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      Lawrence + Memorial Hospital and Westerly Hospital

      Notice of Privacy Practices

      Effective September 1, 2013

      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.

      This Notice of Privacy Practices describes the privacy practices of Lawrence + Memorial Hospital, Westerly Hospital and satellite locations, departments and workforce members (collectively, the “Hospitals”). All facilities operated by Lawrence + Memorial Hospital and Westerly Hospital will follow this privacy notice. If you have questions about this notice please contact the Privacy Officer of the Hospitals at (860) 442-0711 ext. 4234 or the Patient Relations Department of the Hospitals at (860) 442-0711 ext. 5032.

      Our Pledge Regarding Medical Information

      We understand that medical information about you and your health is personal. We are committed to protecting medical information about you. We create a record of the care and services you receive. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated at the Hospitals.

      This notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.

      We are required by law to:

      • Make sure that medical information that identifies you is kept private in accordance with the law;

      • Notify you of a breach of your unsecured protected health information;

      • Give you this notice of our legal duties and privacy practices with respect to medical information about you; and

      • Follow the terms of the notice that is currently in effect.

      We must also obtain your written authorization before using your health information or sharing it with others outside of the Hospitals for:

        • Marketing. We may not disclose any of your health information for marketing purposes if the Hospitals will receive direct or indirect financial remuneration not reasonably related to the Hospitals’ cost of making the communication, without your written authorization.

        • Sale of Health Information. We will not sell your health information to third parties without your written authorization. The sale of health information, however, does not include a disclosure for public health purposes, for research purposes where the Hospitals will only receive remuneration for our costs to prepare and transmit the health information, for treatment and payment purposes, for the sale, transfer, merger or consolidation of all or part of the Hospitals, for a business associate or its subcontractor to perform health care functions on the Hospitals’ behalf, or for other purposes as required and permitted by law.

      How We May Use and Disclose Medical Information About You.

      The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

          • For Treatment. We may use medical information about you to provide you with medical treatment or services and to coordinate your continuing care. We may disclose medical information about you to doctors, nurses, technicians, medical students, or other personnel who are involved in taking care of you. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals. The Hospitals also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work, and x-rays. We also may disclose medical information about you to people outside of the Hospitals who may be involved in your medical care, such as family members, clergy or others we use to provide services that are part of your care.

          • For Payment. We may use and disclose medical information about you so that the treatment and services you receive may be billed to and payment may be collected from you, an insurance company, or a third party. For example, we may need to give your health plan information about surgery you received so your health plan will pay us or reimburse you for the surgery. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.

          • For Health Care Operations. We may use and disclose medical information about you for health care operations. These uses and disclosures are necessary to run the Hospitals and to make sure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, technicians, medical students, and other personnel for review and learning purposes. We may also combine the medical information we have with medical information from other hospitals and healthcare providers to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.

          • Business Associates. We may disclose medical information to a contractor or a business associate that needs the information to perform services for us. All business associates are required to sign a written agreement to keep this information confidential.

          • Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care.

          • Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

          • Health-Related Benefits and Services. We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

          • Fundraising Activities. We may use medical information about you to contact you in an effort to raise money for the Hospitals. We may disclose medical information to a foundation related to the Hospitals so that the foundation may contact you in raising money for the Hospitals. We only would release contact information, such as your name, address and phone number, the dates you received treatment or services, treating physician and outcomes. If you do not want to be contacted for fundraising efforts, you must notify The Development Office at Lawrence + Memorial Hospital in writing, via telephone or via email at development@lmhosp.org.

          • Future Communications. We may communicate to you via newsletters, mail outs, or other means regarding treatment options, health related information, disease management programs, wellness programs, or other community based initiatives or activities the facilities are participating in.

          • Organized Health Care Arrangement. The Hospitals and medical staff members operate as an organized health care arrangement. Information will be shared by members of the organized health care arrangement as necessary to carry out treatment, payment, and health care operations. For example, physicians and caregivers may access medical information maintained by the Hospitals in their offices to assist in reviewing past treatment as it may affect current or future treatment. Please note that these physicians are independent of the Hospitals and are not employees or agents of the Hospitals.

          • Electronic Health Information Exchange. The Hospitals maintain your medical information in electronic format and share your electronic medical information for treatment, payment, and health care operations, such as through electronic prescriptions. The Hospitals also disclose your electronic medical information over exchanges accessed by third parties. The exchange is required to comply with certain privacy and security requirements. For example, if you are treated by another provider who can access the exchange used by the Hospitals, we will disclose your electronic medical information to the other provider upon their request for purposes of treatment, payment, or health care operations.

