Notice of Privacy Practices

We understand that medical information about you and your health is personal. We are committed to protecting medical information about you. We create a record of the care and services you receive at University Health Services. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by University Health Services personnel.

To ensure confidentiality and privacy and strengthen the bonds of trust between providers and patients, we prohibit any type of secretive electronic recording or transmission of the patient visit.

To ensure confidentiality of your medical record and all communications with staff and volunteers, we prohibit the conduct of a University Health Services patient visit using any form of a commercial application of video chat including but not limited to Skype, Facetime, etc. It is a significant HIPAA disclosure risk to use this media and its use is not endorsed by Penn State Risk Management or Penn State privacy policies.

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

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

While you are a student at Penn State, University Health Services is one of your primary health care providers. Each time you visit University Health Services, a record of your visit is made. Typically, this record contains your health history, symptoms, examination and test results, diagnoses, treatment, and a plan for future care of treatment. This information, often referred to as your health or medical record, serves as:

• A basis for planning your care and treatment
• A means of communication among the many health professionals who contribute to your care
• A legal document describing the care you received
• A means by which you or a third-party payer can verify that services billed were actually provided
• A tool for educating health professionals
• A source of data for medical research
• A source of information for public health officials charged with improving the health of the nation
• A source of data for facility planning and marketing
• A tool with which we can assess and continually work to improve the care we render and the outcomes we achieve

• Ensure its accuracy
• Better understand who, what, when, where, and why others may access your health information
• Make more informed decisions when authorizing disclosure to others

We will use your health information for treatment

For example: Information obtained by a nurse, clinician (a physician, nurse practitioner, physician assistant), or other member of your health care team will be recorded in your medical record and used to determine the course of treatment that should work best for you. Your clinician will document in your record his/her expectations of the members of your health care team. Members of your health care team will then record the actions they took and their observations. In that way, the clinician will know how you are responding to treatment. A different department of University Health Services may share health information about you in order to coordinate the different treatments you need, such as prescriptions, lab work, and x-rays. If University Health Services staff refer you to another clinician or hospital, information regarding your visit may be shared with these health care providers. In accordance with Penn State policy AD.22, University Health Services may also share your health information with other Penn State units when disclosure or access is authorized in advance by the PSU HIPAA Privacy Officer.

We will use your health information for payment

For example: a bill may be sent to you or a third-party payer. The information on or accompanying the bill may include information that identifies you as well as your diagnosis, procedures, and supplies used.

We will use your health information for regular health care operations.

For example: Members of the clinical staff, the risk or quality improvement manager, 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 health care and service we provide. We may use health information to review our treatment and services and to evaluate the performance of our staff in caring for you.

Business Associates

There are some services provided in our organization through contracts with business associates. Examples include reference laboratories. When these services are contracted, we may disclose your health information to our business associates so that they can perform the job we have asked them to do. We require these associates to agree that they will protect the privacy of your health information in the same manner that we do. Images and reports of x-ray tests performed at University Health Services, including those ordered by clinicians outside of University Health Services, are shared with the ordering clinician and are scanned into your electronic health record at University Health Services.

Appointment Reminders

We may use and disclose health information to contact you as a reminder that you have an appointment for treatment or medical care at University Health Services.

Treatment Alternatives

We may use and disclose health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

Health-Related Benefits and Services

We may use and disclose health information to tell you about health-related benefits or services that may be of interest to you.

Individuals Involved in Your Care

In life threatening/extreme emergency situations, we may use or disclose health information to notify, or assist in notifying a family member, personal representative, or another person responsible for your care about your location and general condition. We may release health information about you to a friend or family member who is involved in your health care. In addition, we may disclose health information about you to an organization assisting in a disaster relief effort so that your family can be notified about your condition, status, and location. You have the opportunity to agree to, prohibit, or restrict the use or disclosure of health information to these individuals.

Research

Under certain circumstances, we may use and disclose health 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 are subject to a special approval process. This process evaluates a proposed research project and its use of health information, trying to balance the research needs with patients' needs for privacy of their health information. Before we use or disclose health information for research, the project will have been approved through this research approval process.

As Required by Law

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

To Avert a Serious Threat to Health and Safety

We may use and disclose health 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. Any disclosure, however, would only be to someone able to help prevent that threat.

