THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN ACCESS THIS INFORMATION.
PLEASE REVIEW THIS NOTICE CAREFULLY.
If you have any questions about this notice, contact the privacy official at the facility where you received this notice, send an email to firstname.lastname@example.org or contact:
System Director, Privacy | MC843
100 Michigan Street NE
Grand Rapids, MI 49503
Who Will Follow This Notice
For purposes of this notice, “Spectrum Health” or “Spectrum Health facilities” will refer to all hospitals, clinics, offices, facilities and operations within the Spectrum Health providers listed below:
- Aero Med Spectrum Health
- All ambulatory locations including, but not limited to:Spectrum Health Laboratory
- Spectrum Health Occupational Health
- Spectrum Health Radiology
- Spectrum Health Rehabilitation and Sports Medicine
- Spectrum Health Sleep Disorders Centers
- Spectrum Health South Pavilion
- Spectrum Health Surgery Center – East Paris
- Spectrum Health Surgery Center – Lake Drive
- Spectrum Health Surgery Center – South Pavilion
- Spectrum Health Urgent Care Centers
- Grand Rapids Clinical Oncology Program
- Helen DeVos Children’s Hospital
- Lakeshore Area Radiation Oncology Center
- Resident and Specialty Practices
- Spectrum Health Big Rapids Hospital
- Spectrum Health Blodgett Hospital
- Spectrum Health Butterworth Hospital
- Spectrum Health Continuing Care, which includes:
- Spectrum Health Center for Acute Rehabilitation
- Spectrum Health Home Medical Equipment
- Spectrum Health Hospice and Palliative Care
- Spectrum Health Infusion Pharmacy Services
- Spectrum Health Neuro Rehabilitation Services
- Spectrum Health Orthotic and Prosthetic Services
- Spectrum Health Rehab and Nursing Centers
- Spectrum Health Special Care Hospital
- Spectrum Health Visiting Nurse Association
- Spectrum Health Fred and Lena Meijer Heart Center
- Spectrum Health Gerber Memorial
- Spectrum Health Kelsey Hospital
- Spectrum Health Kelsey Hospital Long-Term Care
- Spectrum Health Kelsey Hospital Rehab and Nursing Center
- Spectrum Health Lemmen-Holton Cancer Pavilion
- Spectrum Health Ludington Hospital
- Spectrum Health Medical Group
- Spectrum Health Medical Group Center for Integrative Medicine
- Spectrum Health Medical Group Integrated Care Campus at East Beltline
- Spectrum Health Medical Group Integrated Care Campus at Holland
- Spectrum Health Medical Group Integrated Care Campus at Wyoming
- Spectrum Health Reed City Hospital
- Spectrum Health Reed City Hospital Rehab and Nursing Center
- Spectrum Health United Hospital
- Spectrum Health United Hospital Long-Term Care
- Spectrum Health United Hospital Rehab and Nursing Center
- Spectrum Health Zeeland Community Hospital
- Other health care facilities and provider offices operated by Spectrum Health
Please note that this list of facilities and offices is current as of October 2013, but may change prior to the next printing of this notice. All Spectrum Health facilities and offices will follow this notice, whether listed or not. A change in this list does not constitute a material change in the practices described in this notice. The most current list of facilities and offices included in the definition of “Spectrum Health” or “Spectrum Health facilities” can be obtained at each patient registration office or by calling 616.486.4113.
This notice also applies to the Spectrum Health Organized Health Care Arrangement (OHCA). The OHCA refers to the Spectrum Health facilities and health care providers who, while not necessarily legally affiliated with Spectrum Health, participate in your care or treatment at a Spectrum Health facility, including:
- Any health care professional authorized to enter information into any medical record established and maintained by Spectrum Health
- All departments and units of Spectrum Health’s hospitals, clinics and offices
- All employees, volunteers, students and other Spectrum Health personnel
- The medical staff at any Spectrum Health facility and the individual members of that medical staff
- Any other health care provider who, although not employed by Spectrum Health, provides services to you at a Spectrum Health facility, including, but not limited to:
- Laboratory and diagnostic providers
- Physicians and other health professionals, such as nurses, nurse practitioners, physician assistants and physical therapists
Spectrum Health reserves the right to change participation in its OHCA by any individual or organization. If you have questions about a health care provider’s participation status, call 616.486.4113.
