Compliance / HIPAA
JOHN KNOX VILLAGE
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.
IF YOU HAVE ANY QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT THE JOHN KNOX VILLAGE CORPORATE COMPLIANCE OFFICER AT 816-347-2109.
This Notice of Privacy Practices (or “Notice”) describes how we will use and disclose protected health information (“PHI”) and data that we receive or create related to your healthcare. We understand that your PHI is personal to you, and we are committed to protecting the information about you. John Knox Village is an organization with a variety of services available to our residents and other clients. There are many departments that could access PHI for the performance of those services. These departments include, but are not limited to, Village Assisted Living, Village Assisted Living Memory Care, Village Hospice, Village Home Health, Village Helpers In-Home Care, Village Nursing, the Resident Wellness Clinic, Village Emergency Medical Service, the Fitness Centers and the Village Care Center. All of John Knox Village’s departments follow the terms of this Notice.
We are required by federal law and applicable state law, regulations, and other authorities to protect the privacy of your PHI and to provide you with this Notice. We are required to protect the confidentiality of your PHI and will disclose your PHI to a person other than you or your personal representative only when permitted under federal or state law. This protection extends to any PHI that is oral, written, or electronic, such as health information transmitted by facsimile, modem, or other electronic device. This Notice describes how we may use and disclose your health information. In some circumstances, as described in this Notice, the law permits us to use and disclose your PHI without your express permission. In all other circumstances, we will obtain your written authorization before we use or disclose your PHI. This Notice also describes your rights and the obligations we have regarding the use and disclosure of PHI. Under federal and applicable state law, we are required to follow the terms of the Notice currently in effect. YOU ARE NOT REQUIRED TO AUTHORIZE ADDITIONAL USES AND DISCLOSURES OF YOUR PHI.
Uses and Disclosures
How We May Use And Disclose Your PHI Without Your Permission
The following categories describe the different ways we may use and disclose (or release) your PHI without your permission.
- Treatment. We may use PHI while providing, coordinating, or managing your healthcare, including emergency treatment situations. For example: Information obtained by a nurse, physician, or other member of your health care team will be recorded in your record and used to determine the course of treatment that should work best for you. Your physician will document in your record his/her expectations for the members of your healthcare team (in the form of orders). Members of your healthcare team will then record the actions they took and their observations. In that way, the physician will know how you are responding to treatment. We will also provide your physician or subsequent healthcare provider with copies of various reports that should assist him/her in treating you once you are discharged or move to another level of care at John Knox Village or discharged to a hospital or another healthcare facility. In addition, we may disclose your PHI from time-to-time to another physician or healthcare provider (e.g. a specialist or laboratory) who, at the request of your physician, becomes involved in your care by providing assistance with your healthcare diagnosis or treatment.
- Payment. We may use and disclose medical information to obtain or provide compensation or reimbursement for providing your healthcare. For example: Your PHI will be used, as needed, to obtain payment for your healthcare services. This may include certain activities that your health payor may undertake before it approves or pays for healthcare services, such as making a determination of eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity and undertaking utilization review activities (e.g. obtaining approval for a stay may require that your relevant PHI be disclosed to obtain approval for that stay).
- Health Care Operations. Members of staff and/or quality improvement team may use information in your health record to assist the care and outcomes in your case and others like it. We may use and disclose your health information to deal with certain administrative aspects of your healthcare, to provide services and to manage our business more efficiently. For example: We may use or disclose, as needed, your PHI in order to support the business activities of John Knox Village. These activities include, but are not limited to, quality improvement activities, associate review activities, training of healthcare students, licensing, and conducting or arranging for other business activities. We may combine medical and other health information about many residents or patients to evaluate the need for new services or treatment. Members involved with quality improvement may use information in your health/medical record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the healthcare and services we provide. We may remove information that identifies you from combined sets of information to protect your privacy.
How We May Use And Disclose Your PHI In Other Special Circumstances
We are permitted under federal and applicable state law and are likely to use or disclose your PHI without your permission only when certain circumstances may, arise as described below.
- Business Associates. There are some services provided in our organization to you through other companies termed as “business associates.” Federal law requires us to enter into business associate agreements with these other companies to safeguard your PHI. Examples include temporary staffing agencies, physician services, laboratory services, therapy services, consultants and information technology vendors. When these services are contracted, we may disclose your health information to our business associate so that it can perform the job we have requested and then bill for services rendered.