Coroners, Medical Examiners, and Funeral Directors

We may disclose health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or to determine the cause of death. We may also disclose medical information about patients of University Health Services to funeral directors as necessary to carry out their duties.

Public Health Risks

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

• To prevent or control disease, injury, or disability
• To report births and deaths
• To report child abuse or neglect
• To report reactions to medications or problems with products
• To notify people of recalls of products they may be using
• To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
• To notify 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

Health Oversight Activities

We may disclose health 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.

Military and Veterans

If you are a member of the United States armed forces or foreign military personnel, we may disclose health information about you as requested by military command authorities to assure the proper execution of the military mission, if the appropriate military authority has published a notice in the Federal Register with the following information:

1. Appropriate military command authorities or the appropriate foreign military authority
2. Purposes for which the protected health information may be issued or disclosed

Workers' Compensation

We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers' compensation or other similar programs established by law.

Lawsuits and Disputes

In connection with a lawsuit or a dispute, we may disclose health 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 process by someone else involved in the dispute. We may use and disclose health information in defending or asserting a lawsuit involving your treatment at University Health Services.

Law Enforcement

We may disclose health information if asked to do so by a law enforcement official:

• 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 be the result of criminal conduct
• About criminal conduct at University Health Services
• In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description, or location of the person who committed the crime.

National Security and Intelligence Activities

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

Protective Services of the President of the United States and Others

We may disclose health information about you to authorized federal officials so they may provide protection to the President of the United States, 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 disclose health information about you to the correctional institution or law enforcement official. This disclosure would be necessary for the institution to provide you with health care, to protect your health and safety or the health and safety of others, or for the safety and security of the correctional institutions.

We will not sell your health information, or use it for marketing or fundraising purposes without receiving written authorization.

In order to provide the best continuity of care, the local hospital, Mount Nittany Medical Center, may provide information to University Health Services regarding services that you receive there. If you would prefer that this information not be shared with University Health Services, please let Mount Nittany Medical Center staff know at the time of your visit.

You have the following rights regarding health information we maintain about you:

Right to Inspect and Copy

You have the right to inspect and copy health 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 health information that may be used to make decisions about you, you must submit your request in writing to the University Health Services Health Information Management department. 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.

We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to health information, you may request that the denial be reviewed. Another licensed health care professional chosen by University Health Services will review your request and the denial. The person conducting the review will not be the person who denied your request.

Right to Amend

If you feel that health 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 or for University Health Services.

To request an amendment, your request must be made in writing and submitted to the University Health Services Health Information Management department. 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 us, unless the person or entity that created the information is no longer available to make the amendment
• Is not part of the health information kept by or for University Health Services
• Is not part of the information which you would be permitted to inspect and copy
• Is accurate and complete

Right to an Accounting of Disclosures

You have the right to request an accounting of disclosures. This is a list of the disclosures we made of health information about you. This list will not include disclosures we made to you or authorized by you, or disclosures made for the purposes of treatment, payment, or our operations or those authorized by you.

To request this list of accounting of disclosures, you must submit your request in writing to the University Health Services Health Information Management department. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a twelve-month period will be free. For additional lists, we may charge you for the cost 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 health information we use or disclose about you for treatment, payment, or health care operations. We are not required to agree to your request. To request restrictions, you must make your request in writing to the University Health Services Health Information Management department. 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, for example, disclosure to your spouse.

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 can ask that we only contact you at work or by mail.

To request confidential communications, you must make your request in writing to the University Health Services Health Information Management department. 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.

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. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. To obtain a paper copy of this notice you may stop by the University Health Services Information Desk

Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with written permission. If you provide us permission to use or disclose health 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. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

We reserve the right to change the terms of this notice and the changes will apply to all information we have about you. The new notice will be available upon request, at our facility.

If you believe your privacy rights have been violated, you may file a complaint with Penn State or with the Secretary of the Department of Health and Human Services. To file a complaint with Penn State, contact the Penn State Privacy Office,  go to https://security.psu.edu/hipaa/  for instructions on how to print, complete, and submit the Penn State Health Information Privacy Complaint Form.

All complaints must be submitted in writing. You will not be penalized for filing a complaint.

You may also file a complaint directly with the Office for Civil Rights.