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Introduction
President Mark Stutrud has determined that Lutheran Social Services of Michigan
(LSSM) is a Covered Entity under the Administrative Simplification Subtitle of the
Health Insurance Portability and Accountability Act of 1996 (HIPAA). Because LSSM
provides both covered and non-covered functions, Mark Stutrud has designated the
agency as a "Hybrid Entity." As such, HIPAA will only apply to the agency's health
care components that bill electronically (as defined in HIPAA) and its non-covered
functions that the agency has chosen to include. Additionally, Mark Stutrud has
designated LSSM and Lakeview Lutheran Manor, a separate wholly-owned subsidiary
licensed nursing home of LSSM, as an Affiliated Covered Entity (ACE). The following
units of LSSM are designated as HIPAA covered functions:
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- Lakeview Lutheran Manor, Cadillac, MI
- Luther Haven, Detroit, MI
- Luther Home, Grand Rapids, MI
- Luther Woods, Grand Rapids, MI
- Luther Manor, Saginaw, MI
- Child & Family Services – West Michigan
- Persons with Disabilities, all units throughout MI
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Persons wishing more information about LSSM's privacy activities may contact the
agency's HIPAA Privacy Officer Ben Robinson, Senior Vice President. Persons wishing
more information about the LSSM's security activities may contact the agency's HIPAA
Security Officer Frank Sellgren, Director of Information Technology. Please see
the following Notice of Privacy Practices.
LUTHERAN SOCIAL SERVICES OF MICHIGAN NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES
HOW HEALTH 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 Director of Corporate
Compliance at (800) 421-3062 or (313) 823-7700.
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OUR PLEDGE REGARDING HEALTH INFORMATION
Lutheran Social Services of Michigan ("LSSM") is committed to protecting health
information about you. This Notice describes LSSM's privacy practices and that of
all its departments, units, employees, staff, volunteers, and other personnel. This
Notice will tell you about the ways in which we may use and disclose health information
about you. It also describes your rights and certain obligations we have regarding
the use and disclosure of health information. We are required by law to:
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Appointment Reminders. We may use and
disclose health information to contact you as a reminder that you have an appointment
for treatment or health care at LSSM.
Treatment Alternatives. We may use and
disclose health information to tell you about, or recommend, possible treatment
options or alternatives that may be of interest to you.
Health-Related Benefits and Services
- We may use and disclose health information to tell you about health-related benefits
or services that may be of interest to you.
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Give you this Notice of our legal duties and privacy practices with respect to health
information about you;
- Make sure that health information that identifies you is kept private; and
- Follow the terms of the Notice that is currently in effect.
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Individuals Involved in Your Care or Payment for Your Care. We may release health
information about you to a close personal friend or family member who is with you
and is involved in your health care or payment for your care, so long as you have
not objected and it is reasonable for us to infer that such disclosure is in your
best interests.
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HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU
The following categories describe different ways we use and disclose health information.
For each category we will explain what we mean and try to give some examples. Not
every use or disclosure in a category will be listed. However, all of the ways we
are permitted to use and disclose information will fall within one of the categories. |
Facility Directory. Unless you tell us
otherwise, we may disclose facility directory information which is your location
and general condition (fair, stable, etc.) to callers who ask for you by name. Also,
unless you tell us otherwise, we may disclose your religious affiliation to clergy.
Fundraising.
We may use limited demographic information about you to contact you regarding fundraising
opportunities at LSSM, unless you tell us you do not wish to receive such communications.
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Treatment.
We may use and disclose health information about you to provide you with health
treatment or services. For example, your primary care physician may need to know
about treatment you received at LSSM in order to coordinate other treatments you
are receiving.
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Research. We may disclose health information
about you if the disclosure has been approved by an Institutional Review Board or
similar privacy board. We may also disclose limited health information about you
to preparatory to research so long as the information does not leave LSSM.
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Payment. We may use and disclose health
information about you so that the treatment and services you receive at LSSM may
be billed and payment may be collected from you, an insurance company or a third
party. For example, we may need to give your health plan information about treatment
you received at LSSM so your health plan will pay us or reimburse you the treatment.
