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.
Grace Reproductive Health Services d/b/a Meadow Reproductive Health & Wellness (“Meadow,” “we,” or “us”) and staff are committed to the protection of the privacy of your health record and the confidentiality of your visit. We are required by law to provide individuals with notice of our legal duties and privacy practices with respect to your “Protected Health Information” or “PHI” (defined below) and the confidentiality of your visit in compliance with applicable law. This Notice of Privacy Practices (“Notice”) describes how we may use and disclose your PHI to carry out treatment, payment, or health care operations, and for other specified purposes that are permitted or required by law.
Your healthcare record, whether in written, printed or electronic form, and the information it contains will not be disclosed or released to any one outside of Meadow without your written authorization except as allowed or required by applicable law.
No one, including your parent or spouse, will be allowed access to your information without your written authorization except when required by law.
I. Our Responsibilities
Meadow and the members of its workforce are committed to protecting the privacy and confidentiality of your personal information and PHI.
Meadow is required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), as amended by the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”), to maintain the privacy and security of your PHI and to provide you with a notice of our legal duties, our privacy practices, and your patient rights.
Whenever we use or disclose your PHI, we are required to abide by the terms of this Notice.
II. Definition of Protected Health Information
PHI is information about you, including your demographic information, that relates to your physical or mental health condition or health care provided to you. PHI can include your medical history, laboratory results, insurance information, and other health information that is collected, generated, used, and communicated by Meadow to deliver health care services and bill for our health care services. Examples of PHI include your name, date of birth, medical record number, social security number, insurance beneficiary number, and genetic information.
III. Uses and Disclosures of Your Protected Health Information
Meadow may use or disclose your health information for the following purposes:
Treatment.
|
We may use or disclose your PHI for purposes of providing your medical treatment, including determining the best treatment for you. For example, we may use your PHI to perform our testing services and disclose your testing results to your physician and other health care providers involved in your care.
|
Healthcare Operations.
|
We may use or disclose your PHI to facilitate our healthcare operations. For example, we may use and share information in your health record to assess the care you received for the purpose of our Continuous Quality Improvement Program.
If your services are being paid in full or in part by a local or national reproductive health fund, Meadow may securely share limited health information with these organizations to improve the quality of their care.
De-identified statistical information may be released to the National Abortion Federation (NAF) and other organizations to improve the quality of our care. Any outside agency will also be required to safeguard your information.
|
Payment Purposes.
|
We may use or disclose your PHI for purposes of billing and collecting payment for our services. For example, we may disclose PHI to your health plan in order to obtain payment for the services provided to you.
If you want to submit a claim to your insurance company for reimbursement, Meadow will do so for you as a courtesy or can assist you in preparing the necessary forms. Many insurance companies include full range reproductive health care in their policies, but your employer may have excluded pregnancy related services or family planning because of recent Supreme court rulings putting the rights of a business above those of their employees. Every policy is different, so please ask your policy’s Customer Service representative.
|
Judicial and Administrative Proceedings & Law Enforcement.
|
Under certain circumstances, we may be permitted, but not required, to disclose your PHI to comply with a judicial or administrative order or in response to a subpoena, discovery request, or other lawful process.
However, we are prohibited from using or disclosing your PHI for any of the following activities (each a “Prohibited Purpose” and collectively, the “Prohibited Purposes”):
● To conduct a criminal, civil, or administrative investigation into, or impose criminal, civil, or administrative liability on any person for the mere act of seeking, obtaining, providing or facilitating reproductive health care, where such health care is lawful under the circumstances in which it is provided; and
● The identification of any person for the purpose of conducting such investigation or imposing such liability.
For example, we may receive a request for use or disclosure of your PHI from a law enforcement official, for the purpose of investigating or imposing liability for the reproductive health care that you lawfully received. Under these circumstances, we are prohibited from using or disclosing your PHI to such law enforcement official because the request is for a Prohibited Purpose.
|
Health Oversight Activities.
|
We may disclose your PHI to a healthcare oversight agency for activities that are authorized by law, such as audits, investigations, inspections, and licensure activities. For example, we may disclose your PHI to agencies responsible for ensuring compliance with the rules of government health programs, such as Medicare or Medicaid.
|
State-Mandated Statistical Reporting Requirements.
|
The Commonwealth of Virginia requires reporting of statistical information regarding abortions, including patient age, race, educational status, city or county of residence, and gestational age. You may opt out of providing this information. We will not release your name, address, or any other identifying information.
|
Threats to Health and Safety.
|
We may disclose your PHI to prevent or reduce the risk of a serious and imminent threat to the health and safety of an individual or the general public. For example, Meadow may be required by law to report health information related to preventing certain communicable diseases, injury or disability.