- Fundraising. We may use certain information and may contact you for the purposes of raising funds. If you do not want us to use your information for fundraising purposes, you may notify us using the information listed at the end of this Notice.
- Individuals Involved In Your Care or Payment for Your Care. Unless you notify us that you object, we may disclose to a family member, other relative, a close personal friend or any other person you identify, health information relevant to that person’s involvement in your care or payment related to your care. If you are unable to agree to such a disclosure, we may disclose such information, as necessary, if we determine that it is in your best interest based on professional judgment. We may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, of your location and general condition.
- Public Health. We may disclose your PHI to federal, state, or local authorities, or other public entities charged with preventing or controlling disease, injury, or disability for public health activities. These activities may include the following: disclosures to notify individuals of exposure to a disease or risk for contracting or spreading a disease or condition.
- Facility Directories. Unless you notify us that you object and wish to “opt-out,” we may use and disclose in our facility directory your name, location in the facility, general condition (e.g. good, fair), and religious affiliation. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name. If you elect to “opt-out” of the directory, we will not acknowledge your presence at John Knox Village.
- Future Communications. We may communicate with you via newsletters, mailings, or other means regarding treatment options, health-related information, disease management programs, wellness programs, or other community-based initiatives or activities in which our facility is participating.
- Required By Law. We may use or disclose your PHI to the extent that law requires the use or disclosure. The use and disclosure will be made in compliance with the law and will be limited to the relevant requirements of the law. You will be notified, when required by law, of any such uses or disclosures. We will disclose health information to the following entities, including but not limited to:
- The U.S Food and Drug Administration
- Public health or legal authorities charged with preventing or controlling disease, injury or disability
- Correctional institutions (if you are in custody of the correctional institution or a law enforcement officer
- Worker’s compensation agents
- Organ and tissue donation organizations
- Military command authorities
- Health oversight agencies
- Funeral directors, coroners, medical examiners
- National security and intelligence agencies
- Protective services for the president of the United States and others
- Organ Donation. Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs for the purpose of tissue donation and transplant.
- Research. If you are participating in a research protocol, please notify John Knox Village. Your medical information will not be released for a research project unless you consent in writing or, in the case of pre-study evaluation, an authorized Institutional Review Board has issued a waiver of authorization for review of records at the John Knox Village.
- Military, National Security, or Incarceration/Law Enforcement Custody. If you are involved with the military, national security or intelligence activities, or you are in the custody of law enforcement officials or an inmate in a correctional institution, we are permitted to release your health information to the proper authorities so they may carry out their duties under the law. We are permitted to release medical information about you to authorized federal officials so that they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
- Workers’ Compensation. We are permitted to disclose your health information to the appropriate persons in order to comply with the laws related to worker’s compensation or other similar programs.
We May Use Or Disclose Your PHI For Other Purposes Only With Your Authorization
We will obtain your valid written authorization before using or disclosing your PHI for purposes other than those described above (or as otherwise permitted or required by law) including before using or disclosing your PHI for marketing purposes or in exchange for remuneration and before using and disclosing your psychotherapy notes under certain circumstances. You may revoke this authorization at any time by submitting a written notice to our Compliance Officer at the address listed below. If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by your authorization. Understandably, we are unable to rescind any disclosure we have already made with your authorization.
YOUR HEALTH INFORMATION RIGHTS
Although your health record is the physical property of John Knox Village, you have the right to:
- Inspect and Copy health information that may be used to make decisions about your care. You have the right to access and copy your PHI contained in the “designated record set,” which includes medical and billing records. We will respond to your request in writing within 30 days (with a possible 30-day extension). You also have the right to request an electronic copy of your PHI. If your PHI is not readily producible in such an electronic form or format, we will provide your PHI in a readable electronic form and format as agreed to by you and John Knox Village. A fee may be charged for the expense of fulfilling your request. We may deny your request to inspect and copy, in certain very limited circumstances, such as if we have reasonably determined that providing access to PHI would endanger your life or safety or cause substantial harm to you or another person. If you are denied access to medical information, you may request that the denial be reviewed in some situations. Another licensed professional chosen by John Knox Village will review your request and the denial. The person conducting the review will not be the same person that denied your request. We will comply with the outcome of the review. To inspect or copy your PHI, submit a written request to our Compliance Officer.