Our Pledge Regarding Your Medical Information
We understand that medical information about you and your health is personal, and we are committed to protecting it. We create a record of the care and services you receive at Spectrum Health. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records related to your care, which are maintained by Spectrum Health, whether electronic or paper, and whether made by hospital personnel, your personal doctor, a consulting or other treating doctor, a diagnostic facility, or any Spectrum Health facility or support personnel. If your personal doctor is not part of the Spectrum Health OHCA, he or she may have different policies or notices regarding the use and disclosure of your medical information.
This notice covers the ways in which we may use and disclose medical information about you. It also describes your rights and certain obligations we have regarding the use and disclosure of medical information.
We are required by law to:
- Maintain the privacy of the medical information that identifies you
- Give you this notice of our legal duties and privacy practices with respect to medical information about you
- Follow the terms of the notice that is currently in effect
- Notify affected individuals following a breach of unsecured PHI
How We May Use and Disclose Your Medical Information
In many situations, we can use and share your medical information without your written permission (authorization). However, uses and disclosures that are not described here will only be made with your permission. In some situations, your written authorization is required to use or share your medical information. The following categories describe different ways that we use and disclose medical information. Not every use or disclosure in a category will be listed, but all of the ways we are permitted to use and disclose information will fall within one of the categories.
For Treatment: We may use your medical information to provide treatment or services to you. We may disclose medical information about you to other health care providers who are involved in your treatment. We may consult with these providers or refer you to them as part of your care. These other providers may include, but are not limited to, doctors, nurses, technicians, medical students, laboratory and diagnostic providers, pharmacists, nurse practitioners, physician assistants, physical therapists, or other personnel who plan your treatment or provide it to you.
For example, a doctor treating you for a broken leg may need to know if you have diabetes, because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes, so we can arrange for appropriate meals. Different Spectrum Health departments may share your medical information in order to coordinate the different things you need, such as prescriptions, lab work, X-rays or therapy, or to coordinate a referral. We also may disclose medical information about you to people outside Spectrum Health who might be involved in your medical care following treatment at Spectrum Health, such as family members. We also may disclose your medical information to another health care provider you are referred to or transferred to for health care services.
Doctors and other providers who may treat you at places other than Spectrum Health need access to the most complete information possible in order to make decisions about your care. These providers are able to access your electronic and paper records from Spectrum Health for this purpose. Also, when these providers have referred you to Spectrum Health for treatment, they are able to access your records to follow your treatment progress. Spectrum Health has procedures and technology in place to protect the privacy and security of your records in these cases.
For Payment: We may use and disclose your medical and non-medical information so the treatment and services you receive at Spectrum Health can be billed to (and payment can be collected from) you, an insurance company or other third party. For example, we may need to provide your health plan with information about a surgery you received at the hospital so your health plan can pay us or reimburse you for the surgery. We may tell your health plan about a treatment you are going to receive to obtain prior approval or determine whether your plan will cover the treatment. Some providers who deliver care at Spectrum Health bill separately and we may provide payment-related information to them to coordinate the billing process. We also may contact you in writing or on the telephone to discuss your account or to verify or gather more information about your insurance coverage. If you have paid in full for a health care item or service, and you do not wish your health plan to receive information about that item or service, we will not share that information with your health plan, unless we are required by law to do so.
