Privacy Practices

NOTICE OF PRIVACY PRACTICES OF COMMUNITY ALLIANCE REHABILITATION SERVICES

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.

EFFECTIVE DATE OF NOTICE: November 1, 2023

OUR RESPONSIBILITIES

This Notice describes the privacy practices of Community Alliance Rehabilitation Services and all of its programs and services and Community Alliance Health Partners, including employees, volunteers, students, and any other persons acting on each organization’s behalf. This Notice also describes the privacy practices of an Organized Health Care Arrangement (“OHCA”) under HIPAA between Community Alliance Rehabilitation Services and Community Alliance Health Partners. An OHCA allows legally separate Covered Entities to use and disclose protected health information (“PHI”) for the joint operations of the OHCA. Community Alliance Rehabilitation Services and Community Alliance Health Partners participate in an OHCA to facilitate access to PHI that may be relevant to your care as part of our integrated care model. As a result, both organizations may share your PHI with each other for purposes of treatment, payment, or the health care operations related to the OHCA.
Our organizations are required to maintain the privacy of your medical information and provide you with this notice of our legal duties and privacy practices with respect to information we collect and maintain about you. We will abide by the terms of this notice and notify you if we are unable to agree to a requested restriction. We will accommodate reasonable requests you may have to communicate health information by alternative means or at alternative locations.

Your Individual Rights

Although your client record is the physical property of Community Alliance Rehabilitation Services or Community Alliance Health Partners, the information in your record belongs to you. You have the following rights:

Request for Voluntary Restrictions

You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment, or health care operations, or to persons involved in your care or for the payment of your care. We are not required to agree to your request, with one exception explained in the next paragraph, and we will notify you if we are unable to agree to your request. We are required to agree to your request that we not disclose certain health information to your health plan for payment or health care operations purposes, if you pay out-of-pocket in full for all expenses related to that service prior to your request, and the disclosure is not otherwise required by law. Such a restriction will only apply to records that relate solely to the service for which you have paid in full. If we later receive an Authorization from you dated after the date of your requested restriction which authorizes us to disclose all of your records to your health plan, we will assume you have withdrawn your request for restriction. You must make a separate request to each covered entity from whom you will receive services that are involved in your request for any type of restriction.

Access to Your Client Record and Medical Information

You may inspect and copy much of the information we maintain about you with some exceptions. If we maintain the medical information electronically in one or more designated record sets and you ask for an electronic copy, we will provide the information to you in the form and format you request, if it is readily producible. If we cannot readily produce the record in the form and format you request, we will produce it in another readable electronic form we both agree to. We may charge a cost-based fee for producing copies or, if you request one, a summary. If you direct us to transmit your medical information to another person, we will do so, provided your signed, written direction clearly designates the recipient and location for delivery.

Amendment

You may request that we amend certain medical information that we keep in your record. We are not required to make all requested amendments but will give each request careful consideration. If we deny your request, we will provide you with a written explanation of the reasons and your rights.

Accounting

You have the right to receive an accounting of certain disclosures of your medical information made by us or our business associates for the six years prior to your request. Your right to an accounting does not include disclosures for treatment, payment and healthcare operations and certain other types of disclosures, for example, as part of a facility directory or disclosures in accordance with your authorization.

Confidential Communication

You may request that we communicate with you about your medical information in a certain way or at a certain location. We will attempt to accommodate all reasonable requests which specifies the alternate means or location.

Notice in Case of Breach

We are required by law to notify you of a breach of your unsecured medical information. We will provide such notification to you without unreasonable delay, but no later than 60 days after we discover the breach.

How To Exercise These Rights

All requests to exercise these rights must be in writing. We will respond to your request on a timely basis in accordance with our written policies and as required by law. Contact the Privacy Officer for more information or to obtain request forms.

ABOUT THIS NOTICE

We are required to follow the terms of the Notice currently in effect. We reserve the right to change our privacy practices and to make the new practices and provisions effective for all medical information that we maintain. Before we make such changes effective, we will post the changes on bulletin boards within program facilities. The revised Notice will also be posted on our web site at www.community-alliance.org. You are entitled to receive this Notice in written form. If you want a copy in written form, please contact the Privacy Officer at the address listed below.

UNDERSTANDING YOUR CLIENT RECORD / INFORMATION

Each time you utilize a service and work with staff members, a record of the service provided is made. Typically, this record contains diagnoses, services provided, and a plan for future care or treatment. This information, often referred to as your client or medical record, serves as:

  • Basis for planning your care, treatment, rehabilitation and support
  • Means of communication among the many health professionals who contribute to your care
  • Legal document describing the care you received
  • Means by which you or a third-party payer can verify that services billed were actually provided
  • A tool in educating health professionals, including students
  • A source of information for public health officials who oversee the delivery of health care
  • A source of data for facility planning and marketing
  • A tool with which we can assess & continually work to improve the care we render and outcomes achieved

Understanding what is in your record and how your medical information is used is important to helping you ensure its accuracy; better understand who, what, when, where and why others may access your medical information; and make more informed decisions when authorizing disclosure to others.

