Privacy Policy & Notice of Privacy Practices

A. Our Commitment to Your Privacy

Our practice is dedicated to maintaining the privacy of your individually identifiable health information, referred to as IIHI. In conducting our business, we will create records regarding you and the treatment and services we provide to you. We are required by law to maintain the confidentiality of health information that identifies you. We are also required by law to provide you with this notice of our legal duties and the privacy practices that we maintain in our practice concerning your IIHI. By federal and state law, we must follow the terms of the notice of privacy practices that we have in effect at the time.

We realize that these laws are complicated, but we must provide you with the following important information:

• How we may use and disclose your IIHI
• Your privacy rights in your IIHI
• Our obligations concerning the use and disclosure of your IIHI

The terms of this notice apply to all records containing your IIHI that are created or retained by our practice. We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this notice will be effective for all of your records that our practice has created or maintained in the past, and for any of your records that we may create or maintain in the future. Our practice will post a copy of our current Notice in our offices in a visible location at all times, and you may request a copy of our current Notice at any time.

B. Questions About This Notice

If you have questions about this notice or our health information privacy policies, please contact:

Privacy Officer, AMS Cardiology

Phone: 215-517-1000

Welsh Road, Horsham, PA 19044

Website: amscardiology.com

C. How We May Use and Disclose Your IIHI

The following categories describe the different ways in which we may use and disclose your IIHI.

1. Treatment

Our practice may use your IIHI to treat you. For example, we may ask you to have laboratory tests (such as blood or urine tests), and we may use the results to help us reach a diagnosis. We might use your IIHI in order to write a prescription for you, or we might disclose your IIHI to a pharmacy when we order a prescription for you. Many of the people who work for our practice — including, but not limited to, our doctors and nurses — may use or disclose your IIHI in order to treat you or to assist others in your treatment. Additionally, we may disclose your IIHI to others who may assist in your care, such as your spouse, children, or parents. Finally, we may also disclose your IIHI to other health care providers for purposes related to your treatment.

2. Payment

Our practice may use and disclose your IIHI in order to bill and collect payment for the services and items you may receive from us. For example, we may contact your health insurer to certify that you are eligible for benefits and we may provide your insurer with details regarding your treatment to determine if your insurer will cover or pay for your treatment. We also may use and disclose your IIHI to obtain payment from third parties that may be responsible for such costs, such as family members. Also, we may use your IIHI to bill you directly for services and items. We may disclose your IIHI to other health care providers and entities to assist in their billing and collection efforts.

3. Health Care Operations

Our practice may use and disclose your IIHI to operate our business. As examples, our practice may use your IIHI to evaluate the quality of care you received from us or to conduct cost-management and business planning activities for our practice. We may disclose your IIHI to other health care providers and entities to assist in their health care operations.

4. Appointment Reminders

Our practice may use and disclose your IIHI to contact you and remind you of an appointment, including via phone, email, or SMS as described in Part Two of this policy.

5. Treatment Options

Our practice may use and disclose your IIHI to inform you of potential treatment options or alternatives.

6. Health-Related Benefits and Services

Our practice may use and disclose your IIHI to inform you of health-related benefits or services that may be of interest to you.

7. Release of Information to Family and Friends

Our practice may release your IIHI to a friend or family member that is involved in your care or who assists in taking care of you, such as a spouse or caregiver accompanying you to an appointment.

8. Disclosures Required by Law

Our practice will use and disclose your IIHI when we are required to do so by federal, state, or local law.

D. Use and Disclosure in Certain Special Circumstances

The following categories describe unique scenarios in which we may use or disclose your identifiable health information:

1. Public Health Risks

Our practice may disclose your IIHI to public health authorities authorized by law to collect information for purposes such as:

• Maintaining vital records, such as births and deaths
• Reporting child abuse or neglect
• Preventing or controlling disease, injury, or disability
• Notifying a person regarding potential exposure to a communicable disease
• Reporting reactions to drugs or problems with products or devices
• Notifying individuals if a product or device they may be using has been recalled
• Notifying appropriate government agencies regarding potential abuse or neglect of an adult patient, including domestic violence, where required or authorized by law
• Notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance

2. Health Oversight Activities

Our practice may disclose your IIHI to a health oversight agency for activities authorized by law, including investigations, inspections, audits, surveys, licensure, and disciplinary actions.

3. Lawsuits and Similar Proceedings

Our practice may use and disclose your IIHI in response to a court or administrative order if you are involved in a lawsuit or similar proceeding. We also may disclose your IIHI in response to a discovery request, subpoena, or other lawful process, but only if we have made an effort to inform you of the request or to obtain a court or administrative order protecting the information.

