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Newton Family Physicians
767 West First Street, Newton, NC 28658
Privacyand protection of personal information is important to Newton Family Physicians, PA. We are committed to collecting, using and disclosing personalinformation responsibly and only to the extent necessary for the services weprovide. We also try to be open andtransparent as to how we handle personal information. This document describes our privacy polices.
WHAT IS PERSONALINFORMATION: Personalinformation is information about an identifiable individual. Personal information includes informationthat relates to: an individual’spersonal characteristics (ex: gender,age, home address, phone numbers, ethnic background, family status); health(ex: health history, health conditions,health services received by them). Personal information is different from business information (ex: an individual’s business location and phonenumber). This is not protected byprivacy legislation.
WHO WE ARE: Our organization, Newton Family Physicians, PA, includesat the time of writing six physicians, four nurse practitioners and thirty one supportstaff. We use a number of agencies andconsultants that may, in the course of their duties, have limited access topersonal information we hold. These includecomputer consultants, cleaning agency, accountants, credit card company,software vendor, attorneys, hospitals, other doctors offices, electronic claimsclearinghouse (insurance billing), and financial institutions. We restrict their access to any personalinformation we hold as much as reasonably possible. We also have their assurance that they followappropriate privacy policies.
NORTH CAROLINA HEALTHINFORMATION EXCHANGE(NCHealthConnex): Beginning February, 2018, we participate inthe North Carolina state-operated Health Information Exchange called NCHealthConnex. For patients withinsurance coverage through Medicaid, North Carolina Health Choice and all stateemployee plans, whether current or retired, we will be sharing relevant healthinformation about you with NC HealthConnex. This will allow other health careproviders to access your information when it may be necessary. Please review the NC HealthConnex brochureprovided to you.
WE COLLECT PERSONALINFORMATION: (PRIMARYPURPOSES)
About Patients: Like all physicianoffices, we collect, use and disclose personal information in order to serveour patients, and provide treatment. Forexample, we collect information about a patient’s health history, includingfamily history, physical condition, medication and life style choices. We also may collect financial information inorder to file insurance claims on the patient’s behalf. We do this so we can provide the very bestcare available for the present condition. We also collect information from other offices or facilities to assistin treatment. We may collect information in an emergencysituation from family members even if a patient is not able to give consent(ex: the patient is unconscious). All of this information is secured in theproper location in our office and is protected in our electronic health recordas well as our practice management system where financial information isstored.
About Members of the General Public: For members of thegeneral public, our primary purpose for collecting personal information is toprovide notice of special events (i.e. health fairs) or to make them aware of Newton Family Physicians’ services ingeneral or for specific notifications (i.e. flu shot reminders). For example, we may collect work informationand phone numbers, email addresses, and even emergency contact information.
About Contract Staff, and Students: We collect personalinformation for contract workers in order to be able to contact them in thefuture (new work assignments) and for necessary work related communication(sending payroll checks, year end tax receipts). Examples of the types of personal informationthat we collect are: home address,home/cell telephone numbers. It is rarefor us to collect such information without prior consent, but it might happenin the case of a health emergency (TB outbreak) or to investigate a possiblebreach of law (if theft were to occur in our clinic). If contract staff or students wish a letterof reference or an evaluation, we will collect information about their workrelated performance and provide a report as authorized by them.
WE COLLECT PERSONALINFORMATION: (RELATED AND SECONDARYPURPOSES)
Likemost organizations, we also collect, use and disclose information for purposesrelated to or secondary to our primary purposes. The most common examples are:1)To invoicepatients for services not paid for at the time, to process credit card paymentsor to collect unpaid accounts and 2) To advise patients and others aboutspecial events or opportunities (health fair, vaccine supplies) that we haveavailable.
Ouroffice reviews patient charts and other files for the purpose of ensuring thatwe provide high quality services, including assessing the performance of ourstaff. In addition, external consultants(auditors, lawyers, practice consultants, voluntary accreditation programs) mayon our behalf do audits and quality improvement reviews of our office,including reviewing patient files and interviewing our staff.
Newton Family Physicians, PA isregulated by the American Academy of Family Physicians, the American MedicalAssociation and the American Academy of Nurse Practitioners. We are audited for quality by the Centers forMedicare & Medicaid Services, Drug Enforcement Agency, various insuranceagencies and our local hospital where we are on staff. External regulators have their own strictprivacy policies (financial institutions, software vendors, collection agency,etc). Also various insurance companiesand pharmaceutical companies have their own privacy policies. All of the above entities have the right toreview our charts and interview our staff as part of their mandates. In these circumstances, we may consult withprofessionals (ex: lawyers, accountants)who will investigate a specific matter and report back to us.
