Boston Health Care for the
Homeless Program (BHCHP)/McInnis Health Group (MHG) keeps a record for each
patient of the health care services provided. We are required by law to keep your Protected Health
Information (PHI) private. We are
also required by law to notify patients of our legal duties and privacy
practices used to keep your PHI private. BHCHP/MHG is required to obey the
Notice of Privacy Practices currently in effect.
BHCHP/MHG Is a Community Health Center member of Boston Health Net and may share information with BMC or the other Community
Health Center members of Boston Health Net for the purposes of treatment, payment, and health care operations.
For a full list of sites at which Boston Health Care for the
Homeless Program (BHCHP)/McInnis Health Group (MHG) provides care and a full
list of Collaborations see the final page of this document.
New Medical Record Retention Regulations:
The length of time clinics and hospitals in Massachusetts must keep medical records has been reduced from 30 years to 20 years.
This time frame was reduced by state law, “Chapter 305 of the Acts of 2008, An Act To Promote Cost Containment, Transparency, And Efficiency In The Delivery Of Quality Health Care,” (signed into law by Governor Deval Patrick on August 10, 2008) and the corresponding Massachusetts Department of Public Health Regulations effective July 10, 2009.
Effective July 10, 2009, Boston Health Care for the Homeless Program/McInnis Health Group will maintain medical records for a period of
no longer than 20 years from a patient’s last date of service.
Patient access to medical records will not change with this change in the law. Patients will continue to have the right to inspect his/her medical records upon request at any time during the 20 year period for which we are required to maintain medical records.
When records are 20 years old or older, Boston Health Care for the Homeless Program/McInnis Health Group is required to notify the Department of Public Health, 30 days prior to the intended date of destruction, of our intention to destroy the records. Destruction of records which are 20 years old or older is done by a vendor who has signed an agreement to transport and destroy the records in a manner which protects your confidentiality at all times.
You may obtain a full copy of the Boston Health Care for the Homeless Program’s Records Retention and Destruction Policy by contacting the Privacy Officer at 857-654-1078.
A. Uses of Health Information:
BHCHP/MHG may share your protected health information for treatment,
payment, and health care operations without obtaining specific permission.
2. Payment: BHCHP/MHG may use your protected health information to bill for our services and to collect for our services. For instance, your insurance company or third party payor can request to see copies of your record to verify services which you received. Another example is that BHCHP/MHG may be required to share information with your insurance company or third party payor to obtain prior approval for your treatment.
3. Health Care Operations: Health Care Operations are the functions that all health care facilities and agencies perform to verify that the delivery of care to patients is being properly performed and that the facility or agency is functioning properly. One example of this is chart review to evaluate staff performance. Another example is chart review in the medical records department or by the Medical Records Committee to verify that all records are completed according to legal requirements.
4. As required by law or legal authorities: Other situations in which we may share your protected health information include those releases required and/or allowed by federal, state and local law. For a list of the situations and/or federal, state, and local agencies to whom we may release your protected health information without your consent, see the list below.
5. Appointment reminders: We may share your protected health information to contact you as a reminder that you have an appointment.
6. Treatment alternatives: We may share your protected health information to tell you about or recommend possible treatment alternatives.
7 Benefits and services: We may share your protected health information to tell you about health related benefits or services that may be of interest to you.
8. Individuals involved in your care or payment for your care: We may share your medical information, including your condition and the fact that you are being treated, to friends or family members who are involved in your care or payment for your care.
9. Disaster Relief: We may share your protected health information with legally authorized public or private Disaster Relief Organizations for the following reasons:
a) Notification of individuals involved in your care;
b) Assistance to the Disaster Relief Organization for disaster relief efforts.
PERMITTED RELEASE OF PROTECTED HEALTH INFORMATION WITHOUT PATIENT CONSENT
Medical Emergencies: a situation which causes immediate jeopardy to the patient’s health or life and which requires immediate intervention
Certain State and Federal Agencies:
· Medicare
· Medicaid
· Veterans’ Benefits
· Support by the Commonwealth
· Aid to Families With Dependent Children
· Assistance to the Aged and Disabled
· Division of Medical Assistance (for a patient application for Medicaid Benefits or Programs)
· Department of Children and Families (formerly
Department of Social Services) (for investigations
of reports of suspected child abuse/neglect) or
(for inspection of charts of children in their custody)
· Disabled Persons Protection Commission
· Department of Elder Affairs/Elder Abuse Investigations
· Commissioner of Public Health/Department of Public Health
· Medical Examiner/Coroner
· Funeral Directors
· Department of Public Health-infections diseases or
diseases dangerous to the public or
· Local Board of Health-infectious diseases or diseases dangerous to the public (if not already reported to the Department of Public Health
· Vaccine Reactions’
· Deaths
· Events which cause (or could cause) harm to patients or employees
· Police (for wounds, burns, injuries
· Law enforcement (in response to a warrant or to report a crime on BHCHP property
· Correctional Institution-to provide you with initial health care
· Department of Public Safety (wounds, burns, injuries)
· Courts (in response to a lawful request such as subpoena or court order
10: Research: Under certain circumstances, we may share medical information about you for research purposes; however, we will do this only through a special review process. If a researcher will have access to your name, address, or other information that reveals who you are, we will ask for your specific permission or get approval from an Internal Review Board.