|
Persons Involved in Your Care or Payment for Your Care.
|
We will not disclose your PHI to persons involved in your care or payment for your case, such as a family member, relative, or close friend, unless you ask us to do so.
|
Notification.
|
We will not disclose your PHI to notify, or assist in notifying, a family member or another person responsible for your care regarding your location and general condition, unless you ask us to do so.
|
Personal Representatives.
|
We may disclose your PHI to your authorized personal representative, such as a lawyer, administrator, executor, or other authorized person responsible for you or your estate.
|
Minors’ PHI.
|
We will not disclose PHI about you to your parents or legal guardians if you are a minor, unless you ask us to do so.
|
Communication about Products and Services; Marketing.
|
We may use and disclose your PHI to contact you about other Meadow products and services that are medically necessary following your care with us.
[Any marketing information that is not medically necessary will be made available to you only with your authorization. Should you choose to receive such marketing information, we will use your PHI to tailor the information to your needs and preferences.] We do not disclose your PHI to third parties for marketing purposes without your written authorization.
|
Research.
|
Under certain circumstances, and subject to your written authorization or an Institutional Review Board waiver (as applicable), we may use or disclose your PHI for research purposes within Meadow and with research collaborators outside of Meadow who are under contract and are also obligated to protect PHI. Generally, research projects at Meadow are subject to review by a committee responsible for ensuring the protection of individual research subjects, appropriate patient authorization, and an adequate plan to safeguard PHI.
|
Victims of Abuse, Neglect, or Violence.
|
If required or authorized by law, we may disclose your PHI to a government agency, such as a social services or protective services agency, if we reasonably believe that an adult or child is the victim of abuse, neglect, or domestic violence.
|
Data Breach Notification.
|
As described below, we may use your PHI to provide legally required notices of unauthorized access, acquisition, or disclosure of your PHI.
|
De-Identification of PHI.
|
We may de-identify your PHI by removing identifying features as determined by law to make it extremely unlikely that the information could identify you.
|
Fundraising
|
We will not use or disclose your PHI for fundraising purposes, unless it is de-identified and required for a foundation grant for the Clinic.
We may use or disclose your PHI to our Business Associates to contact you regarding our fundraising activities. You have the right to opt out of receiving fundraising communications.
|
Additional Uses and Disclosures.
|
Meadow may also use or disclose your PHI in other ways as permitted by law, including, but not limited to or for:
● Specialized Government Functions, including, but not limited to, military command authorities, national security and intelligence organizations, and correctional institutions
● Workers’ Compensation Programs
● Coroners, Medical Examiners, and Funeral Directors
● The FDA
● Organ and Tissue Donation Organizations
|
All Other Disclosures.
|
Uses and disclosures of PHI for purposes other than those described above (or as otherwise permitted or required by law) will not be made without a written authorization signed by you or your personal representative. For example, most uses and disclosures of psychotherapy notes (where appropriate) require your signed authorization.
Once you sign an authorization, you may revoke it at any time by contacting Meadow, unless we have already relied upon it to use or disclose PHI. A revocation of authorization must be submitted to the Privacy Officer at the address provided at the end of this Notice.
|
Uses and Disclosures Requiring an Attestation.
|
As described in more detail above, under certain circumstances, we may be permitted, but not required, to use or disclose your PHI for health oversight activities, judicial and administrative proceedings, law enforcement purposes, or to coroners and medical examiners. When we receive a request for your PHI for any of these purposes, we are required to obtain a signed attestation from the party making the request before we may disclose your PHI.
The attestation is used to verify that party making the request for your PHI is not requesting your PHI for a Prohibited Purpose (as defined on p.3 Section: Judicial and Administrative Proceedings & Law Enforcement).
For example, we may disclose your PHI to an agency responsible for ensuring compliance with the rules of government health programs, such as Medicare or Medicaid, which constitutes a health oversight activity. Because PHI disclosures for health oversight activities require a signed attestation, we would be required to obtain a signed attestation from the agency, verifying that the disclosure is not for a Prohibited Purpose, before we may disclose your PHI to that agency.
|
Potential for Redisclosure.
|
If your PHI is disclosed to a recipient pursuant to any of the applicable purposes described above in this Section, it is possible that such PHI may be subject to further redisclosure by the recipient and no longer protected by the requirements of this Notice.
|
Meadow will not sell, rent, share, or otherwise disclose mailing lists or other personally identifiable information to any outside organization without your written authorization.
IV. Your Rights Regarding Your Medical Information
You have the following rights with respect to your PHI. To exercise any of these rights, please contact our Privacy Officer using the contact information provided at the end of this Notice.
