Groden Center Notice of Privacy Practices Effective: March 1, 2005

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully. Our Duty is to Safeguard Your Protected Health Information.

The Groden Centers mission is to provide individualized services to children and adults to help them reach their greatest level of independence, productivity and integration. We provide these services within a caring, supportive and knowledgeable environment that allows for the greatest amount of growth, individual dignity, personal worth and development of self-control. To carry out this mission some programs collect, use and disclose personal health information. This information is private and confidential and there are policies and procedures in effect to protect this information from unlawful disclosure. This notice will tell you how we may use and disclose protected health information about you. Protected health information means any health information about you that identifies you or for which there is a reasonable basis to believe the information can be used to identify you. In the header above, that information is referred to as medical information. In this notice, we simply call all of that protected health information, health information. This notice also will tell you about your rights and our duties with respect to health information about you. In addition, it will tell you how to complain to us if you believe we have violated your privacy rights. We use and disclose health information about you for a number of different purposes. Each of those purposes is described below.

We may use and disclose health information about you with or without your consent for your treatment, payment for services you receive, or our health care operations. These include:

For Treatment: We may use health information about you to provide, coordinate or manage the services, supports, and health care you receive from us and other providers. For example: We may disclose health information about you to doctors, nurses, psychiatrists, clinical psychologists, behavioral and vocational specialists, treatment teachers direct support staff and other agency staff, volunteers and other persons who are involved in supporting you or providing care. We may consult with other health care providers concerning you and, as part of the consultation, share your health information with them. For example, staff may discuss your information to develop and carry out your individual plan of care. Staff may share information to coordinate needed services, such as medical tests, transportation to a doctors visit, physical therapy, etc. Staff may need to disclose health information to entities outside of our organization (for example, another provider, or a state/local agency) to obtain new services for you.

For Payment: We may use and disclose health information about you so we can be paid for the services we provide to you. This can include billing, collection and related data processing to a third party payor, such as Medicaid, your insurance company, or a government agency. For example, we may need to provide the Rhode Island Departments of Education or Children, Youth and Families or Health or Human Services or Mental Health, Retardation and Hospitals or the Division of Developmental Disabilities, or the Massachusetts Department of Mental Retardation, or a local school department with information about the treatment and habilitation services we provide to you so we will be reimbursed for those services. We also may need to provide Medicaid/Medicare/Social Security or a state agency with information to ensure you are eligible for specific financial benefits. We also may use and disclose health information about you to payors to determine financial responsibilities, for example: to determine eligibility for coverage, for coordinating benefits, or for medical necessity and utilization reviews.

For Health Care Operations: We may use and disclose health information about you for our own operations. These are necessary for us to operate the Groden Center and to maintain quality care for our clients. For example, we may use health information about you to review the services we provide and the performance of our employees supporting you. We may disclose health information about you to train our staff and volunteers. We also may use the information to study ways to more efficiently manage our organization, for accreditation or licensing activities, or for our compliance program.

We may use and disclose your health care information with or without your authorization for other important purposes permitted or required by law, in an emergency, or when there are substantial communication barriers to obtaining your consent. These include:

Disaster Relief: We may use and disclose health information about you to a public or private entity authorized by law or by its charter to assist in disaster relief efforts. This will be done to coordinate with those entities in notifying a parent/guardian, personal representative, family member, other relative, close personal friend, or other person identified by you of your location, general condition or death.

Reporting abuse, neglect or domestic violence: We may use and disclose the health information of suspected victims of abuse, neglect, or domestic violence including reporting the information to social service or protective services agencies.

Public health activities: We may use and disclose health information about you to prevent or control the spread of disease or other injury; public health surveillance or investigations; reporting adverse events with respect to food, dietary supplements, product defects and other related problems to the Food and Drug Administration; medical surveillance of the workplace or to evaluate whether you have a work-related illness or injury; or in order to comply with Federal or state law.

Health oversight activities: We may use and disclose health information about you for designated activities and functions including: audits, civil, administrative, or criminal investigations, inspections, licensure or disciplinary actions, or civil, administrative, or criminal proceedings or actions, or other activities necessary for appropriate oversight of government benefit programs.

Judicial and administrative proceedings: We may use and disclose health information about you in response to an order of a court or administrative tribunal, a warrant, subpoena, discovery request, or other lawful process.

Law enforcement activities: We may use and disclose health information about you for the purpose of identifying or locating a suspect, fugitive, material witness, or missing person, or reporting crimes in emergencies, or reporting a death.

Relating to decedents: We may use and disclose the health information of an individual’s death to coroners, medical examiners and funeral directors. Additionally, we may disclose a decedents health information to human organ procurement organizations relating to organ, eye, or tissue donations or transplants.

For research purposes: In certain circumstances, and under the supervision of an Internal Review Board, we may disclose health information about you to assist in medical/psychiatric research.

