NOTICE OF PRIVACY PRACTICES

This Notice of Privacy Practices describes how San Diego Imaging (“SDi”) may use and disclose your protected health information to carry out treatment, payment, or health care operations and for other purposes that are 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, that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services.

Understanding Your Health Information

Each time you visit a healthcare provider (hospital, imaging center, physician, etc.), a record of your visit is made.  Typically, this record contains your symptoms, examination and test results, diagnosis(es), treatment(s), and a plan for future care or treatment.  This information, often referred to as your health or medical record, serves as:

• A basis for planning your care and treatment.
• A means of communication among the many health professionals who contribute to your care.
• A legal document describing the care you received.
• A means by which you or a third-party payer can verify that services billed were actually provided.
• A tool for educating health professionals.
• A source of data for medical research.
• A source of information for public health officials charged with improving the health of the nation.
• A source of data for planning and marketing.
• A tool for assessing ways in which to continually improve rendered care and outcomes.

Your healthcare providers also maintain information concerning the charges to your account for healthcare services rendered to you, any third parties (insurance companies, health plans, etc.) who may have an obligation for payment of the charges and the status of your account. Understanding what is in your record and how your health information is used helps you:

• Ensure its accuracy.
• Better understand who, what, when, where, and why others may access your health information.
• Make more informed decisions when authorizing use by or disclosure to others.

SDi is required by law to maintain the privacy of your medical information and to provide you with notice of our legal duties and privacy practices.  SDi is required to abide by the terms of this Notice of Privacy Practices.  We may change the terms of our notice, at any time.  The new notice will be effective for all protected health information that we maintain at that time.  Upon your request, we will provide you with any revised Notice of Privacy Practices.  Please send your request to SDi, P.O. Box 23540, San Diego, CA 92193, Attention: Privacy Coordinator.  You may also contact the Privacy Coordinator at (858) 565-0950 ext.235 with any questions regarding our privacy practices, your privacy rights, or requests for additional information regarding your privacy.

Permitted Uses

SDi may use and disclose your medical information for specific reasons:

• Treatment: SDi provides your doctor or other healthcare providers with the results of the diagnostic imaging exams we perform.  We may contact you before an exam to remind you of your appointment or call to talk with you about preparing for an exam.

EXAMPLE: Your primary physician orders a study of your right shoulder.  An SDi radiologist interprets the study and reports the results to your primary physician.  Your primary physician then refers you to an orthopedic surgeon for evaluation and the orthopedic surgeon contacts the SDi radiologist for consultation regarding the study.

• Payment: SDi bills your insurance company, you directly, or another person that may be responsible for payment of your account.  We may contact your health plan to see if they provide coverage for the exam(s) your doctor ordered.

EXAMPLE: SDi receives a request from your insurance carrier for a copy of the report from your recent imaging study for payment processing.  SDi provides a copy of the report to the carrier to facilitate payment.

• Health Care Operations: SDi routinely reviews previously performed exams to maintain quality assurance goals.  That means we may select your images for review by other radiologists.  We may also select your billing information for review by our internal compliance department or external auditors.

EXAMPLE: SDi may periodically select random imaging study reports for review to monitor the quality and completeness of the documentation.

Other Permitted Uses and Required Disclosures

(With Consent, Authorization, or Opportunity to Object)

SDi may use or disclose your protected health information in the following instances.  You have the opportunity to agree or object to the use or disclosure of all or part of your protected health information.  If you are not present or able to agree or object to the use or disclosure of the protected health information, then your physician may, using professional judgment, determine whether the disclosure is in your best interest.  In this case, only the protected health information that is relevant to your health care will be disclosed.

• Others Involved in Your Healthcare: Unless you object, SDi may disclose to a member of your family, a relative, a close friend, or any other person you identify, your protected health information that directly relates to that person’s involvement in your health care.  If you are unable to agree or object to such a disclosure, we may disclose such information as necessary if we determine that it is in your best interest based on our professional judgment.
• Emergencies: SDi may use or disclose your protected health information in an emergency treatment situation.  If this happens, your physician shall try to obtain your consent as soon as reasonably practicable after the delivery of treatment.  If your physician or another physician in the practice is required by law to treat you and the physician has attempted to obtain your consent but is unable to obtain your consent, he or she may still use or disclose your protected health information to treat you.
• Communication Barriers: SDi may use and disclose your protected health information if your physician or another physician in the practice attempts to obtain consent from you but is unable to do so due to substantial communication barriers and the physician determines, using professional judgment, that you intend to consent to use or disclosure under the circumstances.

