Doc2Go, an affiliate of The MetroHealth System
2500 MetroHealth Drive
Cleveland, OH 44109
THIS NOTICE DESCRIBES HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION TO CARRY OUT TREATMENT, PAYMENT OR HEALTH CARE OPERATIONS AND FOR OTHER PURPOSES PERMITTED OR REQUIRED BY LAW. IT ALSO DESCRIBES YOUR RIGHTS TO ACCESS AND CONTROL YOUR PROTECTED HEALTH INFORMATION.
“Protected Health Information” is information about you, including demographic information (e.g. name, address, other contact information such as phone numbers and email address, age, gender, and date of birth), that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services.
If you have any questions about this notice, please contact Doc2Go’s Privacy Office at (216) 778-3101. We may contact you regarding your Protected Health Information and healthcare through any means deemed appropriate, including by telephone, email and text message.
The following describes the ways that we use and disclose health information that identifies you. Except for the purposes described below, we will use and disclose your health information only with authorization.
For Treatment. We may use health information about you to provide, coordinate or manage your medical treatment or services. We may disclose medical information about you to doctors or other health care providers who are involved in taking care of you. We may share medical information about you to supply the things you need, such as prescriptions or lab work. We also may disclose medical information about you to people outside of Doc2Go such as a health care provider who may be involved in your medical care, family members, or others that are part of your care.
For Health Care Operations. We may use and disclose medical information about you for health care operations. This may include sharing information with The MetroHealth System or other third-party organizations involved in providing you services or payment processing. These uses and disclosures are needed to run Doc2Go and make sure that all our members receive quality care. For example, we may use medical information to review our treatment and services and to review the services provided by our staff in caring for you. We may also combine the medical information we have with medical information from other health care providers to compare how we are doing and see where we can make changes in the care and services that we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.
Health Information Exchange. We may also share Protected Health Information about you with other non-Doc2Go providers. The disclosure of your Protected Health Information to non- Doc2Go providers may be done electronically through a Health Information Exchange [HIE] that allows providers involved in your care to access some of your Doc2Go records to coordinate services for you. We may make your medical information available electronically through an electronic HIE to other health care providers and health plans that request your information for their treatment and payment purposes. We may share your Protected Health Information in a community-wide information system for the purposes of diagnosis, treatment and care coordination. Other health care providers may access your Protected Health Information through this system as part of your treatment. The approved HIE maintains appropriate safeguards to protect the privacy and security of your Protected Health Information. Only authorized individuals may access your Protected Health Information from the HIE. If you or your personal representative do not wish to have your Protected Health Information shared with a HIE, please contact Doc2Go’s Privacy Officer who can assist you in this request. You have a right to request in writing that Doc2Go not disclose your Protected Health Information to the HIE or that Doc2Go not disclose specific categories of your Protected Health Information to the HIE. Your request will be honored by Doc2Go. Please be aware that any restrictions on the disclosure of your Protected Health Information to an HIE may result in a health care provider not having access to information that is necessary for that provider to render appropriate care. Contact Doc2Go’s Privacy Officer for questions or concerns.
Appointment Reminders. We may use and disclose medical information to contact you to remind you of an appointment for treatment or medical care at Doc2Go, as applicable.
Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options that may be of interest to you.
Health-Related Benefits and Services. We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.
Individuals Involved in Your Care or Payment for Your Care. We may release medical information about you to a friend or family member who is involved in your medical care. We may also give information to someone who helps pay for your care. You may object to having your medical information given to a friend or family member who is involved in your medical care.
Business Associates. Individuals or organizations that are not part of Doc2Go may provide services related to your care and/or Doc2Go’s operations, including its affiliate, The MetroHealth System. Such services may include things like billing or providing medical devices related to your treatment. We will disclose medical information as needed so the appropriate service can be rendered. We will obtain assurances that these individuals or organizations will also safeguard your information and protect your privacy and the security of your information.
Marketing. In most circumstances, we are required to get your written authorization before we use or disclose your Protected Health Information for marketing purposes. We will not sell our member lists, sell Protected Health Information or disclose your Protected Health Information to a third party for marketing purposes where we receive any form of payment without the appropriate written authorization. We may give you information that would encourage you to purchase or use a product that Doc2Go is currently using. We are not required to obtain your permission if we are giving you a gift of nominal value. If the gift were to involve a direct or indirect payment to Doc2Go from a third party, we must obtain your permission that would state such a payment is involved. We are not required to obtain your permission if we are communicating with you face to face. Authorization is required for any disclosure that constitutes the sale of Protected Health Information.
Research. Participation in clinical research studies may be an option available to you as a member of Doc2Go. Your doctors often are aware of newer treatments that may be available only under research protocols. However, in order to determine whether these treatments are applicable to you, we may need to review your medical records from time to time. Prior to approval, all research protocols must be reviewed by an independent committee to assure, among other things, that the privacy of your medical information is protected. Our doctors and/or affiliated personnel may view your medical information to determine if a research protocol is practical or to determine whether you would be a candidate for it. The medical information they review does not leave Doc2Go’s medical record. Only our doctors and affiliated personnel will review your medical record and none of your Protected Health Information will be disclosed to third parties without your specific authorization. If it is preliminarily determined that you may be eligible for treatment under a research protocol and that such treatment may be beneficial to you, your doctor or a member of our staff will contact you with further information.