To avert a serious threat to health or safety: We may use and disclose health information about you in order to avert a serious threat to health or safety.

For specific government functions: We may disclose the health information of military personnel and veterans in certain situations. Similarly, we may disclose the health information of inmates to correctional facilities in certain situations. We may also disclose health information about you to governmental programs responsible for providing public benefits, and for workers compensation. Additionally, we may disclose health information about you, if required, for national security reasons.

Appointment Reminders, and Treatment and Service Alternatives: We may use and disclose health information about you to contact you to remind you of an appointment for treatment or services. We may use and disclose health information about you to contact you about treatment and service alternatives that may be of interest to you.

Health Related Benefits and Services, and Marketing Communications: We may use and disclose health information about you to contact you about health-related benefits and services that may be of interest to you, or to communicate with you about a product or service to encourage you to purchase the product or service. This may be: To describe a health-related product or service that is provided by us, for your treatment, for case management or care coordination for you; To direct or recommend alternative treatments, therapies, health care providers, or settings of care. We may communicate to you about products and services in a face-to-face communication by us to you. We also may communicate about products or services in the form of a promotional gift of nominal value. All other use and disclosure of health information about you by us to make a communication about a product or service to encourage the purchase or use of a product or service will be done only with your written authorization.

Fundraising: We may use and disclose demographic information such as your name and address to contact you to ask for contributions or assistance in raising funds to support our mission. If you do not want us to contact you for fundraising, notify our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909

Facilities Directories: We may include your name and your location in a facility in directories at some of our facilities for people that ask for you by name. If you do not want to appear in a directory, notify our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909.

Disclosures to Family and Others Involved in Your Care: We may disclose to a parent/guardian, personal representative, family member, other relative, a close personal friend, or any other person identified by you; health information about you that is directly relevant to that persons involvement with the services and supports you receive or payment for those services and supports. We also may use or disclose health information about you to notify, or assist in notifying, those persons of your location, general condition, or death. If there is a family member, other relative, or close personal friend that you do not want us to disclose health information about you to, please notify our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909

Other Uses and Disclosures with Your Authorization: Other uses and disclosures of your health information will be made only with your written authorization. You may revoke such an authorization at any time by notifying our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909. However, if you revoke such an authorization, it will not have any affect on actions taken by us in reliance on it. If there is an emergency situation and you cannot be given your opportunity to object, disclosure may be made if it is consistent with any prior expressed wishes and disclosure is determined to be in your best interests. You must be informed and given an opportunity to object to further disclosure as soon as you are able to do so.

Your Rights With Respect to Health Information About You: You have the following rights with respect to health information that we maintain about you. If you have any questions or requests concerning these rights, contact our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909

Right to Request Restrictions: You have the right to request that we restrict the uses or disclosures of health information about you to carry out treatment, payment, or health care operations. You also have the right to request that we restrict the uses or disclosures we make to: (a) a family member, other relative, a close personal friend or any other person identified by you; or, (b) public or private entities for disaster relief efforts. For example, you could ask that we not disclose health information about you to your brother or sister. We are not required to agree to any requested restriction. However, if we do agree, we will follow that restriction unless the information is needed to provide emergency treatment. Even if we agree to a restriction, either you or we can later terminate the restriction.

Right to Receive Confidential Communications: Unless you tell us otherwise in writing, we may contact you by either telephone or mail. You have the right to request that we communicate health information about you to you in a certain way or at a certain location. For example, you can ask that we only contact you by mail or at work. We may not require you to tell us why you are asking for the confidential communication. We will accommodate your reasonable request. However, we may, if necessary, require information from you concerning how payment will be handled. We also may require an alternate address or other method to contact you.

Right to Inspect and Copy: With a few very limited exceptions – for example: psychotherapy notes and information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding – you have the right to inspect and obtain a copy of health information about you. We may require you to provide us with a written request for access to health information about you. We will respond to your written request within 30 days of its receipt. If we deny your access request, we will give you written reasons for our denial and explain your right to have our denial reviewed. However, if we agree to your request for access, we must provide you with access to health information about you in the form or format requested by you, if it is readily producible in such form or format. We may provide you with a summary of requested health information about you, in lieu of providing access to health information about you or we may provide you with an explanation of health information about you if you agree in advance to such a summary or explanation and agree to the fees imposed for such summary or explanation. We will provide you with access as requested in a timely manner, including arranging a convenient time and place for you to inspect or obtain copies of health information about you or mailing a copy of health information about you to you at your request. If you request a copy of health information about you or agree to a summary or explanation of health information about you, we are permitted to charge a reasonable cost-based fee for copying, postage, mailing, and the costs of preparing an explanation or summary as agreed upon in advance. We reserve the right to deny you access and copies of certain health information about you as permitted or required by law. In the event that we must deny you access to the health information you seek, we will reasonably attempt to accommodate your request for access to other portions of health information about you that may satisfy your request. Upon denial of a request for access, we will provide you with a written denial specifying the legal basis for our denial, a statement of your rights, and a description of how you may file a complaint with us. If we are not in possession of the PHI you have requested, but we know where the requested PHI is maintained, we will inform you of where to direct your request for access.