          • Directory. If you are a patient at a facility that maintains a patient directory, we may include certain limited information about you in the directory. This information may include your name, your location in the facility, your general condition (e.g., good, fair, serious, critical, undetermined etc.), and your religious affiliation. The directory information, except for your religious affiliation, may be released to people who ask for you by name. Your religious affiliation may be given to a chaplain or representative of your faith community, such as a priest or rabbi, even if they don’t ask for you by name. This is so your family, friends, and clergy can visit you at the facility and generally know how you are doing.

          • Individuals Involved in Your Care or Payment for Your Care. Unless you object or request a restriction, we may release medical information about you to a friend or family member who is involved in your medical care or payment for your care. We may also tell your family or friends your condition and if you are being treated at one of the facilities. In addition, we may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, and location.

          • As Required By Law. We will disclose medical information about you when required to do so by federal, state, or local law.

          • To Avert a Serious Threat to Health or Safety. We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.

          • Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with patients' need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, but we may, however, disclose medical information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the medical information they review does not leave the facilities.

            Proof of Immunization.We may disclose proof of a child’s immunization to a school about a child who is a student or prospective student of the school, as required by state or other law, if a parent, guardian, other person acting in a parental or guardianship role, or an emancipated minor authorizes us to do so.

      Special Situations

          • Organ and Tissue Donation. If you are an organ donor, we may release medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

          • Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.

          • Workers' Compensation. We may release medical information about you to comply with workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.

          • Law Enforcement. We may release medical information if asked to do so by a law enforcement official:

            • In response to a court order, authorized subpoena, warrant, summons or similar process
            • To identify or locate a suspect, fugitive, material witness, or missing person
            • About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement
            • About a death we believe may be the result of criminal conduct
            • About criminal conduct at the facilities
            • In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.
          • Public Health Risks. We may disclose medical information about you for public health activities. These activities generally include the following:

            • To prevent or control disease, injury or disability
            • To report births and deaths
            • To report child abuse or neglect
            • To report reactions to medications or problems with products
            • To notify people of recalls of products they may be using
            • To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
            • To notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect, or domestic violence.

            We will only make these disclosures if you agree or when required or authorized by law.

          • Health Oversight Activities. We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

          • National Security and Intelligence Activities. We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

          • Protective Services for the President and Others. We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.

          • Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

          • Coroners, Medical Examiners and Funeral Directors. We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information about patients of the facilities to funeral directors as necessary to carry out their duties.

          • Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

      Special Records.

      For disclosures concerning health information relating to care for psychiatric conditions, certain substance abuse treatment, sexually transmitted diseases, genetic information or HIV-related testing or treatment, special restrictions may apply. For example, we generally may not disclose this specially protected information in response to a subpoena, warrant or other legal process unless you sign a special authorization or a court orders the disclosure.

            • HIV-Related Information: Special rules under Connecticut and Rhode Island law limit the disclosure of HIV-related information.

      Connecticut: This information may be disclosed for treatment and payment purposes. Your authorization will be necessary for most other disclosures, except for disclosures to certain public health officials, to committees or organizations conducting oversight or monitoring of the facilities, to address a significant occupational exposure or other disclosures permitted by Connecticut law

      Rhode Island: We may not disclose to a third party the result of an individual’s HIV test without prior written consent of that individual, or in the case of a minor, the minor’s parent, guardian, or agent, on a form that specifically states that HIV test results may be released. Accordingly, any result of HIV testing, positive or negative, or even that an HIV test was ordered or performed cannot be disclosed without specific written consent or a court order compelling the release.

          • Substance Abuse Treatment: If you are treated in a specialized substance abuse program, your authorization will be needed for most disclosures, except for treatment purposes among program personnel, to qualified personnel for limited health care operations purposes, to business associates performing services on our behalf, as well as for medical emergencies, meeting certain reporting requirements, research and other disclosures permitted by federal law.

          • Psychiatric Information: Connecticut and Rhode Island law provides special protections for psychiatric information. In both states, this information may be disclosed for your diagnosis or treatment in a mental health program, for business and administrative operations and limited information may be disclosed for payment purposes. Your authorization is needed for most other disclosures, unless the disclosure relates to certain legal proceedings where your psychiatric condition is relevant or is to government agencies charged with the oversight, administration and payment of mental health services in the state. Information maintained in psychotherapy notes is protected even further, and will not be disclosed without a specific written authorization, a court order or for limited reasons permitted by law.

