breach occurs that may compromise the privacy or security of your health information.
• We will comply with state law requirements to obtain your consent for certain disclosures of health information about HIV/AIDS, drug or alcohol treatment, or mental health services.

Changes to this Notice
We may change our privacy practices at any time and the changes will apply to current and any new medical information we collect about you. Should our practices change, a revised Notice of Privacy Practices will be posted in our center and on our website at www.theorthosurgerycenter.com. You may request a copy of our Notice of Privacy Practices.

How We Will Use or Disclose Your Health Information
We may use and share your health information in the following ways:

• Treatment: We may use your health information and share it with other health care providers who are treating you. For example, we may provide your health information to a specialist for a referral.
• Payment: We may use and share your health information to bill and obtain payment from health plans or other entities. For example, we may send billing information to your health plan to obtain payment for your care.
• Health care operations: We may use and share your health information for our regular health care operations, including to run our business, to improve the quality of our services, and to contact you. For example, we may use your information in a comparison of patient data to improve treatment standards. We may also disclose your health information for certain health care operations of other entities that have a relationship with you.

We may also share your information in other ways, typically in ways that contribute to the public good, such as public health and research. We may use and share your health information for the following:

• Public health activities: We may share your health information with public health or legal authorities to assist with preventing or controlling disease, injury, or disability; to help with product recalls; to report adverse reactions to medications; to report suspected abuse, neglect, or domestic violence; or to prevent or reduce a serious threat to anyone’s health or safety.
• Research: We may use or disclose your information for health research when certain conditions have been met.
• Transfer of information at death: We may share health information with funeral directors, medical examiners, and coroners to carry out their duties consistent with applicable law.
• Organ donation: We may share health information with organ procurement organizations.
• Workers’ compensation: We may use and share your information for workers’ compensation claims (eligibility for claims due to work-related injury).
• Government requests: We may disclose your health information to appropriate health oversight agencies for oversight activities that are authorized by law. We may also disclose health information for law enforcement purposes or with a law enforcement official. We may also disclose your health information for certain specialized government functions, including military, veterans, and presidential protection services.
• Compliance with law: We may share your information as required by state, federal, or local laws.
• Legal proceedings: We may share your health information in response to a court or administrative order or in response to a subpoena.
• Business associates: We sometimes contract with outside entities, such as accountants, lawyers, and consultants. We may share your health information with these business associates relating to the services that they provide to us, but we require them to abide by this notice, and they are directly responsible for compliance with applicable state and federal privacy laws and regulations.

Your Choices
In some instances, you have the opportunity to prohibit or ask that we restrict the use of your information. If you have a preference for how we share your information in the following situations, please let us know. Note that if you are unable to tell us your preference, we may disclose your information if we believe it is in your best interest or to avert a threat to health or safety:

• Directory: Unless you notify us that you object, we may use your name, location in the center, general condition, and religious affiliation for directory purposes, provide this information to clergy and people who ask for you by name, and mark your name on a nameplate next to your door.
• Family: We may share with your family member, friend, or other person involved in your care health information relevant to that person’s involvement in your care or payment for your care, including notifying them of your location and general condition. If appropriate, these communications may also be made after your death.
• Disaster relief: We may use or disclose your information to assist in a disaster relief situation.

Authorizations and Other Uses of Health Information
In other instances, we will not share your information unless you give us written permission. Specifically, we will not sell your health information, use your health information for marketing purposes, or use or disclose your psychotherapy notes, with some limited exceptions, without your written authorization.

Your Health Information Rights
You have certain rights with respect to your health information:

• Access to medical record: You may request to view or obtain a paper or electronic copy of your medical record, which will be provided to you in the time frames established by law, when you. In order to better respond to your request, we require that you make such requests in writing on our standard form. We may charge you a reasonable, cost-based fee for paper or electronic copies.
• Correct medical record: If you believe that any health information in your record is incorrect or incomplete, you may request that we correct the existing information or add the missing information by submitting a written request that provides your reason for requesting the change. If we deny your request, we will tell you why it was denied.
• Confidential communications: You may request that we contact you in an alternative manner (for example, home or office phone) or to send mail to an alternate address. Your request must be made in writing and submitted to ____________. We will attempt to accommodate all reasonable requests.
• Limit use or disclosure: You may request that we not use or disclose your health information for a particular reason related to treatment, payment, or our operations. We ask that such requests be made in writing on our standard form. We will consider your request, but we are not required to abide by it, unless it is a request to prohibit disclosures to your health care plan relating to a service for which you have already paid in full out of pocket.
• Obtain accounting: You may request a list of all disclosures of your information we have made during a specific time period (not to exceed 6 years). Please note that the accounting will not include treatment, payment, health care operations, or certain other disclosures. You will not be charged for your first accounting request in any 12-month period, but for any requests that you make thereafter, you will be charged a reasonable, cost-based fee.
• Copy of notice: You may request a paper copy of this Notice of Privacy Practices at any time. You may also access and print a copy of our notice from our website at www.theorthosurgerycenter.com.
• File a complaint: If you believe your privacy rights have been violated or disagree with a decision we have made about your access, you may file a complaint by calling our Privacy Officer at (330-758-1065 x223) or by submitting a written complaint to the Privacy Officer at tcera@theorthosurgerycenter.com. You can file a complaint with the Ohio Department of Health at 1-800-342-0553. You may also file a complaint with the Secretary of the Department of Health and Human Services. There will be no penalty or retaliation for filing a complaint.

Effective: January 1, 2018