Right to Amend: You have the right to ask us to amend health information about you. You have this right for so long as the health information is maintained by us. We will act on your request within sixty (60) calendar days after we receive your request. If we grant your request, in whole or in part, we will inform you of our acceptance of your request and provide access and copying as stated above. If we grant the request, in whole or in part, we will make reasonable efforts to inform and provide the amendment within a reasonable time to persons identified by you as having received your health information and relevant persons that we know are in possession of your health information that is the subject of your amendment and that may have relied, or could foreseeably rely, on that information to your detriment. We also will make the appropriate amendment to the health information by appending or otherwise providing a link to the amendment. We may deny your request to amend health information about you. We may deny your request if it is not in writing and does not provide a reason in support of the amendment. In addition, we may deny your request to amend health information if we determine that the information: a. Was not created by us, unless the person or entity that created the information is no longer available to act on the requested amendment; b. Is not part of the health information maintained by us; c. Would not be available for you to inspect or copy; or, d. Is accurate and complete. If we deny your request, we will inform you of the basis for the denial. You will have the right to submit a statement of disagreement with our denial. Your statement may not exceed 2 pages. We may prepare a rebuttal to that statement. Your request for amendment, our denial of the request, your statement of disagreement, if any, and our rebuttal, if any, will then be appended to the health information involved or otherwise linked to it. All of that will then be included with any subsequent disclosure of the information, or, at our election, we may include a summary of any of that information. If you do not submit a statement of disagreement, you may ask that we include your request for amendment and our denial with any future disclosures of the information. We will include your request for amendment and our denial (or a summary of that information) with any subsequent disclosure of the health information involved. You also will have the right to complain about our denial of your request.

Right to an Accounting of Disclosures: You have the right to receive an accounting of disclosures of health information about you. The accounting may be for up to six (6) years prior to the date on which you request the accounting but not for disclosures made before April 14, 2003. Certain types of disclosures are not included in such an accounting: a. Disclosures to carry out treatment, payment and health care operations; b. Disclosures of your health information made to you; c. Disclosures that are incident to another use or disclosure; d. Disclosures that you have authorized; e. Disclosures for disaster relief purposes; f. Disclosures for national security or intelligence purposes; g. Disclosures to correctional institutions or law enforcement officials; h. Disclosures that are part of a limited data set for purposes of research, public health, or health care operations (a limited data set is where things that would directly identify you have been removed.) i. Disclosures made prior to April 14, 2003. Under certain circumstances your right to an accounting of disclosures to a law enforcement official or a health oversight agency may be suspended. Should you request an accounting during the period of time your right is suspended, the accounting would not include the disclosure or disclosures to a law enforcement official or to a health oversight agency. Your request must state a time period for the disclosures. It may not be longer than six (6) years from the date we receive your request and may not include dates before April 14, 2003. Usually, we will act on your request within sixty (60) calendar days after we receive your request. Within that time, we will either provide the accounting of disclosures to you or give you a written statement of when, within an additional thirty (30) days, we will provide the accounting and why the delay is necessary. There is no charge for the first accounting we provide to you in any twelve (12) month period. For additional accountings, we will charge you for the cost of providing the list. We will notify you of the cost involved and give you an opportunity to withdraw or modify your request to avoid or reduce the fee.

Right to Copy of this Notice: You have the right to obtain a paper copy of our Notice of Privacy Practices. You may request a copy of our Notice of Privacy Practices at any time. To obtain a paper copy of this notice, contact our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909

Our Right to Change Notice of Privacy Practices: We reserve the right to change this Notice of Privacy Practices at any time. We reserve the right to make the new notices provisions effective for all health information that we maintain, including that created or received by us prior to the effective date of the new notice.

Complaints: If you believe that we may have violated your individual privacy rights, you may submit your written complaint to our Privacy Compliance Officer at the address provide in this paragraph. Your written complaint must name the entity that is the subject of your complaint and describe the acts and/or omissions you believe to be in violation of the Rule or of the provisions outlined in our Notice of Privacy Practices. If you prefer, you may file your complaint with the Secretary of the U.S. Department of Health and Human Services (Secretary). However, any complaint you file must be received by us, or filed with the Secretary, within 180 days of when you knew, or should have known, the act or omission occurred. We will take no retaliatory action against you if you make such complaints. If you wish to file any complaints, please forward your written correspondence to our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909. To file a complaint with the United States Secretary of Health and Human Services, send your complaint to him or her in care of: Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Avenue SW, Washington, D.C. 20201.

Questions and Information: If you have any questions or want more information concerning this Notice of Privacy Practices, please contact our Privacy Officer, 610 Manton Avenue, Providence, Rhode Island 02909.