Catholic Charitable Bureau of the Archdiocese of Boston, Inc.

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.

Our Pledge to You

Catholic Charities understands that information about you and your health is personal and private. We are committed to protecting the privacy of your Protected Health Information (PHI). The state and federal governments have very strict rules governing the use and disclosure of health information, and Catholic Charities takes seriously its compliance with all applicable laws and regulations. At Catholic Charities, all employees and volunteers receive ongoing training in privacy policies and practices so that you can feel confident that your health information is being respected and protected.

In order to provide you with coordinated, quality care, Catholic Charities maintains a written record of your treatment. This record contains the personal information needed to provide you with the best possible care and documentation of the treatment services you receive. This record is kept in a secure location and access to it is limited.

This notice will tell you about the ways in which Catholic Charities may use your Protected Health Information and when and how that information may be disclosed. This notice will also tell you about your rights with respect to your health information.

Under most circumstances, Catholic Charities will disclose your PHI to an outside party only with your signed, informed consent. However, as specified in federal and state law, there are circumstances in which we may use or disclose your PHI without your consent.

Catholic Charities may use or disclose your Protected Health Information Without Your Consent to:

• Provide Quality Treatment. Health information recorded in your clinical record will be used by your clinicians and/or service providers to assure the quality and coordination of your care. For Example:
  • The clinical record is one way in which the various Catholic Charities professionals involved in your care communicate about your treatment.
  • Program staff will use your recorded PHI if you call needing assistance with a prescription or an appointment.
  • Supervisory staff use your recorded PHI to review your care and assist your service provider in providing you with the highest quality treatment.
  • For Payment. Your Protected Health Information is used in the completion of authorizations for insurance companies and in processing billing to pay for the services provided to you. Prior authorizations may require a detailed description of your current symptoms/problem and the plan for addressing that problem. Bills for services provided may require PHI including identifying information, a diagnosis, and a brief description of the service provided.
  • For the Operation of Catholic Charities. Our quality assurance team may review your treatment record in order to assess the quality and effectiveness of our treatment services.
  • To Contact You. Catholic Charities may use your identifying information, including your address and phone number, to contact you with regards to an issue related to your treatment, such as to remind you of an appointment, change an appointment, follow up on some aspect of your care, inform you about treatment alternatives and services or benefits that we offer, or inform you of a change in Catholic Charities policy or procedure that has an impact on you and your treatment. Catholic Charities will NOT use PHI obtained from clinical records for the purpose of marketing or fundraising without your express authorization.

Catholic Charities may also use or disclose your PHI without your consent in the following circumstances:

• In an Emergency To Avert a Serious Threat to Health or Safety. We may use and disclose medical 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 the threat.
• Public Health Reporting or Duties. We may disclose medical 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 elder abuse or exploitation.
  • To report reactions to medications or problems with products.
  • 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.
  • To inform coroners, medical examiners and funeral directors as necessary for them to carry out their duties.
  • To organ, tissue, and other donation organizations, upon or proximate to your death, if Catholic Charities has no indication on hand about your donation preferences.
  • To the sponsor of your health plan (i.e., group health plan or HMO).
  • To outside third-parties, known as Business Associates, to conduct treatment, payment or health care operations on behalf of Catholic Charities.
  • For research purposed under certain circumstances, but only to researchers and under protocols designed to protect the privacy of your health information.
  • To comply with laws relating to worker's compensation and similar programs.
• When Required by Law or Judicial Proceedings. Catholic Charities may disclose your PHI in response to a valid subpoena or court order. If Catholic Charities is served with a valid subpoena or court order demanding the release of your PHI, we will make every reasonable effort to contact you to inform you that a subpoena or court order has been received and your PHI is being released to a court or to a party in litigation.
• Regulatory Oversight. We may disclose your PHI to an oversight regulatory agency for activities authorized by law, including audits and inspections as necessary for our licensure and for the government to monitor the health care system, government programs, and compliance with civil rights laws.
• Law Enforcement. We may disclose identifying information to law enforcement in the event of the following:
  • In response to a court order, subpoena, warrant, summons or similar process.
  • To identify or locate a suspect, fugitive, material witness, or missing person (with properly executed documentation such as a search warrant).
  • To provide information about the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement.
  • To provide information about a death we believe may be the result of criminal conduct.
  • In the event that you commit a crime or make a threat of a crime, or are reasonably suspected of the same, while on Catholic Charities property or against a Catholic Charities employee.
• Specific Government Functions. We may release information about you to authorized federal officials in connection with military and veterans activities, national security and intelligence activities, for protection of the President or other authorized persons or foreign heads of state or to conduct special investigations.
• Family, Friends, and Guardians. As a general rule, Catholic Charities will not release any information about you or your care to any individual without your specific, written consent. This includes family and friends. There are some specific exceptions to this policy as allowed by Federal Law.
• Catholic Charities may discuss your case with your parent, caretaker, or guardian if you are under the age of 18 or under the guardianship of another adult.
• In the case of impaired or elder clients, Catholic Charities will share information with specified family members or friends who are involved in your care. However, you have the right to request that we not share information with any specific individual or anyone whom you have not specifically identified with a written authorization.