HOW WE WILL USE OR DISCLOSE YOUR MEDICAL INFORMATION

The following are the types of uses and disclosures we may make of your medical information without your permission. Medical information includes your individually identifiable medical, insurance, demographic and medical payment information. For example, it includes information about your diagnosis, medications, insurance status and policy number, or medical claims history, address, and social security number. Where State or federal law restricts one of the described uses or disclosures, we follow the requirements of such State or federal law. These are general descriptions only. They do not cover every example of disclosure within a category.

Treatment/Service Provision

We will use or disclose your medical information for the purpose of providing you with services, coordinating and consulting about your treatment and care with other health care providers, social service providers and making referrals for services and benefits that you need. This means that as we provide services and coordinate with other providers involved in your care, personal health care information will be disclosed. For example, information obtained by the Community Alliance Rehabilitation Services team you are working with will be recorded in your record and used to plan your individual action plan with you, your physician and others of your choosing. We will also disclose your medical information to other practitioners, providers and health care facilities for their use in treating you in the future. For example, if you are transferred to another facility or program, we will send medical information about you to the facility/program.

Payment

We will use or disclose your medical information for payment, including for the payment activities of other health care providers or payers. For example, a bill may be sent to you or to a third-party payer, including Medicaid, Medicare, Health and Human Services, Region 6 Behavioral Healthcare, Department of Education, U.S. Department of Housing and Urban Development, State housing assistance program manager, and the Rental Assistance Program housing authority. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis and services provided. In addition, payments may be made on your behalf, from your funds, such as to grocery stores, utility companies, landlords and pharmacies. These payments will identify you as a client of Community Alliance Rehabilitation Services or Community Alliance Health Partners. We may also disclose medical information about you to other medical care providers, medical plans, and health care clearinghouses for their payment purposes. If State law requires, we will obtain your permission prior to disclosing to other providers or health insurance companies for payment purposes.

Health Care Operations

We will use or disclose your medical information for our health care operations. For example, members of the staff, members of the quality review team or other members of our workforce may use information in your client record to evaluate the treatment, services, outcomes and the performance of our staff in caring for you. This information is used in an effort to continually improve the quality and effectiveness of the health care and service we provide.

Business Associate

There are some services provided in our organization through the use of outside people and entities. Examples of these “business associates” include our computer hardware and software companies and financial auditors. We will use or disclose your medical information to our business associates so that they can perform the job we have asked them to do. To protect your medical information, however, we require the business associate to appropriately safeguard your information.

Appointment Reminders

We may contact you as a reminder that you have an appointment for treatment, medical, or other services. If we are unable to reach you, then we may leave a message at the phone number provided us, such as on an answering machine.

Treatment Alternatives

We may contact you to provide information about service provision, treatment alternatives or other health-related benefits that may be of interest to you.

Fundraising

We may contact you as a part of a fundraising effort. We may also use or disclose certain medical information about you, such as your name, address, phone number, dates you received services, and the names and contact information of your involved family members or friends, to a business or associate or to a foundation related to our organization so that they may contact you as part of fundraising efforts. If you do not wish to receive further fundraising communications, you should follow the instructions written on each communication that informs you how to be removed from any fundraising lists. You will not receive any fundraising communications from us after we receive your request to opt out unless we have already prepared a communication prior to receiving notice of your election to opt out.

Directory/Listing

Unless you notify us that you object, we may use your name, location in the facility, and general condition for listing purposes. This information may be provided to people who ask for you by name. We may also use your name on a nameplate next to or on your door within our residential facilities in order to identify your room or within Day Rehabilitation on a community trip or birthday bulletin board listing, unless you notify us that you object.

Communication with Family

We may use or disclose your location or general condition to a family member or your personal representative or another person identified by you. If any of these individuals are involved in your care, we may also disclose such medical information as is directly relevant to their involvement. We will only release this information if you agree, are given the opportunity to object and do not, or if in our professional judgment, it would be in your best interest to allow the person to receive the information or act on your behalf. For example, we may allow a family member to pick up your personal belongings or prescriptions on your behalf. We may also disclose your information to an entity assisting in disaster relief efforts so that your family or individual responsible for your care may be notified of your location and condition.

Required by Law

We will use and disclose your information as required by federal, State or local law.

Public Health Activities

We may use or disclose your medical information for public health activities. For example, to public health or legal authorities charged with preventing or controlling disease, injury, or disability, to appropriate authorities authorized to receive reports of abuse or neglect, or to notify a person who may have been exposed to a disease or may be at risk of contracting or spreading a disease or condition. Other information that may be disclosed includes information related to adverse events associated with food, supplements, or product defects.

Abuse, Neglect or Domestic Violence

We may notify the appropriate authority if we believe a client has been the victim of abuse, neglect or domestic violence. Unless such disclosure is required by law (for example, to report a particular type of injury), we will only make this disclosure if you agree.

Health Oversight Activities

We may use or disclose medical 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.

Judicial and Administrative Proceedings

If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose information about you in response to a subpoena, discovery request or other lawful process by someone else involved in the dispute, but only if reasonable efforts have been made to notify you of the request or to obtain an order from the court protecting the information requested.