Health Care Operations. We may use and
disclose health information about you for Health Practice operations. These uses
and disclosures are necessary to run LSSM and make sure that all of our patients
receive quality care. For example, we may use health information to review our treatment
and services and to evaluate the performance of our staff in caring for you.
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Special Purposes When Permitted or Required by Law.
We may disclose health information about you as for special purposes when permitted
or required by law, including the following:
- To avert a serious threat to health or safety against you, the public or another
person.
- For public health and administrative oversight activities such as disease control,
abuse or neglect reporting, health and vital statistics, audits, investigations,
and licensure reviews.
- For organ and tissue donation and transplant to facilitate organ or tissue donation
and transplant.
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- To workers' compensation or similar programs for the payment of benefits for work-related
injuries.
- To coroners, health examiners and funeral directors to identify a deceased person,
determine cause of death, or to carry out duties.
- To comply with court orders, judicial proceedings, or other legal processes related
to law enforcement, custody of inmates, legal and administrative actions, and criminal
activity.
- For U.S. military and veteran reporting regarding members and veterans of the armed
forces of U.S. or foreign military.
- For national security and intelligence activities such as protective services for
the President and other authorized persons.
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We are not required by law to agree to your request. We will not amend your health
information if this information was not created by LSSM, or if it not part of your
health care record, or if the information is accurate and complete.Your Right to
an Accounting of Disclosures. You have the right to request an "accounting of disclosures."
This is a list of certain disclosures we made of health information about you. Your
request must state a time period. We may limit the time period to 6 years and to
disclosures made on or after April 14, 2003. The first list you request within a
12-month period is free. For additional lists, we may charge you for the costs of
providing the list.Your Right to Request Restrictions. You have the right to request
a restriction or limitation on the health information we use or disclose about you.
We are not required by law to agree to your request. If we do agree, we will comply
with your request unless the information is needed to provide you emergency treatment.
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State and Other Federal Laws. In addition,
LSSM must also comply with applicable state and other federal laws. For example,
under Michigan law, LSSM must obtain written consent from a patient before disclosing
substance abuse treatment information for even treatment and payment purposes, except
in emergencies. LSSM will continue to abide by these and other applicable state
and federal laws.
Other Uses of Health Information Require an Authorization.
Other uses and disclosures of health information not covered by this Notice or the
laws that apply to us will be made only with your written authorization. If you
provide us an authorization to use or disclose health information about you, you
may revoke that authorization, in writing, at any time. If you revoke your authorization,
we will no longer use or disclose health information about you for the reasons covered
by the written authorization. You understand that we are unable to take back any
disclosures we have already made with your authorization, and that we are required
to retain our records of the care that we provide to you. |
Your Right to Request Confidential Communications.
You have the right to request that we communicate with you about health matters
in a certain way or at a certain location. For example, you can ask that we only
contact you at work or by mail. We will not ask you the reason for your request.
We will accommodate all reasonable requests.
Right to Paper Copy of this Notice. You
have the right to a paper copy of this Notice. 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, or you have a complaint about our privacy
practices, we encourage you to file a complaint with LSSM.
Lutheran Social Services of Michigan
Attn: Director of Corporate Compliance
8131 E. Jefferson
Detroit, MI 48214
(800) 421-3062
bsing@LSSM.org
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YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU
You have many rights with regard to your health information. If you wish to exercise
any of these rights, please submit your request in writing to respective division
director or vice president. You can find the up-to-date contact information on our
contact page.
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You may also file a compliant directly with the Secretary of the Department of Health
and Human Services. You will not be penalized in any way for filing a complaint.
CHANGES TO THIS NOTICE
We reserve the right to change this Notice. We reserve the right to make the revised
or changed Notice effective for health information we already have about you as
well as any information we receive in the future. We will post a copy of the current
Notice at LSSM and make copies available upon request. |
Right to Inspect and Copy. You have the
right to inspect and copy health information that may be used to make decisions
about your care. We may charge a reasonable fee for the costs of copying, mailing
or other supplies associated with your request.
Your Right to Amend 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 add a statement. You must provide
a reason that supports your request for an amendment.
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