WILDWOOD PROGRAMS

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.

This notice has been in effect since April 14, 2003.  If you have any questions about this notice, please contact Wildwood’s Privacy Officer at (518) 640-3321.

OUR PRIVACY COMMITMENT TO YOU:

    At Wildwood Programs, we understand that information about you and your family is personal.  We are committed to protecting your privacy and sharing information only with those who need to know and are allowed to see the information to assure quality services for you.  This notice tells you how Wildwood Programs uses and discloses information about you.  It describes your rights and what our responsibilities are concerning information about you.
    Wildwood Programs is required by law to maintain the privacy of protected health information, to provide individuals with notice of its legal duties and privacy practices with respect to protected health information, and to notify affected individuals following a breach of unsecured protected health information.
    All people who work for Wildwood Programs (including volunteers, interns, and contractors) will follow this notice. 
    All information we create or keep that relates to your health or care and treatment, including information that can be used to identify you (such as name, address, birth date, social security number, medical information, service plans, etc.) will be considered protected health information.

YOUR HEALTH INFORMATION RIGHTS:

    You have the following rights concerning your health information. When we use the word “you” in this notice we also mean your personal representative.  Depending on your circumstances, and in accordance with state law, this may be your guardian, involved parent, spouse, or adult child, or your advocate.
•    You have a right to see or inspect your health information and obtain a copy. Some exceptions apply, such as psychotherapy notes, records regarding incident reports and investigations, and information compiled for use in court or administrative proceedings.
•    If we deny your request to see your health information, you have the right to request a review of that denial.  A professional chosen by Wildwood Programs who was not involved in denying your request will review the record and decide if you may have access to the record.
•    You have the right to ask Wildwood Programs to change or amend your health information that you believe is incorrect or incomplete.  We may deny your request in some cases, for example if Wildwood Programs did not create the record or if after reviewing your request, we believe the record is accurate and complete.
•    You have the right to request a list of the disclosures Wildwood Programs has made of your health information.  We will not, however, keep or provide you with a list of certain disclosures, for example, disclosures made for treatment, payment and health care operations, or disclosures made to you or made to others with your permission.
•    You have the right to request a restriction on uses and disclosures of your health information.  However, Wildwood Programs is not required to agree to your request, if, in their professional judgment, the restriction could negatively impact treatment, payment or health care operations, or in the event of an emergency.
•    You have the right to request that Wildwood Programs communicate with you in a way that will help keep your information confidential.
•    You have the right to receive a paper copy of this notice.  You may ask Wildwood Programs staff to give you another copy, or you may obtain one from our website at www.wildwoodprograms.org
•    To request access to your health information or to request any of the rights listed here, you may contact any of your Wildwood Programs staff or Wildwood’s Privacy Officer at (518) 640-3321.

WILDWOOD PROGRAMS’ RESPONSIBILITIES FOR YOUR HEALTH INFORMATION:

Wildwood Programs is required by law to:
•    Maintain the privacy of your information
•    Give you this notice of our legal duties and practices concerning the health information we have about you
•    Follow the rules in this notice.  Wildwood Programs will use or share information about you only with your permission except for the reasons explained in this notice. We will tell you if we make changes to our privacy practices in the future.  If significant changes are made, Wildwood Programs will give you a new notice and will post a new notice on our website at www.wildwoodprograms.org.

HOW WILDWOOD PROGRAMS USES AND DISCLOSES HEALTH CARE INFORMATION:

Within Wildwood Programs, we may use and disclose health information without your permission for the purposes described below.  If sharing information outside of Wildwood Programs, we will obtain your consent to share confidential information.  For each of the categories of uses and disclosures, we explain what we mean and offer an example.  Not every use or disclosure is described, but all of the ways we will use or disclose information will fall within these categories:
•    Treatment:  Wildwood Programs will use your health information to provide you with treatment and services.  We may disclose health information to residential, employment, school, service coordination, day services, residential habilitation, recreation, and other Wildwood Programs personnel, volunteers or interns who are involved in providing you care.  For example, involved staff may discuss your health information to develop and carry our your Individualized Service Plan (ISP).  Other Wildwood Programs staff may share your health information to coordinate different services you need, such as medical tests, respite care, transportation, etc.  We may also need to disclose your health information to your service coordinator and other providers outside of Wildwood Programs who are responsible for providing you with the services identified in your ISP or to obtain new services for you.
Wildwood Programs may use and disclose health information to contact you as a reminder that you have an appointment for treatment or services at one of our programs.
•    Payment:  Wildwood Programs will use your health information so that we can bill and collect payment from you, a third party, an insurance company, Medicare or Medicaid or other governmental agencies.  For example, we may need to provide the New York State Department of Health (Medicaid) with information about the services you received through one of our programs so they will pay us for the services.  In addition, we may disclose your health information to receive prior approval for payment for services you may need.  Also, we may disclose your health information to the US Social Security Administration, or the Department of Health, or to the Office for People With Developmental Disabilities to determine your eligibility for services, coverage or your ability to pay for services.
•    Health Care Operations:  Wildwood Programs will use health information for administrative operations.  These uses and disclosures are necessary to operate our programs and services and to make sure all consumers receive appropriate, quality care.  For example, we may use health information for quality improvement to review our treatment and services and to evaluate the performance of our staff in caring for you.  We may also disclose health information to clinicians and other personnel for on-the-job training.  We will share your health information with other Wildwood Programs staff, for the purposes of obtaining legal services and conducting fiscal audits.  We will also share your health information with Wildwood Programs staff to resolve complaints or objections to your services. We may also disclose health information to our business associates who need access to the information to perform administrative or professional services on our behalf.