Other Permitted Uses and Required Disclosures

(Without Consent, Authorization, or Opportunity to Object)

SDi may use or disclose your protected health information in the following situations without your consent or authorization.  These situations include: 

• Required By Law: SDi may use or disclose your protected health information to the extent that law requires the use or disclosure.
• Public Health: SDi may disclose your protected health information for public health activities and purposes to a public health authority that is permitted by law to collect or receive the information.
• Communicable Diseases: SDi may disclose your protected health information, if authorized by law, to a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading the disease or condition.
• Health Oversight: SDi may disclose protected health information to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections.
• Abuse or Neglect: SDi may disclose your protected health information to a public health authority, governmental entity, or agency that is authorized by law to receive reports of abuse or neglect.
• Food and Drug Administration: SDi may disclose your protected health information to a person or company required by the Food and Drug Administration to report adverse events, product defects or problems, biologic product deviations, track products; to enable product recalls; to make repairs or replacements, or to conduct post marketing surveillance, as required.
• Legal Proceedings: SDi may disclose your medical information in response to an order of a court or administrative tribunal, or in response to a subpoena, discovery request, or other lawful process.
• Law Enforcement: SDi may disclose protected health information, so long as applicable legal requirements are met, for law enforcement purposes.
• Military Personnel: SDi may disclose protected health information of individuals who are Armed Forces personnel for activities deemed necessary by appropriate military command authorities.
• Medical Examiner: SDi may disclose protected health information to a coroner or medical examiner to permit such person to fulfil their lawful duties.
• Workers’ Compensation: SDi may disclose your protected health information as authorized to comply with workers’ compensation laws and other similar legally established programs.

Your Rights

SDi supports patient rights, including your rights with respect to your medical information.  These rights include:

• Requesting Restrictions: You may ask SDi to limit use or disclosure of your health information.  We are not required to agree to your request, but if we agree, we will abide by your request except as required by law, in emergencies, or when the information is necessary to treat you.  Your request must: 1) be in writing, 2) describe the information that you want restricted, 3) state if the restriction is to limit our use or disclosure, and 4) state to whom the restriction applies.
• Confidential Communications: You may ask SDi to communicate with you in a particular way or at a certain location to maintain your confidentiality.  Your request must be in writing and must tell us how you intend to satisfy your financial responsibility and specify an alternate way that we can contact you confidentially.  You do not have to give a reason for your request.
• Inspect and Copy: You may request access to inspect and copy your personal information maintained in SDi records.  Your request must be in writing.  We will act on your request within 5 business days after we get it.  If we must deny your request we will send you a written denial.  If this happens, you may request a review of the denial.  We may charge you a fee for this service.
• Amendment: You may ask SDi to amend personal information in SDi’s possession if you believe that it is incorrect or incomplete.  Your request must be in writing and must include a reason to support the amendment.  Your request may be denied if we believe that the information is complete and accurate, if the information is not part of the information that you would be permitted to inspect or copy, or if we did not create the information.
• Accounting of Disclosures: You may request a list of disclosures of your personal information made by SDi over a previous six (6) year period (not including service dates prior to April 14, 2003).  Your first request within a 12-month period is free, but we may charge for additional lists within the same 12-month period.
• File a Complaint: If you believe that SDi has violated your privacy rights, you may file a complaint directly with us by contacting the Privacy Coordinator.  You may also file a complaint with the Secretary of the Department of Health and Human Services.  You will not be penalized for complaining.
• Provide an Authorization for Other Uses and Disclosures: SDi will request your written authorization for uses and disclosures of your health information that are not identified in this notice or permitted by law.  You may revoke your authorization at any time in writing.