Deceased Individuals

We are required to apply safeguards to protect your medical information for 50 years following your death. Following your death, we may disclose medical information to a coroner, medical examiner or funeral director as necessary for them to carry out their duties and to a personal representative (for example, the executor of your estate). We may also release your medical information to a family member or other person who acted as personal representative or was involved in your care or payment for care before your death, if relevant to such person's involvement, unless you have expressed a contrary preference.

Law Enforcement

We may release certain medical information if asked to do so by law enforcement:

  • As required by law, including reporting certain wounds and physical injuries
  • In response to a court order, subpoena, warrant, summons or similar process
  • To identify or locate a suspect, fugitive, material witness or missing person
  • If you are the victim of a crime if we obtain your agreement or, under certain limited circumstances, if we are unable to obtain your agreement.
  • To alert authorities of a death we believe may be the result of criminal conduct
  • Information we believe is evidence of criminal conduct occurring on our premises; and
  • In emergency circumstances to report a crime; the location of the crime or victims or the identify, description or location of the person who committed the crime

Research

We may disclose information to researchers when certain conditions and safeguards have been met.

Threats to Health or Safety

Under certain circumstances, we may use or disclose your medical information to avert a serious threat to health and safety if we, in good faith, believe the use or disclosure is necessary to prevent or lessen the threat and is to a person reasonably able to prevent or lessen the threat (including the target) or is necessary for law enforcement authorities to identify or apprehend an individual involved in a crime.

Specialized Government Functions

We may use and disclose your medical information for national security and intelligence activities authorized by law or for protective services of the President. If you are a military member, we may disclose to military authorities under certain circumstances. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose to the institution, its agents or the law enforcement official your medical information necessary for your health and the health and safety of other individuals.

Workers' Compensation

We may disclose medical information about you as authorized by law for workers' compensation or similar programs that provide benefits for work-related injuries or illness.

Incidental Uses and Disclosures

There are certain incidental uses or disclosures of your information that occur while we are providing service to you or conducting our business. For example, use of an overhead paging system may be used to call you during the program and others in the building may hear your name called. We will make reasonable efforts to limit these incidental use and disclosures.

Health Information Exchange

We participate in one or more electronic health information exchanges which permits us to electronically exchange medical information about you with other participating providers (for example, doctors and hospitals) and health plans and their business associates. For example, we may permit a health plan that insures you to electronically access our records about you to verify a claim for payment for services we provide to you. Or, we may permit a physician providing care to you to electronically access our records in order to have up to date information with which to treat you. We may in the future allow other parties, e.g. public health departments that participate in the health information exchange, to access your medical information electronically for their permitted purposes as described in this Notice.

Uses and Disclosures Requiring Your Authorization

There are other uses and disclosures we will make only with your written authorization. These include:

Prospective Employers

We may request to use and disclose your medical information in order to help you in choosing, obtaining and retaining a job in the community.

Housing Eligibility and Processing

We may request to and disclose your medical information for housing eligibility and processing with Community Alliance Housing Corporations, Community Alliance Residential Services, Community Alliance Housing Management Services, and other housing services such as Douglas County Housing Authority and Omaha Housing Authority. For example, your personal health and financial information may be used to determine your eligibility for a subsidized housing program.

Disability Determination Reviews

We may request to use and disclose your medical information for the purpose of assisting the Social Security Administration and attorneys involved in your case in determining disability or continuing disability in seeking Social Security benefits and/or Supplemental Security Income.

Psychotherapy Notes

These are notes made by a mental health professional documenting conversations during private counseling sessions or in joint or group therapy. Many uses or disclosures of psychotherapy notes require your authorization.

Sale of Medical Information

We will not sell your medical information to third parties without your authorization. Any such authorization will state that we will receive remuneration in the transaction.

Marketing

We will not use or disclose your medical information for marketing purposes without your authorization. Moreover, if we will receive any financial remuneration from a third party in connection with marketing, we will tell you that in the authorization form.

Uses and Disclosures Not Described Above

Any other use or disclosure of your medical information that is not described in the preceding examples.

If you provide authorization, you may revoke it at any time by giving us notice in accordance with our authorization policy and the instructions in our authorization form. Your revocation will not be effective for uses and disclosures made in reliance on your prior authorization.

FOR MORE INFORMATION OR TO REPORT A PROBLEM

If you have questions and would like additional information, you may contact our Privacy Officer using the contact information listed below. If you believe that your privacy rights have been violated, you may file a complaint with us. Complaints must be filed in writing on a form provided by us. The complaint form may be obtained from any staff member and when completed, should be returned to the addresses listed below. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services. There will be no retaliation for filing a complaint.

CONTACT INFORMATION

Privacy Officer
Community Alliance Rehabilitation Services
4001 Leavenworth Street
Omaha, Nebraska 68105
Phone: 402-341-5128

Privacy Officer
Community Alliance Health Partners
4001 Leavenworth Street
Omaha, Nebraska 68105
Phone: 402-341-5128