Access to PHI.
|
You, or your authorized representative, have the right to inspect and copy your PHI maintained by us. You may retrieve copies of your PHI using an online patient portal or by requesting a copy of your information, in which case we may charge you a reasonable fee for the costs of copying, mailing, or other supplies that are necessary to fulfill your request. If we maintain an electronic health record containing your information, you have the right to request that we send a copy of your health information in electronic format to you or a third party that you identify, usually within 30 days of your request. We may deny access to certain information for specific reasons, for example, if the access requested is reasonably likely to endanger the life or safety of you or another person. If your request for information is denied, you may request that the denial be reviewed by filing a request for review with Meadow’s Privacy Officer.
|
Amend Your Protected Health Information.
|
You can ask us to correct or update health information in your record that you think is incorrect or incomplete. You may use the patient portal to correct patient information and request amendments to your record. All requests must be in writing and must explain why the information should be corrected or updated. We may deny your request under certain circumstances and provide a written explanation within 60 days.
|
Request Confidential Communications.
|
You can ask us to contact you in a specific way (for example, not leaving voicemail or texts, only calling before a certain time, sending mail to a different address). We will say “yes” to all reasonable requests, but please keep in mind that we cannot share private health information via text/SMS message or standard email. Our patient portal is a secure form of communications that may be used for this purpose. We reserve the right to verify your identity in order to confirm the alternative contact and address information.
|
Restrictions on Uses and Disclosures.
|
You can ask us not to use or share certain health information for treatment, payment, or our healthcare operations. We are not required to agree to your request, and we may say “no” if omitting information would affect your care. We will not disclose your PHI to persons involved in your care or payment for your case, such as a family member or close friend, unless you ask us to do so. We will honor your privacy request.
If a service or health care item is paid for in full without utilizing insurance benefits, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.
|
Get a list of those with whom we’ve shared your information.
|
You can ask for a list (accounting) of certain disclosures of your PHI made by us or our Business Associates for purposes other than treatment, payment, healthcare operations, and certain other activities.
The accounting will exclude disclosures we have made directly to you, disclosures to friends or family members involved in your care, disclosures made pursuant to a valid authorization, and disclosures for notification purposes. The request must be in writing, and the accounting will include disclosures made within the prior six (6) years. The first accounting you request within a twelve (12) month period will be provided free of charge, but you may be charged for the cost of providing additional accountings. We will notify you of the cost involved, and you may choose to withdraw or modify your request at that time.
|
Get a copy of this privacy notice.
|
You can ask for a paper or electronic copy of this notice at any time. We will provide you with a paper or electronic copy, as applicable, promptly.
|
V. Breach Notification
Meadow is required by law to notify you following the discovery that there has been a breach of your unsecured PHI, unless Meadow reasonably determines, after investigating the situation and assessing the risks presented, that there is a low probability that the privacy or security of your PHI has been compromised. You will be notified in a timely manner, no later than sixty (60) days after discovery of the breach, unless state law requires notification sooner.
VI. Changes to Our Notice of Privacy Practices
We reserve the right to amend our privacy practices and the terms of this Notice from time to time, provided such changes are permitted by applicable law, and such changes will apply to all PHI that we have about you. When changes are made, we will promptly post the updated Notice on the Meadow website at link above, and the new notice will be available upon request in our office. Please review this website periodically to ensure that you are aware of any updates.
VII. Compliance with Laws
If more than one law applies to this Notice, such as a more stringent state law, we will follow the more stringent law.
VIII. Questions and Complaints
If you have any questions or comments about our privacy practices or this Notice, or if you would like a more detailed explanation about your privacy rights, please contact Meadow Privacy Officer using the contact information provided at the end of this Notice.
If you believe that we may have violated your privacy rights, you may submit a complaint to our Privacy Officer.
If you feel we have been unable to provide satisfactory resolution, you can file a complaint by contacting:
U.S. Department of Health and Human Services Office for Civil Rights
200 Independence Avenue, S.W.
Washington, D.C. 20201
1-877-696-6775
https://www.hhs.gov/ocr/privacy/hipaa/complaints
We will not retaliate against you, and you will not be penalized in any way, if you choose to file a complaint with us or with HHS.
IX. Contact Information
When communicating with us regarding this Notice, our privacy practices, or your privacy rights, please contact the Privacy Officer using the following contact information:
Grace Reproductive Health Services d/b/a Meadow Reproductive Health & Wellness
Attn: Michael Scheinberg
1749 Old Meadow Rd Suite 600
McLean, VA 22102
703-783-3300
[email protected]
This notice is effective as of November 1, 2024.