As Required By Law. We will disclose medical information about you when required to do so by federal, state or local law. This may include disclosures to Boards governing the professional practice of health care providers such as the State Medical Board. Disclosure of highly sensitive information such as an individual who has taken an HIV test, the results of an HIV test, and the identity of an individual with AIDS will only be released as mandated by law or authorized by the individual.
To Avert a Serious Threat to Health or Safety. We may use and disclose medical about you when needed 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.
If the breach involves 10 or more members whose contact information is out of date we will post a notice of the breach on our website or in a major print or broadcast media.
Organ and Tissue Donation. If you are an organ donor, we may release medical information to places that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as needed to help with organ or tissue donation and transplantation.
Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the proper foreign military authority.
Workers’ Compensation. We may release medical information about you for workers’ compensation or similar programs. These programs provide benefits for work related injuries or illness.
Health Oversight Activities. We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are needed for the government to monitor the health care system, government programs, and compliance with laws and regulations.
Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may disclose medical information to defend a lawsuit brought against Doc2Go or any of its staff. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
Emergency Circumstances. We may release medical information about you if you are unable to object due to incapacity or if there is a need for emergency treatment. We may also disclose some or all your personal health information if it is in your best interest, which would be determined by Doc2Go in the exercise of professional judgment.
Coroners, Medical Examiners and Funeral Directors. We may release medical information to a coroner or medical examiner. This may be needed, for example, to identify a deceased person or determine the cause of death. Medical information about a person deceased for more than 50 years is not Protected Health Information.
National Security and Intelligence Activities. We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
Protective Services for the President and Others. We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.
Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.
You have the following rights regarding medical information we maintain about you:
Right to Inspect and Copy. You have the right to inspect and copy your health information contained in your designated record set, which is the information that may be used to make decisions about your care. Usually, this includes medical and billing records, but does not include information gathered in anticipation of a legal proceeding and information prohibited by law. To inspect and copy your health information contained in the designated record set, you must submit your request in writing to Medical Records, 2500 MetroHealth Drive, Cleveland, Ohio 44109. If you request a copy of the information, we may charge a reasonable fee for the costs of copying, mailing or costs incurred in responding to your request. We may deny your request to inspect and copy of records in limited cases. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by Doc2Go will review your request and the denial. The person doing the review will not be the person who denied your request. We will comply with the outcome of the review.
Right to an Electronic Copy of Medical Records. If your Protected Health Information is maintained in an electronic format (known as an electronic medical record or an electronic health record), you have the right to request that an electronic copy of your record be given to you or transmitted to another individual or entity. We will make every effort to provide access to your Protected Health Information in the form or format you request, if it is readily producible in such form or format. If the Protected Health Information is not readily producible in the form or format you request your record will be provided in either our standard electronic format or if you do not want this form or format, a readable hard copy form. We may charge you a reasonable, cost-based fee for the labor associated with transmitting the electronic medical record.
If your request is granted, Doc2Go will make the amendment and inform you when it is done. If your request is denied, we will provide you with a written denial stating the basis for denial. You have the right to submit a written statement disagreeing with the denial. Doc2Go must act on a request no later than 60 days after receipt of your request or notify you in writing that we need an additional 30 days.
Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures”. This is a list of the disclosures we made of medical information about you that is outside of the information disclosed as described in this document. For example, certain disclosures are expected and therefore would not be included in a disclosure history, including disclosures for: treatment; billing and collection of payment for your treatment; health care operations; those that you have requested or authorized; those made to individuals involved in your care; disclosures allowed by law when the use or disclosure relate to specialized government functions or correctional institutions and other law enforcement custodial situations; or a limited data set that does not contain certain information that would identify you. To request an accounting of disclosures, you must submit your request in writing to Medical Records. Your request must state a time period, which may not be longer than six (6) years. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12-month period will be free. For more lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.
Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. We are not required 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. To request restrictions, you must make your request in writing to Medical Records marked “personal and confidential”. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.
Right to Revoke Authorization. You have the right to revoke your authorization at any time only if it is in writing.
Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. To request confidential communications, you must make your request in writing to the Director of Medical Records marked “personal and confidential”. We will not ask you the reason for your request. Your record must specify how or where you would like us to contact you. We will comply with all reasonable requests.
Right to a 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. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will have a copy of the current notice available at Doc2Go’s website and office location, as applicable. The notice will identify the effective date on the first page, in the top left corner. If the notice is changed, a revised copy will be available for your review on Doc2Go’s website and office location, as applicable.
If you believe your privacy rights have been violated, you may file a complaint with Doc2Go or with the Secretary of the Department of Health and Human Services. To file a complaint with Doc2Go, you may contact the Doc2Go Privacy Officer at 2500 MetroHealth Drive, Cleveland, Ohio, 44109. You may also telephone the Compliance Office at (216) 778-3101.
You may contact the Secretary of the Department of Health and Human Services, Washington D.C., in writing within 180 days of the time that you feel your privacy rights have been violated. You will not be penalized for filing a complaint.
Other uses and disclosures of your 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 permission to use or disclose your health information, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose your health information for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.
This notice is effective on January 1, 2019.