For Health Care Operations: We may use and disclose the minimum medical information about you necessary or practicable for the health care operations of Spectrum Health and others who have provided care to you. These uses and disclosures are necessary to run Spectrum Health entities and make sure that all of our patients receive quality care. For example, we may use medical information to review our treatments and services, and to evaluate the performance of our staff in caring for you. We also may combine medical information about many patients to decide what additional services Spectrum Health should offer, what services are not needed and whether certain new treatments are effective. We may disclose information to doctors, nurses, technicians, medical students and other hospital personnel for review and educational purposes. We may combine the medical information we have with medical information from other organizations to compare our performance and determine how we can improve the care and services we offer. In these cases, we will remove information that identifies you so others can use it to study health care and health care delivery without learning who the specific patients are. We also may use certain medical and non-medical information to contact you and ask your opinion on the quality of services you received at Spectrum Health and how we can improve our services.
Incidental Uses and Disclosures: We may use or disclose your medical information when it is associated with another use or disclosure that is permitted or required by law. For example, conversations between doctors, nurses or other Spectrum Health personnel regarding your medical condition may, at times, be overheard. Please be assured that we have appropriate safeguards to avoid such situations as much as possible.
Appointment Reminders: We may use and disclose medical information to remind you of an appointment you scheduled for a treatment or medical service at a Spectrum Health facility.
Treatment Alternatives: We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives.
Health-related Benefits and Services: We may use and disclose medical information to tell you about health-related services or benefits that may interest you.
Fundraising Activities: We may use certain non-medical information, including, but not limited to, your name, address, telephone number, dates and place of service, age, and gender, to contact you to raise money for Spectrum Health affiliates through a foundation owned or controlled by Spectrum Health. The money raised will be used to expand and improve the services and programs we provide to the community. You have the right to opt out of receiving fundraising communications.
Hospital Directory: We may include limited information about you in the hospital directory while you are a patient at a Spectrum Health hospital. This information may include your name, location in the hospital, your general condition (e.g., fair, stable, etc.) and your religious affiliation. This information, except for your religious affiliation, may also be disclosed to people who ask for you by name. In addition, the hospital may keep a separate directory that lists your religious affiliation and disclose that directory to members of the clergy. This is so your family, friends and clergy can visit you in the hospital and know your general condition. You have the right to ask us to restrict (limit or not include) your information in hospital directories. To request restrictions, you must tell us during registration.
Individuals Involved in Your Care or the Payment of Your Care: We may disclose medical information about you to a friend or family member who is involved in your medical care. We also may give information to someone who is involved with payment or helps pay for your care. We may tell your family and friends about your general condition. In addition, we may disclose medical information about you to an entity assisting in a disaster relief effort, so your family can be notified about your condition, status and location.
Research: Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve evaluating the health and recovery of patients who received one medication compared with those who received another for the same condition. All research projects are subject to a special approval process. This process evaluates a proposed research project and its use of medical information. This process also ensures that the research needs are balanced with our patients’ need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process. We may, however, disclose medical information about you to people preparing to conduct a research project. For example, we may disclose information to researchers to help them look for patients with specific medical needs, so long as the medical information they review does not leave Spectrum Health. We may need to ask for your specific permission if the researcher will have access to your name, address or other personal information, or will be involved in your research-related care at the hospital.
As Required by Law: We will disclose medical information about you when required by federal, state or local law or regulation. For instance, we are required to report certain injuries or illnesses for public health purposes.
To Avert a Serious Threat to Health or Safety: We may use and disclose your medical information when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. We would only disclose your information to someone able to help prevent the threat.
Communications Regarding Spectrum Health’s Programs or Products: We may use and disclose your health information to inform you of a health-related product or service of Spectrum Health. In addition, we may use or disclose your health information to tell you about products or services related to your treatment, case management or care coordination, or to communicate alternative treatments, therapies, providers or settings of care. We may occasionally tell you about another company’s products or services, but will use or disclose your health information for such communications only if they occur in person.
Spectrum Health records and transmits health information, including prescription information, electronically. Health information is shared for the purposes outlined in this notice and is protected electronically through local, state and national health information exchanges. Spectrum Health participates in the Michigan Health Connect (MHC) information exchange and may participate in other information exchanges in the future. MHC has rules regarding how health information can be accessed through the exchange, and limits the use and disclosure of such information. You can email email@example.com for more information about MHC and your rights associated with the transmission of your information through this and other health information exchanges.