OTHER USES AND DISCLOSURES THAT DO NOT REQUIRE YOUR PERMISSION:

    In addition to treatment, payment and health care operations, Wildwood Programs will use your health information without your permission for the following reasons:
•    When we are required to do so by federal or state law;
•    For public health purposes, including prevention and control of diseases, injury or disability, reporting births and deaths, reporting child abuse or neglect, reporting reactions to medication or problems with products, and to notify people who may have been exposed to a disease or are at risk of spreading the disease;
•    To report domestic violence and adult abuse or neglect to government authorities if you agree or if necessary to prevent serious harm;
•    For health oversight activities, including audits, investigations, surveys and inspections, and licensure. These activities are necessary for government to monitor the health care system, government programs, and compliance with civil rights laws.  Health oversight activities do not include investigations that are not related to the receipt of health care or receipt of government benefits in which you are the subject;
•    For judicial and administrative proceedings, including hearings and disputes. If you are involved in a court or administrative proceeding we will disclose health information if the judge or presiding officer orders us to share the information;
•    For law enforcement purposes, in response to a subpoena, or other legal process, to identify a suspect or witness or missing person, regarding a victim of a crime, a death, criminal conduct at the facility, and in emergency circumstances to report a crime;
•    Upon your death, to coroners or medical examiners for identification purposes or to determine cause of death, and to funeral directors to allow them to carry out their duties;
•    To organ procurement organizations to accomplish cadaver, eye, tissue or organ donations in compliance with state law;
•    For research purposes when you have agreed to participate in the research an Institutional Review Board or Privacy Committee has approved the use of the health information for the research purposes;
•    To prevent or lessen a serious and imminent threat to your health and safety or someone else’s;
•    To authorized federal officials for intelligence and other national security activities authorized by law or to provide protective services to the President and other officials;
•    To correctional institutions or law enforcement officials if you are an inmate and the information is necessary to provide you with health care, protect your health and safety or that of others, or for the safety of the correctional institution;
•    To governmental agencies that administer public benefits if necessary to coordinate the covered functions of the programs;
•    To the Wildwood Foundation, for the purposes of fundraising.  Such information can only include dates of treatment, demographic information, department of service, treating staff, outcome information, and health insurance status.  You may opt out of receiving future fundraising notifications.

USES AND DISCLOSURES THAT REQUIRE YOUR AGREEMENT OR AUTHORIZATION:

    Wildwood Programs may disclose health information to the following persons if we tell you we are going to use or disclose it and you agree or do not object:
•    To family members and personal representatives who are involved in your care if the information is relevant to their involvement and to notify them of your condition and location; or
•    To disaster relief organizations that need to notify your family about your condition and location should a disaster occur.

AUTHORIZATIONS REQUIRED FOR ALL OTHER USES AND DISCLOSURES:

    For all other types of uses and disclosures not described in this Notice, Wildwood Programs will use or disclose health information only with a written authorization signed by you or your personal representative that states who may receive the information, what information is to be shared, the purpose of the use or disclosure and an expiration for the authorization.  Written authorizations are always required for use and disclosure of psychotherapy notes and for marketing purposes. NOTE:  if you cannot give permission due to an emergency, Wildwood Programs may release health information in your best interest.  We must tell you as soon as possible after releasing the information.
    You may revoke your authorization at any time.  If you revoke your authorization in writing we will no longer use or disclose your health information for the reasons stated in your authorization.  We cannot, however, take back disclosures we made before you revoked and we must retain health information that indicates the services we have provided to you.

CHANGES TO THIS NOTICE:

    We reserve the right to change this notice.  We reserve the right to make changes to terms described in this notice and to make the new notice terms effective to all health information that Wildwood Programs maintains.  We will post the new notice with the effective date on our website at www.wildwoodprograms.org and in our facilities. 

COMPLAINTS:

    If you believe your privacy rights have been violated:
•    You may file a complaint with the Wildwood Programs Privacy Officer, 1190 Troy-Schenectady Rd., Building 1, Latham, NY 12110, (518) 640-3321. 
•    You may contact the Secretary of the Department of Health and Human Services.  You may call them at (877) 696-6775 or write to them at 200 Independence Ave. S.W., Washington, DC 20201.

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