Comfort Keepers®
NOTICE OF PRIVACY PRACTICES

​OUR COMMITMENT AND LEGAL DUTY TO YOUR PRIVACY

We are dedicated to maintaining the privacy of your individually identifiable Protected Health Information (PHI). We are required by applicable federal and state law to protect your privacy and to give this Notice about our privacy practices, our legal duties, and your rights concerning your PHI. We must follow the privacy practices that are described in the Notice while it is in effect. We reserve the right to change our privacy practices and the terms of this Notice at any time, provided such changes are permitted by applicable law. We reserve the right to make the changes in our privacy practices and the new terms of our Notice effective for all PHI that we maintain, including PHI we created or received before we make the changes. Before we make a significant change in our privacy practices, we will change this Notice and make the new Notice available upon written request. You may request a copy of our Notice at any time. For more information about our privacy practices, or for additional copies of this Notice, please contact us using the information listed at the end of this Notice.

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USES AND DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION (PHI)

The following categories describe the different ways we use and disclose your PHI in connection with our healthcare operations:

 

Treatment: We may use or disclose your PHI for treatment purposes, including for the activities of a physician or other healthcare provider providing treatment to you. For example, your PHI may be provided to a physician who is treating you to assist with referral or diagnosis.

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Payment: We may use and disclose your PHI to obtain payment for services we provide to you, including determinations of eligibility and coverage and other utilization review activities. For example, obtaining approval for third party payor, Medicare, or passport waivers may require that your PHI be disclosed in order to obtain approval for our services.

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Healthcare Operations: We may use and disclose your PHI in connection with operating our business. These operating activities may include quality assessment and improvement activities, reviewing the competence or qualifications of healthcare professionals, evaluating provider performance, case management, physician reviews, compliance programs or audits, conducting training programs, accreditation, certification, or licensing activities. For example, Comfort Keepers may contact you to remind you of your scheduled visit by our Comfort Keepers office. Your PHI will be used and disclosed from Comfort Keepers Franchises to CK Franchising, Inc. as a course of business operations.

 

Your Authorization: In addition to our use of your PHI for treatment, payment, or healthcare operations, you may give us written authorization to use your PHI or to disclose it to anyone for any purpose. If you give us an authorization, you may revoke it in writing at any time. Your revocation will not affect any use of disclosure permitted by our authorization while it was in effect. Unless you give us a written authorization, we cannot use or disclose your PHI for any reason except those described in this Notice. Release of psychotherapy notes will always require your prior authorization.

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To Your Family and Friends: We must disclose your PHI to you, as described in the Patient Rights section of this Notice. We may disclose your PHI to a family member, friend or other person that is involved in your care, who assists in taking care of you assists with payment for your healthcare, but only if you agree that we may do so.

 

Persons Involved in Care: We may use or disclose PHI, including identifying or locating, to notify, or assist in the notification of a family member, your personal representative, or another person responsible for your care, of your location, your general condition, or death. If you are present, then prior to use or disclosure of your PHI, we will provide you with an opportunity to object to such use or disclosures. In the event of your incapacity or emergency circumstances we will disclose PHI based on a determination using our professional and reasonable judgment and only disclosing PHI that is directly relevant to the person’s involvement in your healthcare. We will also use our professional judgment and our experience with common practice to make reasonable inferences of your best interest in allowing a person to pick up filled prescriptions, medical supplies, and other similar forms of PHI.

 

Abuse or Neglect: We may disclose your PHI to appropriate authorities if we reasonably believe that you are a possible victim of abuse, neglect, or domestic violence or the possible victim of other crimes. This information may be disclosed to the extent necessary to avert a serious threat to the health or safety of you or others.

 

Appointment Reminders: We may use and disclose your PHI to contact you and remind you of an appointment via phone or voicemail messages.

 

Business Associates: some of the services provided in our organization are through contracts with Business Associates. Examples may include after-hours answering service, third party payment vendor or another health care provider. When these services are contracted, we may need to disclose some or all of your PHI so they can perform the job we asked them to do. In order to protect your health information, we do require the Business Associate to appropriately safeguard your information, Public Health Risks: We may use and disclose your PHI to public health authorities or other authorized persons to carry out certain activities related to public health, as permitted by law to collect, or receive the information. This disclosure will be made for purposes such as controlling disease, injury or disability.

 

Marketing Health Related Services: We will not sell or use your PHI for marketing communication without your written authorization.

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Required by Law, Lawsuits and Legal Proceedings: We may use or disclose your PHI when we are required to do so by law, required by a court, in response to subpoenas, discovery requests, or other legal processes.

 

Serious Threats: As permitted by applicable law and standards of ethical conduct, we may need to use or disclose PHI if we, in good faith, believe that the use or disclosure if necessary to prevent or to lessen a serious or imminent threat to the health or to the safety of a person or the public.

