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Medical Consultants Network, Inc. (MCN) Notice of Privacy Practices Effective Date: July 1, 2007 -------------------------------------------------------------------------------- This notice describes how health information about you may be used and disclosed and how you can get access to this information. If you have a complaint, or concern about your MCN assessment, or MCN’s privacy policy, MCN’s medical director or privacy official can be reached at 206 343-6100 or you may send a letter to MCN – Medical Director, 1200 6th Avenue - Suite 1800, Seattle WA 98101. Or you may call the privacy official at (206) 343-6100. Please refer to the document below for more details. PLEASE REVIEW IT CAREFULLY. Privacy Policy, HIPAA Compliance Graham-Leach-Bailey (GLB) and Health Insurance Portability and Accountability Act (HIPAA) MCN is committed to claimant confidentiality in everything we do. We have addressed Personal Health Information (PHI) in the three primary areas of our business: employees/vendors, consultants and systems. The company is HIPAA compliant and continuously strives to comply with the various State and Federal regulations regarding the handling of PHI. MCN has trained and maintains it’s training with all of its employees and has enacted internal policies to assure compliance. As a Business Associate of insurance companies, MCN has access to, creates and discloses Protected Health Information (PHI), the disclosure of which is restricted by the HIPAA Privacy Rule to only what is necessary for health care physician consultants or Business Associates to perform their job. Specific examples of PHI include names, addresses, telephone numbers, Social Security numbers, member IDs, license numbers, birth dates, facial photos and biometric information (fingerprints, DNA, or retinal scans). MCN enforces daily security measures to ensure HIPAA compliance. PHI should not be discussed or left in public spaces, and shredding bins must be used to dispose of PHI. Documents containing PHI may be transmitted outside of MCN using MCN’s in secure manners. Documents containing PHI may be faxed only to secure fax lines. They may also be mailed or delivered by an MCN-approved courier service. MCN employees encourage customers and consultants to use MCN eService and eChannel to access information necessary for completing their job. Each MCN employee has signed a confidentiality statement, which includes the following: MCN and its employees have an ethical and legal obligation to maintain full confidentiality regarding all information and related documents about patients or claimants evaluated at the company. Information about a patient or claimant will not be released to third parties other than the requesting customer, unless required by law, without a signed release from the patient or claimant. Casual conversation about individual patients must be avoided. Periodically patient materials may be used for teaching or marketing purposes. In such circumstances, sufficient information will be changed so as to render the patient and customer unidentifiable. Observation of exams by employees who are not medical professionals shall occur only with the written permission of the patient, or as requested by a physician as a chaperone. Non-medical professionals may not observe the physical examination of a patient of a different gender if any undressing of the patient is required beyond exposure of an extremity. When evaluated at MCN or an MCN consultant, a record of your visit is made. Typically, this record may contain a written report addressing symptoms, examination and test results, diagnoses, treatment, discussions on future care or treatment, work capacity, impairment rating and billing-related information. This notice applies to all of the records of your care generated by MCN consultants or the company. Our Responsibilities: We are required by law to maintain the privacy of your health information and provide you a description of our privacy practices. We will abide by the terms of this notice. Uses and Disclosures. The following categories describe examples of the way we use and disclose health information: For Assessment: We may use health information about you to assess your injury or disability claim. We may disclose health information about you to doctors, nurses, technicians, office staff and contractors who are involved in your assessment. We may share health information about you in order to coordinate the different things you may need, such as lab work, and x-rays, as well as to complete transcription of your evaluation. We will be providing a copy of your report to the referring agency or client who directed you to have this evaluation. With proper release, we may also provide your physician or a subsequent healthcare provider with copies of various reports that may assist him or her in treating you. In certain cases, your attorney or representative may receive a copy of your assessment. For Payment: We may use and disclose health information about your services to bill and collect payment from the referral source. For Health Care Operations: Members of the MCN staff and/or quality improvement team may use information in your health record to assess the services and outcomes in your case and others like it. The results will then be used to continually improve the quality of services for all those we serve. We may disclose information to doctors, nurses, and other students for educational purposes. We may remove information that identifies you from this set of health information to protect your privacy. We may also use and disclose health information: To business associates we have contracted with to perform the services;
To remind you that you have an appointment for medical assessment;
To assess your satisfaction with our services;
For conducting training programs or reviewing competence of health care professionals.
When disclosing information, we may leave messages on your answering machine/voice mail. Business Associates: There are some services provided in our organization through contracts with business associates. Examples include radiology and certain laboratory tests, as well as contracted transcription services. When these services are contracted, we may disclose your health information to our business associates so that they can perform the job we've asked them to do and bill for these services. To protect your health information, however, we require the business associate to appropriately safeguard your information. As required by law, we may also use and disclose health information for the following types of entities, including but not limited to: Food and Drug Administration
Public Health or Legal Authorities charged with preventing or controlling disease, injury or disability
Correctional Institutions
Workers Compensation Agents
Organ and Tissue Donation Organizations
Military Command Authorities
Health Oversight Agencies
Funeral Directors, Coroners and Medical Directors
National Security and Intelligence Agencies
Protective Services for the President and Others
Law Enforcement/Legal Proceedings: We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena. State-Specific Requirements: Many states have requirements for reporting including population-based activities relating to improving health or reducing health care costs. Some states have separate privacy laws that may apply additional legal requirements. If the state privacy laws are more stringent than federal privacy laws, the state law preempts the federal law. Your Health Information Rights - Although your health record is the physical property of the healthcare practitioner or facility that compiled it, you have the Right to: Inspect and Copy: You have the right to inspect and obtain a copy of the health information that may be used to make decisions about your care. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to health information, you may request that the denial be reviewed. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review. A fee, paid in advance will be required for copies of records before such records are delivered. Amend: If you feel that health information we have about you is incorrect or incomplete, you may ask us to amend the information, by providing additional information in writing which will be kept on file and provided to our client. We may deny your request for an amendment and if this occurs, you will be notified of the reason for the denial. An Accounting of Disclosures: You have the right to request an accounting of disclosures. This is a list of certain disclosures we make of your health information for purposes other than treatment, payment or health care operations where an authorization was not required. 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 may ask that we contact you at work instead of your home. MCN may grant reasonable requests for confidential communications at alternative locations and/or via alternative means only if the request is submitted in writing and the written request includes a mailing address. We reserve the right to contact you by other means and at other locations if you fail to respond to any communication from us that requires a response. We will notify you in accordance with your original request prior to attempting to contact you by other means or at another location. A Paper Copy of This Notice: You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. To exercise any of your rights, please submit your request in writing. Changes to this Notice: We reserve the right to change this notice and the revised or changed notice will be effective for information we already have about you as well as any information we receive in the future. The current notice will be posted at MCN offices and our website and include the effective date. In addition, each time you receive an evaluation at MCN, we will offer you a copy of the current notice in effect. Complaints: If you believe your privacy rights have been violated, you may file a complaint with MCN by addressing the complaint to: Privacy Officer, Medical Consultants Network, 1200 6th Avenue - Suite 1800, Seattle WA 98101. You may also file a complaint with the Secretary of the Department of Health and Human Services. All complaints must be submitted in writing. You will not be penalized for filing a complaint. Other Uses of Health Information: Other uses and disclosures of health information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the assessments or other services that we provided to you. MCN Privacy Officer Medical Consultants Network, Inc. 1200 6th Avenue, Suite 1800 Seattle, WA 98101 Phone: 206.343.6100 Fax: 206.812.6405
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