HIPAA Privacy Notice

Top Cardiology Associates of Michigan (TCAM) is committed to protecting the privacy of your medical information. As a patient of TCAM, the care and treatment you receive is recorded in an electronic medical record (EMR). To best meet your medical needs, we share your medical record with all the health care providers involved in your care. We share your information only to the extent necessary to perform our jobs, to collect payment for the services we provide you and to comply with the laws that govern health care. We will not use or disclose your information for any other purpose without your permission.

Notice of Privacy Practices

Effective Date: January 19, 2015

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO SUCH MEDICAL INFORMATION. PLEASE REVIEW IT CAREFULLY. THE PRIVACY OF YOUR MEDICAL INFORMATION IS IMPORTANT TO US.

OUR RESPONSIBILITY TO PROTECT YOUR PRIVACY

We are required by state and federal laws to maintain the privacy of your medical information, or protected health information (PHI). The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law that provides protection for the privacy and security of PHI. HIPAA also requires us to give you this Notice about our privacy practices, our legal duties and explaining your rights. We must follow the practices in this Notice while it is in effect. This Notice takes effect December 1, 2019, and will remain in effect until we replace it.

USES & DISCLOSURES OF PROTECTED HEALTH INFORMATION

There are uses and disclosures permitted by HIPAA that do not require obtaining prior written consent to carry out the activities listed below:

*note: these examples are not meant to be exhaustive, but to describe the types of uses and disclosures that may be made by our office.

Treatment: We will use and disclose your PHI to provide, coordinate or manage your medical care and any related services in our facility. This includes sharing your medical information as necessary with others involved in your healthcare such as a home health agency, hospitals, hospices, nursing homes, doctors, nurses, physician assistants, residents, medical and nursing students, therapists, technicians, volunteers, emergency service and transportation providers, medical equipment providers, pharmacies, and others involved in your care that may not be listed.

Payment: Your PHI will be used to obtain payment for your healthcare services. We may share your information with a billing company or with your health insurance plan to obtain prior authorizations which will approve or deny services. This may include certain actions that your plan may take before it approves or pays for the services we recommend. You do have the right to request information not to be shared with your insurance company or third party payor if you make a request in writing about a specific treatment or service in advance, and you pay for the services in full before we provide the specific treatment or service to you.

Healthcare operations: we will share your PHI with third party “business associates” that perform various activities (e.g., billing, transcription services, remote cardiac monitoring services, legal and auditing services) as long as they agree to protect the privacy of that information for business management and planning purposes.

Appointment Reminders: we may use your PHI to contact you and remind you about upcoming appointments by mail, text message, email and telephone.

On-Site Contacts: we may call your name when the provider is ready to see you. We may also ask you to write your name on a sign-in sheet. We will take reasonable precautions to protect your privacy.

Individuals involved in your care or Payment for Care: We will only disclose medical information about you to a friend or family member or any other person you identify on your HIPAA form that’s filled out for our office. You have the right to revoke such consent in writing. Any use of disclosure that has already occurred prior to the date on which your revocation of consent is received will not be affected.

Administrative oversight: we may use and disclose medical information related to activities such as accreditations, audits, investigations, licensure, or determining cause of death.

Law enforcement and legal mandates: we may use or disclose your PHI when required to do so by law.

National Security and Intelligence Activities: we may disclose PHI to authorized federal officials for intelligence, counterintelligence and other national security activities as authorized by law.

Workers compensation or other rehabilitative activities: we may disclose PHI about you as required by law or insurers to provide benefits for work-related or victim injuries or illnesses for you.

Coroners, Medical Examiners, and Funeral Directors: we may release PHI to a coroner, medical examiner or funeral director.

Inmates: we may release PHI about you to the correctional institution or law enforcement official if you are in a correctional facility or under custody or a law enforcement official.

CHANGES TO OUR NOTICE

We reserve the right to change our privacy practices and the terms of this Notice at any time. A copy of our current Notice will be on our website and available to all patients. You may request a copy of our Notice (or any subsequent revised Notice) at any time.

PATIENT RIGHTS

Access: you have the right to review, inspect or receive a copy of the PHI that we keep about you. Requests must be written and may be done using our record request form available online and in the office. You will be asked to come back and pick up records when ready.

Accounting of Disclosures: you have the right to receive a list of medical information disclosures, except for disclosures related to treatment, payment or healthcare operations that do not require your consent. Requests must be written and may be for a time-period up to six years from the date of disclosure. The first request in a 12-month period is free. After that, we may charge for additional requests.

Restriction Requests: you have the right to submit a written request that we place additional restrictions on our use or disclosure of your PHI. We are not required to agree to these additional restrictions, but if we do, we will send you a written response informing you of our ability to honor your request.

Confidential Communication: you have the right to request that we communicate with you in a confidential manner, such as at work rather than at home. Request must be in writing. We must accommodate your request if it is reasonable, specifies the alternative means or location, and permits us to continue to bill and collect payment from you.

Amendment: you have the right to submit a written request to amend your medical information, if you believe that information in your medical record is incorrect or that information is missing. We may deny the request if it is not in writing or if it does not include a reason to support the request. Requests may also be denied if our information is complete and accurate, if it was not created by us, or if the information is not part of the medical information kept by or for us. We cannot remove or change the information in the record. If your request is granted, we will add in supplemental information by an addendum.

Electronic Notice: if you receive this notice on our website, you are entitled to receive this notice in written form. Please contact us using the information listed at the end of this notice to obtain this notice in written form.

QUESTIONS AND COMPLAINTS

If you want more information about our privacy practices or have questions or concerns, please contact us using the information below. If you believe that we may have violated your privacy rights, or you disagree with a decision we made about access to your protected health information or in response to a request you made, you may complain to us using the contact information below. You also may submit a written complaint to the U.S. Department of Health and Human Services. We will provide you with the address to file your complaint with the U.S. Department of Health and Human Services upon request. You will not be retaliated against in any way for exercising your rights.

Requests, questions and concerns may be submitted via:

Mail: Information Privacy & Security Office, 43475 Dalcoma Dr. STE 200, Clinton Township, MI 48038

Fax: (586) 228-2517