 

Military and National Security: We may use or disclose your PHI if you are or have been a member of U.S. or foreign military forces and if required by the appropriate authorities. We may also disclose this information to federal officials for intelligence and national security activities authorized by law, as well as, to correctional institution officials in the event of an inmate or an individual taken into custody.

 

Coroners, Medical Examiners, Funeral Directors: We may use or disclose your PHI to a coroner or medical examiner to identify a deceased person and determine the cause of death, as well as, to funeral directors, as authorized by law, so that they may carry out their jobs.

 

Organ Donation: If you are an organ donor: we may disclose PHI to organizations involved in organ and tissue donation, procurement and transplant

 

Research: We may disclose your PHI to researchers when an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your PHI has approved their research.

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Treatment Alternatives: we may use or disclose PHI to inform you about or make recommendations to possible treatment options.

 

Health-Related Benefits and Services: we may use and disclose PHI to tell you about health-related services or benefits that may be of interest to you.

 

Communicable Disease: We may need to disclose your PHI to notify a person who may have been exposed or may be at risk for contracting or spreading a disease or condition.

 

Worker’s Compensation: Your protected health information may be disclosed as authorized to comply with Worker’s Compensation laws and other similar legally established programs.

 

OUR RESPONSIBILITES

By law we are required to maintain the privacy of your health information. In addition, we are required to provide you with notice of our legal duties and privacy practices. This notice is in respect to the information we collect and maintain about you. We reserve the right to change our practice and make new provisions effective for all the PHI we maintain. If our information practices change, a revised notice about those changes will be mailed to the address you supplied upon request. Such changes will also be made public on our Comfort Keepers website. Your health information will not be used or disclosed without your written permission, except as described in this notice. The following uses and disclosures will be made only with explicit authorization from you: (i) uses and disclosures of your PHI for marketing purposes (ii) disclosures that constitute a sale of your PHI, (iii) other uses and disclosures not described in this notice. Except as noted above, you may revoke your authorization in writing at any time.

 

FOR MORE INFORMATION OR TO REPORT A PROBLEM

Should you have questions about this notice or would like additional information, please contact our HIPAA Privacy officer at the address and telephone below: If you believe your privacy rights have been compromised, you have the right to file a complaint with the Privacy Officer at Comfort Keepers or with the Secretary of the Department of Health and Human Services. Their information is listed below. The complaint must be submitted in writing describing the acts or omissions that you believe compromised your privacy rights. This complaint must be filed within 180 days of when you felt the act or omission occurred. We will not take retaliatory action against you for filing such a complaint. The contact information for the Secretary of DHHS and our Privacy Officer is listed below.

 

PATIENT RIGHTS

Access: You have the right to look at or obtain electronic copies of your PHI, with limited exceptions. You must make a request in writing to obtain access to your PHI. You may request access by sending us a letter, using the contact information listed at the end of this Notice. We will charge you a reasonable cost-based fee for expenses such as copies and staff time.

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Accounting of Disclosures: You have the right to receive a list of instances in which we or our business associates disclosed your PHI for purposes, other than treatment, payment, healthcare operations and certain other activities.

 

Breach Notification: You have the right to receive notification of breaches of your unsecured PHI.

Restriction: You may request that we don’t use or disclose your PHI for a particular reason related to treatment, payment, general health care operations, and/or to a particular family member, other relative or close personal friend. Although we will consider your request, please be aware that we are under no obligation to accept it or 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. If you fail to pay for services, we have the right to bill your insurance carrier and disclose your protected health information during the claim.

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Amendment: You have the right to request, in writing, that we amend your PHI. It must explain why the information should be amended. We may deny your request under certain circumstances.

Right to a Paper Copy of This Notice: You are entitled to receive a paper copy of our Notice of Privacy Practices. You may ask us to give you a copy of this Notice at any time.

Right to File a Complaint: If you believe your privacy rights have been violated, you may file a complaint with our Comfort Keepers Privacy Officer.

 

QUESTIONS AND COMPLAINTS

If you want more information about our privacy practices or have questions or concerns, please contact us. If you are concerned that we may have violated your privacy rights, or you disagree with a decision we made about access to your PHI or in response to a request you made to amend or restrict the use or disclosure of your PHI, you may discuss it with us using the contact information listed at the end of this Notice. You also may submit a written complaint to the U.S. Department of Health and Human Services. We will provide you with the address to file your complaint upon your request. We support your right to the privacy of your PHI. We will not retaliate in any way if you choose to file a complaint with us or with the U.S. Department of Health and Human Service

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Contact Information

Comfort Keepers

Privacy Officer: Erin White, 33312 Grand River Avenue, Ste. 200, Farmington, MI 48334
Telephone: (248) 919-8760, Fax: (248) 234-6346, email: care@ckfarmington.com

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US Department of Health and Human Services

Office of the Secretary, 200 Independence Avenue, S.W., Washington, D.C. 20201
Telephone: (202) 619-696-6775, Toll Free: (877) 696-6775 - http://www.hhs.gov/contacts