Organ and Tissue Donation: If you are an organ donor, we may disclose medical information, as necessary, to organizations that handle organ procurement or organ, eye and tissue transplantation, or to an organ donation bank.
Military and Veterans: If you are a member of the armed forces, we may disclose medical information about you as required by military command authorities. We also may disclose medical information about foreign military personnel to the appropriate foreign military authority. If a family member is in the military, in certain circumstances, we may disclose information about you to the military or an approved social services agency such as the Red Cross to advise your family member of your condition.
Workers’ Compensation: We may disclose medical information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries and illnesses.
Public Health Risks: We may disclose medical information about you for public health activities to:
- Prevent or control disease, injury or disability
- Report births and deaths and participate in disease registries
- Report child abuse or neglect
- Report reactions to medications or problems with products
- Notify people of recalls for products they may be using
- Notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
- Notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will make this disclosure only if you agree, or when required or authorized by law.
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 necessary for the government to monitor the health care system, government programs and compliance with civil rights laws.
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 also may disclose medical information about you in response to a subpoena, discovery request or other lawful process by someone involved in the dispute, but only if you have agreed to such a release. However, your permission will not be required if the disclosure has been ordered by a court of law.
Law Enforcement: We may disclose medical information if asked to do so by a law enforcement official in the following situations:
- In response to a court order, subpoena, warrant, summons or similar process
- To identify or locate a suspect, fugitive, material witness or missing person
- If the information is about a victim of a crime and if, under certain limited circumstances, we are unable to obtain the person’s agreement to the disclosure
- About a death we believe may be the result of criminal conduct
- About criminal conduct at a Spectrum Health facility
- In emergency circumstances to report a crime, the location of the crime or victims, or the identity (description or location) of the person who committed the crime
Coroners, Medical Examiners and Funeral Directors: We may disclose medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We also may disclose medical information about patients to funeral directors, as necessary, to carry out their duties.
National Security and Intelligence Activities: We may disclose your medical information 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 can protect the president, authorized people 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 disclose your medical information to the correctional institution or law enforcement official. This disclosure would be necessary for the institution to provide you with health care, protect your health and safety or the health and safety of others, or for the safety and security of the correctional institution.
Third Parties: We may disclose your medical information to certain third parties with whom we contract to perform services on behalf of a Spectrum Health entity. If so, we will have written assurances from the third party that your information will be protected.
Highly Confidential Information: Certain medical information receives special privacy protection, such as psychotherapy notes, services for mental health and developmental disabilities, alcohol and drug abuse treatment and prevention services, and certain diseases. We will use or share your highly confidential medical information only as permitted or required by law, or with your written permission.
Your Rights Regarding Your Medical Information
Right to Inspect and Copy: You have the right to inspect and obtain a copy of the medical information that may be used to make decisions about your care. During an inspection of your information, a health professional may be in attendance to assist you. The information available to you includes medical and billing records, but does not include any psychotherapy notes.
To inspect or obtain a copy of medical information that may be used to make decisions about you, you must submit a request in writing to the specific Spectrum Health facility or medical provider’s office that administered the related services. If you request a copy of the information, we may charge a fee for copying, mailing and other supplies, and any other charges incurred or associated with your request. Copies of electronic records may be provided in an electronic format that can be readily produced or in a format agreed to by you and Spectrum Health. We also will transmit such electronic information directly to an entity or person clearly and specifically designated by you.
We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you can request that the denial be reviewed. Another licensed health care professional chosen by Spectrum Health will review your request and the denial. The person conducting the review will not be the person who denied your initial request. We will comply with the outcome of the review.
If you are participating in research activities, we may deny your request to inspect and copy some of your medical information related to that research, so long as you agreed to this access restriction in the consent form you signed before participating. We also may deny access to psychotherapy records or as otherwise permitted by law.
Right to Amend: If you feel that the medical 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 Spectrum Health.