          • Sexually Transmitted Diseases (Rhode Island only): Rhode Island law provides special protections for information regarding sexually transmitted diseases. We will not disclose information in your medical records pertaining to sexually transmitted diseases or testing for sexually transmitted diseases without your written authorization or a court order.

          • Genetic Testing (Rhode Island only):We will not release information pertaining to your genetic testing (as defined under Rhode Island law) without your prior written authorization.

      Your Rights Regarding Medical Information About You

      You have the following rights regarding medical information we maintain about you:

          • Right to Access, Inspect and Copy. You have the right to access, inspect, and copy medical information that may be used to make decisions about your care. Usually, this includes medical and billing records, but does not include psychotherapy notes. You also have the right to obtain an electronic copy of any of your medical information that we maintain in electronic format.

            • To access, inspect, and copy medical information that may be used to make decisions about you, you must submit your request in writing to the Health Information Management Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.

            • We may deny your request to access, inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by the Hospitals will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.

          • Right to Amend. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for the Hospitals.

            • To request an amendment, your request must be made in writing and submitted to the Health Information Management Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate. In addition, you must provide a reason that supports your request.

            • We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend 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 Hospitals;
              • Is not part of the information which you would be permitted to inspect and copy; or
              • Is accurate and complete.

            If a request is denied, we will provide a written statement of the reasons for the denial, and you have a right to submit a statement disagreeing with that decision.

          • Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures we made of medical information about you. Disclosures for treatment, payment, healthcare operations and according to authorizations you gave us to release your information are not included in this listing.

            • To request this list or accounting of disclosures, you must submit your request in writing to the Health Information Management Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate. Your request must state a time period which may not be longer than six years from today. Your request should indicate in what form you want the list (for example, on paper, 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.

          • Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had to your spouse.

            • You may require a restriction on disclosure of your medical information to a health plan (other than Medicare or other federal health care program that requires the Hospitals to submit information) for purposes of payment or other health care operations (but not treatment) if you paid out of pocket, in full, for the item or service to which the medical information pertains. Otherwise, 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 treatment.

            To request restrictions, you must make your request in writing to the Patient Access Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.

          • Right to 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 can ask that we only contact you at work or by mail.

            • To request confidential communications, you must make your request in writing to the Patient Access Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate. 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.

          • Right to Request Transmission of Your Medical Information in Electronic Format. You may direct us to transmit an electronic copy of your medical information that we maintain in electronic format to an individual or entity you designate. To request the transmission of your electronic medical information, you must submit the request in writing to the Health Information Management Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate.

          • Right to 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.

            • You may obtain a copy of this notice at Lawrence & Memorial Hospital's website, www.lmhospital.org or Westerly Hospital’s website, www.westerlyhospital.org.
            • To obtain a paper copy of this notice, please contact the Patient Access Department of Lawrence + Memorial Hospital or Westerly Hospital, as appropriate, the Patient Relations Department of the Hospitals, or the Privacy Officer of the Hospitals.

      Changes to this Notice

      We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in the facilities. The notice will contain on each page, in the top right-hand corner, the effective date. Should our notice be revised, we will also post the revised notice at Lawrence & Memorial Hospital's website, www.lmhospital.org, and Westerly Hospital’s website, www.westerlyhospital.org.

      Complaints.

      If you believe your privacy rights have been violated, you may file a complaint by contacting Patient Relations or the Privacy Officer of Lawrence & Memorial Hospital. You may also file a complaint with the Office of Civil Rights of the U.S. Department of Health and Human Services. The Privacy Officer can provide you with the correct address. All complaints must be submitted in writing.

      You will not be penalized for filing a complaint.

      Other Uses of Medical Information.

      Other uses and disclosures of medical 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 medical 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 medical information about you for the reasons covered by your written permission. 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 care that we provided to you.

      Contact Information

      Lawrence & Memorial Hospital:
      365 Montauk Avenue
      New London, CT 06320
      Main Number: 860-442-0711

          • Development Office: Ext. 2240
          • Health Access Management Department: Ext. 3063
          • Health Information Management Department: Ext. 2032
          • Patient Relations: Ext. 5032
          • Privacy Officer: Ext. 4234
          • Public Information/Relations: Ext. 2028

      Westerly Hospital:
      25 Wells Street
      Westerly, RI  02891
      Main Number: 401-596-6000

            • Health Information Management Department: 401-348-3262
            • Patient Access Department: 401-348-3209
            • Patient Relations Department: 860-442-0711 Ext. 5032
            • Privacy Officer: 860-442-0711, Ext. 4234