You have a right to:

• See and Get a Copy of Your Information. With limited exceptions, you have the right to see all your recorded Protected Health Information (PHI). You also have a right to get a copy of that information. Requests to see your PHI or obtain a copy must be made in writing. Requests can be made by letter or by filing a “Request for Copy of PHI” form which is available at the front desk or from your service provider. Catholic Charities may offer to review your file with you at the time of inspection. You have the right to refuse that offer. Upon request, Catholic Charities will provide you with one free copy of your record within any 12 month period. Additional requests for copies will be processed for a per page fee permitted by Massachusetts law to cover our expenses. There is never a charge for a copy of a record sent directly to another service provider for the sake of treatment planning. Under very specific, limited circumstances, after a review of your request by a licensed health care provider, we may deny your request to see or copy your PHI. You have the right to appeal that decision to the Catholic Charities Privacy Officer. Your appeal will be reviewed by a licensed health care provider who did not take part in the initial denial decision.
• Request that we Limit Certain Uses and Disclosures of Your Information. You have the right to request that we limit how we use or disclose your PHI. Requests must be made in writing to the Program Director. Although we are not required to comply, whenever possible, we will comply with your request. If we cannot comply, we will inform you of that decision in writing.
• Change or Update Your Information. If you feel that the PHI we have about you is incomplete or incorrect, you may request that we change (amend) that information. You may request an amendment for as long as we maintain your health information. Requests must be made in writing and submitted to the Program Director. When making a request you must specify which information you want amended and why. We are not required to grant requests to amend information that:
  • Was not created by Catholic Charities.
  • Is not part of the standard record.
  • Is not information that you are permitted to inspect or copy.
  • Is accurate and complete.

  If we are unable to comply with your request, we will inform you and you may prepare a written statement to be placed in your record. We will prepare a written response which will also be placed in your record, with a copy sent to you.

• Receive a List of the Disclosures of Your Information. You have the right to receive a list (“accounting”) of the disclosures we have made of your PHI for most purposes other than treatment, payment, or health care operations. The accounting will not include disclosures we have made directly to you or pursuant to your written authorization, disclosures to parents or guardians of minors, or disclosures made to family members when you were present. Requests must be submitted in writing to the Program Director. The request must state the time period, but may not be longer than six years and may not include dates prior to April 14, 2003. Catholic Charities will process one request per patient per 12 month period free of charge. Additional requests will be charged a fee based on the amount of time it will take to process the request. The fee will be based on a charge of $20/hour with a 15 minute minimum. You will be informed of the fee prior to the processing of the request and may withdraw or alter your request at that time.
• Request Communications of Your Information by Alternative Means or at Alternative Locations. You may request that we contact you about medical matters in a certain manner or at a certain location such as only in writing or at a different residence or post office box. Requests must be made in writing to the Program Director. All reasonable requests will be accommodated.
• Withdraw your Consent. You have the right to withdraw your consent to use or disclose PHI except to the extent that action has already been taken. You may withdraw your consent at any time by completing an Authorization Revocation Form which can be obtained from your service provider, at the front desk, or by writing to the address listed at the end of this document. We may refuse to continue to treat an individual who has revoked his or her consent.
• Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice. You may ask for a copy of this notice at any time. Even if you agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. You can obtain a paper copy of this notice from your service provider, from the front desk, or by writing to the medical records department listed at the bottom of this notice. You may also obtain a copy of this notice at our website, www.ccab.org.
• Complaints. If you believe that your privacy rights have been violated, you may file a complaint with Catholic Charities or with the Secretary of the Department of Health and Human Services. To file a complaint with Catholic Charities, contact the program director or the Catholic Charities Privacy Officer. Contact information is listed at the end of this document. You will not be penalized for filing a complaint.

Thank you for taking the time to read this. If you have any questions or concerns, please feel free to talk to your service provider or program director. All requests as specified above should be directed to: Your Program Director Deborah Rambo (See the directory for program Privacy Officer contact information) or Catholic Charitable Bureau of the Archdiocese of Boston 75 Kneeland Street Boston, MA Phone #: 617-482-5440 Fax #: 617-451-0337

This document has been approved by the Board of Trustees of the Catholic Charitable Bureau of the Archdiocese of Boston, Inc. Catholic Charities reserves the right to make changes to this Notice without prior notification. Any changes or amendments beyond contact information must be approved by the board and will not be implemented until approval has been granted, and new documents have been printed.