Amendment requests must be made in writing and submitted to the director of health information management, or the person responsible for medical records at the specific Spectrum Health facility or medical provider’s office that administered the related services. In addition, you must provide a reason that supports your request.
We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. We also may deny your request if you ask us to amend information that:
- Was not created by us, unless the person or entity that created the information is no longer available to make the amendment
- Is not part of the medical information kept by or for a Spectrum Health entity
- Is not part of the information that you would be permitted to inspect and copy
- Is accurate and complete
Right to an Accounting of Disclosures: You have the right to request an “accounting of disclosures,” which is a list of the disclosures we made regarding your medical information, except the following types of disclosures:
- To carry out treatment, payment or health care operations
- To you or your personal representative
- For which you have given your written permission (authorization)
- For a Spectrum Health facility directory or to your family, friends or others involved in your care
- For national security or intelligence purposes
- To correctional institutions or to law enforcement, as described in this notice
- As part of a limited data set (a collection of information that does not directly identify you)
For an accounting of disclosures, you must submit your request in writing to the director of health information management or the person responsible for medical records at the specific Spectrum Health facility or medical provider’s office that administered the related services. Your request must state a time period, which may not be longer than six years from the date of your request.
Your request should indicate in what form you want the list (for example, on paper or electronically). The first list you request within 12 months will be free. We may charge you for the costs of providing additional lists. We will notify you of the cost and you can choose to withdraw or modify your request at that time before any fees 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 recognize that you may wish to exercise your rights differently at various Spectrum Health facilities, such as a hospital, your physician’s office or an outpatient treatment center. It is your responsibility, as the patient, to notify each individual Spectrum Health facility or provider about specific restrictions to use or disclose your medical information. You also have the right to request that we limit the medical information we disclose about you to someone who is involved in your care or the payment of your care, such as a family member or friend. For example, you could ask that we not disclose information about a surgery you had to someone who would otherwise be permitted to know.
If you have paid in full for a health care item or service, and you do not wish your health plan to receive information about that item or service, we will not share that information with your health plan, unless we are required by law to do so. If you want to make this type of restriction, you should notify the Spectrum Health facility or provider where you receive the particular item or service.
For any other type of request, we are not required to agree to restrict the use or disclosure of your health information. If we do agree, we will comply with your request unless the information is needed to provide emergency treatment. If we agree to a restriction, the restriction will not apply to certain disclosures, such as those required to transfer your health care to another facility, those required by law and those required by a third-party payment contract.
To request restrictions, you must write to the person responsible for medical records or the director of health information management at the Spectrum Health facility or office where you received the related services. In your request, you must tell us what information you want to limit, whether you want to limit our use, disclosure or both, and to whom you want the limits to apply. For example, you may want to limit disclosures to your spouse.
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. For example, you can ask that we only contact you at work or by mail.
To request confidential communications, you must write to the privacy official at the specific Spectrum Health facility or provider’s office. Your request must specify how or where you wish to be contacted. We will not ask you the reason for your request. We will accommodate all reasonable requests.
Right to a Paper Copy of This Notice: You may ask for a copy of this notice at any time. Even if you agreed to receive this notice electronically, you still are entitled to a paper copy. You may obtain a copy of this notice on our website, spectrumhealth.org/patientprivacy, or at any Spectrum Health facility.
Changes to This Notice
We reserve the right to change this notice. We also reserve the right to make the revised notice effective for medical information we already have about you and any information we receive in the future. We will post a copy of the current notice in the facilities, offices and locations covered by this notice. The notice will contain the effective date. In addition, each time you register at a facility or office, or you are admitted to a facility for treatment or health care services as an inpatient or outpatient, a copy of the most current notice will be made available to you.
If you believe your privacy rights have been violated, you may file a complaint with the Spectrum Health entity involved or with the secretary of the Department of Health and Human Services.
To file a complaint with Spectrum Health or any Spectrum Health facility, email firstname.lastname@example.org or contact:
System Director, Privacy | MC843
100 Michigan Street NE
Grand Rapids, MI 49503
All complaints must be submitted in writing. You will not be penalized for filing a complaint.