4. Law Enforcement

We may release IIHI if asked to do so by a law enforcement official:

• Regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement
• Concerning a death we believe has resulted from criminal conduct
• Regarding criminal conduct at our offices
• In response to a warrant, summons, court order, subpoena, or similar legal process
• To identify or locate a suspect, material witness, fugitive, or missing person
• In an emergency, to report a crime including the location or victim(s) of the crime, or the description, identity, or location of the perpetrator

5. Deceased Patients

Our practice may release IIHI to a medical examiner or coroner to identify a deceased individual or to identify the cause of death. If necessary, we also may release information in order for funeral directors to perform their jobs.

6. Organ and Tissue Donation

Our practice may release IIHI to organizations that handle organ, eye, or tissue procurement or transplantation, including organ donation banks, as necessary to facilitate organ or tissue donation and transplantation if you are an organ donor.

7. Research

Our practice may use and disclose your IIHI for research purposes in certain limited circumstances. We will obtain your written authorization to use your IIHI for research purposes except when an Internal Review Board or Privacy Board has determined that the waiver of your authorization satisfies applicable requirements, including that the use or disclosure involves no more than minimal risk to your privacy, an adequate plan exists to protect identifiers from improper use, and adequate written assurances exist that the PHI will not be re-used or disclosed inappropriately.

8. Serious Threats to Health or Safety

Our practice may use and disclose your IIHI when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.

9. Military

Our practice may disclose your IIHI if you are a member of U.S. or foreign military forces (including veterans) and if required by the appropriate military authorities.

10. National Security

Our practice may disclose your IIHI to federal officials for intelligence and national security activities authorized by law. We also may disclose your IIHI to federal officials in order to protect the President, other officials, or foreign heads of state, or to conduct investigations.

11. Inmates

Our practice may disclose your IIHI to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official. Disclosure for these purposes would be necessary: (a) for the institution to provide health care services to you, (b) for the safety and security of the institution, and/or (c) to protect your health and safety or the health and safety of other individuals.

12. Workers’ Compensation

Our practice may release your IIHI for workers’ compensation and similar programs as authorized by law.

E. Your Rights Regarding Your IIHI

You have the following rights regarding the IIHI that we maintain about you:

1. Confidential Communications

You have the right to request that our practice communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home rather than at work. To request a type of confidential communication, you must make a written request to the Privacy Officer at AMS Cardiology, specifying the requested method of contact or the location where you wish to be contacted. Our practice will accommodate reasonable requests. You do not need to give the reason for your request.

2. Requesting Restrictions

You have the right to request a restriction in our use or disclosure of your IIHI for treatment, payment, or health care operations. Additionally, you have the right to request that we restrict our disclosure of your IIHI to only certain individuals involved in your care or the payment for your care, such as family members and friends. We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you. Requests must be submitted in writing to the Privacy Officer at AMS Cardiology and must describe: (a) the information you wish restricted; (b) whether you are requesting to limit our use, disclosure, or both; and (c) to whom you want the limits to apply.

3. Inspection and Copies

You have the right to inspect and obtain a copy of the IIHI that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes. You must submit your request in writing to the Privacy Officer at AMS Cardiology. Our practice may charge a fee for the costs of copying, mailing, labor, and supplies associated with your request. Our practice may deny your request in certain limited circumstances; however, you may request a review of our denial.

4. Amendment

You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our practice. Requests must be made in writing to the Privacy Officer at AMS Cardiology, including a reason that supports your request for amendment. Our practice may deny your request if the information is, in our opinion, accurate and complete, not part of the IIHI kept by or for the practice, not part of the IIHI you would be permitted to inspect and copy, or not created by our practice.

5. Accounting of Disclosures

You have the right to request an “accounting of disclosures” — a list of certain non-routine disclosures our practice has made of your IIHI for non-treatment, non-payment, or non-operations purposes. To obtain an accounting of disclosures, you must submit your request in writing to the Privacy Officer at AMS Cardiology. Requests must state a time period no longer than six (6) years from the date of disclosure and may not include dates before April 14, 2003. The first list you request within a 12-month period is free of charge; our practice may charge you for additional lists within the same 12-month period.

6. Right to a Paper Copy of This Notice

You are entitled to receive a paper copy of our Notice of Privacy Practices at any time. To request a paper copy, contact the Privacy Officer at AMS Cardiology.

7. Right to File a Complaint

If you believe your privacy rights have been violated, you may file a complaint with our practice or with the Secretary of the Department of Health and Human Services. To file a complaint with our practice, contact the Privacy Officer at AMS Cardiology in writing. You will not be penalized for filing a complaint.

8. Right to Provide or Revoke Authorization

Our practice will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law. Any authorization you provide to us regarding the use and disclosure of your IIHI may be revoked at any time in writing. After you revoke your authorization, we will no longer use or disclose your IIHI for the purposes described in the authorization. Please note we are required to retain records of your care.