- Request an amendment. If you feel that health information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for John Knox Village. To request an amendment, submit a written request to our Compliance Officer. Request must identify: (i) which information you seek to amend, (ii) what corrections you would like to make, and (iii) why the information needs to be amended. We will respond to your request in writing within 60 days (with a possible 30-day extension). In our response, we will either: (i) agree to make the amendment, or (ii) inform you of our denial, explain our reason, and outline appeal procedures, if applicable.
- An accounting of disclosures. This right applies to disclosures for purposes other than treatment, payment or healthcare operations as described in this Notice. Not all health information is subject to this request. For example, it excludes disclosures we may have made for a facility directory, to family members or friends involved in your care, disclosures authorized by you or for notification purposes. To obtain an accounting, submit a written request to our Compliance Officer. Requests must specify the time period, not to exceed six years, for which you would like to receive the accounting. We will respond in writing within 60 days of receipt of your request (with a possible 30-day extension). We will notify you in advance of the cost involved, and you may choose to withdraw or modify your request at that time.
- Request restrictions or limitations on the health/medical information we use or disclose about you for treatment, payment, or healthcare operations. You also have the right to request a limit on the information we disclose about you to someone who is involved in your care or the payment for your care such as a family member or friend by submitting a written request to our Compliance Officer. For example, you could ask that we not use or disclose information about a surgery that you had. You must identify in this request: (i) what particular information you would like to limit, (ii) whether you want to limit use, disclosure, or both, and (iii) to whom you want the limits to apply. All requests will be carefully considered, but we are not required to agree to those restrictions, except in certain circumstances. We will provide you with a written response to your request within 30 days. If we do agree to restrict use or disclosure of your PHI, we will not apply these restrictions in the event of an emergency. We also have the right to terminate the restriction if: (i) you agree orally or in writing, or (ii) we inform you of the termination, which becomes effective only with respect to your PHI created or received after we inform you of the termination. All requests for restrictions must include your full name, date of birth, and address.
- Request confidential communications. You have the right to request that we communicate with you about your healthcare matters in a certain way or at a certain location. For example, you may ask that we contact you by mail at home or at work. John Knox Village will strive to grant requests for confidential communications at alternative locations and/or via alternative means only if the request is made in writing and the written request includes a mailing address where you will receive bills for services rendered and related correspondence regarding payment for services. Please realize that we reserve the right to contact you by other means and at other locations if you fail to respond to any communication from us that requires a response. We will notify you in accordance with your original request prior to attempting to contact you by other means or at another location.
- A paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still required to a paper copy of this notice. You may obtain a copy of this notice at our website at jkv.org. To exercise any of your rights, please obtain the required forms from the Corporate Compliance Officer and submit your request in writing.
- Restriction on disclosure of PHI when paying out of pocket. You have the right to request a restriction on the disclosure of your PHI (for payment or healthcare operations) to your health plan when you have paid for the service or item in question completely out of pocket in full by submitting a written request to our Corporate Compliance Officer. We are required to agree to this restriction. We will provide you with a written response to your request within 30 days. All requests for PHI must include your full name, date of birth, and address.
- Breach Notification. You have the right to be notified when a breach of your unsecured PHI has occurred. We will provide you with such notification as soon as information regarding the breach is available.
Our contact person for all questions, requests, or for further information related to the privacy of your health information is:
Corporate Compliance Officer
400 N.W. Murray Road
Lee’s Summit, MO 64081
If you believe your privacy rights have been violated, you can file a complaint with the Corporate Compliance Officer of John Knox Village (400 N.W. Murray Road., Lee’s Summit, Missouri 64081) and/or with the Secretary, Department of Health and Human Services (200 Independence Avenue SW, Washington, D.C. 20201).
Changes to This Notice
We reserve the right to change our practices and Notice, and to make the new provisions effective for all PHI we maintain. Any revision to our privacy practices will be described in a revised Notice that will be distributed and posted prominently at various locations in our organization (including our web site).
A copy of the current Notice in effect is always available upon request. Requests are to be made to the Corporate Compliance Officer at (816) 347-2109.
JOHN KNOX VILLAGE CODE OF CONDUCT
Effective Date: This version’s effective date is April 20, 2022.