B. Other sharing of medical information: Sharing of your medical/health information requested for any reason other than those listed in this notice will be done only with your written permission (authorization). If you provide written permission (authorization) for us to share your medical information, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer share your medical information /health information for the purpose covered in your written permission (authorization); however, we are unable to take back any information we have already shared prior to the time your permission (authorization) was revoked. We are required to retain our records of the care that we provided to you.
C. Your
rights regarding your medical information:
1. Right to inspect and copy: You have the right to inspect and copy medical and billing information (excluding psychotherapy notes) that may be used to make decisions about your care. To inspect and copy your medical information, you must complete an Authorization for the Release and/or Discussion of Medical Records and submit it to the Privacy Officer. If you request a copy of the information, we may charge a fee for the costs of copying, mailing, and supplies used.
We may deny your request to inspect and copy in certain, very limited, circumstances. If we deny your request, you may request that we release copies of your record for inspection to you through another physician of your choice or you may request that we release copies of your medical record to you through your attorney. Another licensed health care professional chosen by our organization will review your request and the denial. The person conducting the review will not be the person who denied your request.
To request information about the steps you must take to inspect and copy medical information that may be used to make decisions about your care, contact the Privacy Officer.
2. Right to Amend: If you feel that medical information we have about you is inaccurate or incomplete, you have the right to request us to amend your record. You have the right to request an amendment for as long as the information is kept by (or for) the organization.
To request information about the steps to be taken if you wish us to amend your record or if you wish to submit an amendment, you must submit your request in writing to the Privacy Officer.
Right to Deny Amendment: BHCHP/MHG has the right to deny your request for amendment if it is not in writing or if it does not include a reason to support your request. We may also deny your request if you ask us to amend the following types of information:
§ 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 the organization;
§ Is not part of the information which you would be permitted to inspect and copy; or
§ Is accurate and complete.
3. Right to an Accounting of Disclosures (shared information): You have the right to request an accounting of disclosures, which is a list of the medical information about you which we have shared..
To request a list of accounting of disclosures (shared information), submit your request in writing to the Privacy Officer. Requests for an accounting of disclosures may not be for a period of longer than six years and requests may not include requests for information released (shared) before February 26, 2003. Your request should indicate if you prefer to receive the list on paper or electronically. The first list you request within a 12-month period will be free. For additional 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.
4. Right to request restrictions: You have the right to request a restriction or limitation on the medical information we share about you for treatment, payment, or health care operations. You also have the right to request a limit on the medical information we share about you to someone who is involved in your care or payment for your care, like a family member or friend. For example you could ask that we not share information about a surgery you had.
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 services.
To request restrictions contact the Privacy Officer In your request you must tell us 1.) what information you want to limit and 2.) to whom you want the limits to apply , for example, sharing information with a spouse.
5. Right to request confidential communications: You have the right to request that we communicate with you about health information 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, contact the Privacy Officer. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.
6. Right to a paper copy of this notice: You have the right to obtain a paper copy of this notice. You may ask us to give you a copy of this notice at any time. You may also obtain a copy of this notice at our website or by other electronic means i.e. E-Mail. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.
You may obtain a copy of this notice at our website, www.bhchp.org
You may obtain a paper copy of this notice on admission, on your first visit after the effective date, or you may contact the Privacy Officer.
7. Right to complain: If you feel that your privacy rights have been violated, you may file a complaint with BHCHP/MHG by notifying the Director of Clinical Operations in writing (for clinic) or the Director of Respite (for Respite) by filing a Grievance in accordance with the BHCHP/MHG Grievance Procedure. If the grievance refers to a violation of privacy rights, the Director of Clinical Operations or the Director of Respite will forward your grievance to the Privacy Officer.
If, after following our grievance procedure, you do not feel your complaint has been addressed, you may notify the Secretary of Health and Human Services.
You cannot be penalized for
filing a complaint.
E.