Thecost of some services provided by the organization to our patients is paid forby third parties (ex: BCBS, Cigna,United Healthcare insurance companies). These third party payers often have patient consent or legislativeauthority to direct us to collect and disclose to them certain information inorder to demonstrate patient entitlement funding.
Patientsor other individuals we deal with may have questions about our services afterthey have been received. We also provideongoing services for many of our patients over an extended period for whichprevious records are helpful. We retainour patients information for a minimum of ten years after the last encounter,with the exception of minors in which we retain records for a minimum of tenyears after the patient’s eighteenth birthday.
If NewtonFamily Physicians, PA or its assets were to be sold, the purchaser wouldwant to conduct a “due diligence” review of the offices records to ensure thatit is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review ofour accounting and service files. Thepurchaser would not be able to reproduce or remove any personalinformation. Before being providedaccess to the files, the purchaser must provide a written promise to keep allpersonal information confidential.
Patientscan choose not to be a part of some of these (ex: by declining to receivenotice of special events or opportunities or by paying for your services in advance). However, some of these related or secondarypurposes are mandated and not optional.
Weunderstand the importance of protecting personal information. For that reason, we have taken the followingsteps:
· Paperinformation is either under supervision or secured in non-patient access areas.
· Electronichardware is either under supervision or locked in a restricted area at alltimes.
· Passwordsare used on the servers and by each user.
· Paperinformation is transmitted through sealed, addressed envelopes by reputablecompanies.
· Electronicinformation is transmitted through dedicated lines and has identifiers removed.
· Externalconsultants and agencies with access to personal information must enter intoprivacy agreements with us.
RETENTION AND DESTRUCTIONOF PERSONAL INFORMATION
Weneed to retain personal information for some time to ensure that we can answerany questions patients might have about the services provided and for our ownaccountability to external regulatory bodies. However, we do not want to keep personal information longer thannecessary to protect your privacy.
Wekeep our patient files for ten years after the last encounter and, if a minor,ten years after their eighteenth birthday. We keep all originals from our office and will transfer by writtenauthorization copies of personal healthinformation. We will also transfer uponproper written authorization any financial information that patients request.
Wedestroy paper files or records that have been scanned into our electronic chartby shredding. We destroy electronicinformation by removal upon proper authorization and confirmation from theprovider or the practice administrator. When a computer is retired we ensure that the hard drive is physicallydestroyed. We require that all copiersand fax machines be erased in our presence before getting rid of them.
YOU CAN LOOK AT YOURINFORMATION
Witha few exceptions, patients have the right to see what personal information wehold on them. We will try to help patientsidentify information about their records and help them understand information(acronyms, technical language, etc.). Wewill need to confirm a patient’s identity before providing access. We reserve the right to charge a nominal feefor such requests.
Ifthere is a problem we may ask patients to put their request in writing. If we cannot give access, we will tell apatient within 30 days if at all possible and explain why.
Ifa patient believes there is a mistake in the information they have the right toask for it to be corrected. This appliesto factual information and not to any professional opinions we may haveformed. We may ask you to providedocumentation that our files are wrong. Where we agree that we made a mistake, we will make the correction andnotify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree toinclude in our file a brief statement from you on the point and we will forwardthat statement to anyone else who received the earlier information.
PATIENTS HAVING QUESTIONS
OurInformation Officer, Melissa H. White, will attempt to answer questions orconcerns patients might have. She can be reached at: 767 West First Street, Newton, NC 28658, or828-465-3928. If a patient wishes tomake a formal complaint about our privacy practices, you may make it in writingto our Information Officer. She willacknowledge receipt of your complaint, ensure that it is investigated promptlyand that you are provided with a formal written decision with explanation. If you have a concern about theprofessionalism or competence of our services or the mental or physicalcapacity of any of our professional staff we would ask you discuss thoseconcerns with us.
Thispolicy is made under the Personal Information Protection and ElectronicDocuments Act. That is a complex Act andprovides some additional exceptions to the privacy principles that are toodetailed to set out here. There are somerare exceptions to the commitments set forth above.
Formore general inquiries, The Federal Trade Commission (FTC) and the FederalRegister have detailed explanations of the Red Flag Rules guidelines formedical practices available. Also youmay go to the North Carolina Government website to read about the NorthCarolina Identity Theft Act which is now in place.
FormNPPHIPAA12112015 Updated1/2016 Updated12/2016 Updated8/2017 Updated1/2018
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