Contact Information:
Boston
Health Care for the Homeless Program
780
Massachusetts Avenue
Boston
Massachusetts 02118
PROGRAMS/LOCATIONS OF
CARE AND COLLABORATIONS
BOSTON HEALTH CARE
FOR THE HOMELESS PROGRAM (BHCHP)/McINNIS HEALTH GROUP (MHG)
1. 780
Albany Street (Admin. Offices)
2. Anchor
Inn
3. Asian
Task Force Against Domestic
Violence
4. Barbara
McInnis House
5. Beacon
Townhouse Inn #2
6. Boston
Medical Center ED
7. Boston
Medical Center Infectious
Diseases
Department (AIDS Program)
8. Boston
Medical Center Inpatient
9. Boston
Family Shelter
10. Boston
Living Center
11. Bridge
Over Troubled Waters
12. Bridge
To Recovery
13. Brookview
House
14. Carolina
Hills Shelter
15. Casa
Esperanza Men’s Program
16. Casa
Nueva Vida
17. Church
of Advent
18. Community
Outreach: State Agency Offices
19. Crittenton
Women’s Union
20. Crossroads
21. DTA
Motels (Various Sites)
22. Day
Care and School Outreach, Including
Horizons
for Homeless Children, Dorchester
Jamaica
Plain and Roxbury
23. Dove
24. Entre
Familia
25. Families
In Transition
26. Family
House Shelter
27. Father
Bill’s Place
28. Finex
House
29. Friends
of the Homeless of the South Shore
30. Friends
of the Unborn I
31. Friends
of the Unborn II
32. Hestia
House
33. Hildebrand
Family Shelter I, Dorchester
34. Hildebrand
Family Shelter II, Dorchester
35. Hope
Found, Including Stay-In Beds
36. Hope
Found Transitional Living Program
37. Housing
Families, Inc.
38. Jean
Yawkey Place Clinic (formerly BMC
Homeless
Primary Care)
39. Joelyn’s
Place (Victory Programs)
40. Kingston
House
41. Latinas
Y Ninas
42. Life
House, Columbia Road
43. Life
House, Stoughton Street
44. Long
Island Shelter
45. Long
Island Shelter Annex
46. Margaret’s
House
47. Massachusetts
General Hospital ED
48. Massachusetts
General Hospital Homeless
Primary
Care
49. Massachusetts
General Hospital Inpatient
Rounds
50. Massachusetts
Mental Health Center
51. Metropolitan
Boston Housing (Scattered
Sites)
52. Millenium
House #1
53. Millenium
House #2
54. Nazareth
Residence
55. New
Chardon Street Shelter
56. New
England Shelter for Homeless
Veterans
57. Night
Center, Boston
58. North
Beacon Inn
59. Olivia’s
Place
60. Pilgrim
Shelter
61. Pine
Street Inn Men’s Clinic
62. Pine
Street Inn Women’s Clinic
63. Portis
Family House
64. Project
Hope
65. Queen
of Peace Shelter
66. Renewal
House
67. Revision
House
68. Rosie’s
Place
69. Roxbury
Family Shelter
70. Safe
Harbor
71. Sandra’s
Lodge
72. SOAR
73 Sojourner
House
74. South
End Community Health Center
75. St.
Ambrose
76. St.
Francis House
77. St.
John’s Church
78. St.
Mary’s Women’s and Infants’ Center
79. Street
Outreach, Including:
Geographic
Area, Boston
Geographic
Area, South Shore
Scattered
Site Apartments (Housing First)
Van
(Needle Exchange)
Van
(Pine Street Inn)
80. Suffolk
Downs (Eighth Pole)
81. Transitions
82. Women’s
Lunch Place
83. Women’s
Transition Center
84. Woods
Mullen Shelter
COLLABORATIONS:
Boston
Health Net (OHCA), Including:
BMC
(Health Net Admin. Office)
Codman
Square Health Center
Dorchester
House Multi-Service Center
East
Boston Neighborhood Health Center
Geiger-Gibson
Community Health
Greater
Roslindale Medical and Dental
Center
Harvard
Street Neighborhood Health
Center
Health
Care for the Homeless
Mattapan
Community Health Center
Neponset
Health Center
Roxbury
Comprehensive Community
Health
Center
South
Boston Community Health Center
Boston
Health Net (OHCA), Continued:
South
End Community Health Center
Upham’s
Corner Health Center
Whittier
Street Neighborhood Health
Center
Manet
Community Health Center, Quincy
OTHER COLLABORATIONS:
Above
and Beyond, Brookview,
(Dorchester
and Roxbury)
Boston
Public Health Commission
Boston
Public Schools, Outreach
Cambridge
Health Alliance, including:
Cambridge
and Somerville Health Care
for
the Homeless
Hope
Found
OTHER COLLABORATIONS (Continued):
LARC
Lemuel
Shattuck Hospital
Mass
Mental Health
Metro
Boston Housing
New
England Eye Institute
President’s
Church, Quincy
St.
Francis Mental Health
South
End Community Health Center