Notice of Privacy Practices Summary
 Effective 4/14/2003
Click here to download PPCP's Privacy Policy.

Preferred Primary Care Physicians (PPCP) is committed to protecting the privacy of your health care information, as federal and state laws require.  By “information,” we mean health, treatment, or payment information that identifies you.  Such information is also referred to as “protected health information” (PHI).  Attached is PPCP’s “Notice of Privacy Practices” (Notice).  The Notice explains how we protect your privacy.  It also explains your legal rights about the information in your health record.  All employees and office sites of PPCP must follow the Notice.  This summary tells you briefly what the Notice says and is not a complete account of how we share your health information.  PPCP has the right to change this Summary and the Notice without first notifying you. 

How PPCP (we) may use and share (disclose) your health information

Without your consent, PPCP can use and share your health information to:

• Provide you with medical treatment and other services related to your treatment
• Receive payments from you, an insurance company, or someone else for services we provide to you
• Operate PPCP, which includes such things as giving you appointment reminders, telling you about other treatment options, and contacting you for certain marketing activities
• Comply with the law
• Conduct research, only if approved as necessary and appropriate by a review board (also called an Institutional Review Board), which is obligated to protect human rights in research
• Cooperate in special situations, such as public health, safety, and disaster relief efforts.
• Exception: This does not include information about behavioral health, drugs and alcohol, and AIDS/HIV.

With your verbal agreement, PPCP can:

• Share your health information with family or friends you agree can have this information
• All other uses and sharing of you health information will be done only with your specific written permission or as required by law.

Your legal rights about your health information   

• Right to ask to see and copy your medical record
• Right to ask that we correct any information that is incorrect or incomplete
• Right to ask for a list of people or organizations, other than PPCP, with whom we shared your information.  You do not have a right to request this list in the following two circumstances:
• If we had your written permission to share the information
• If we shared information to carry out treatment, payment, and health care operations
• Right to ask PPCP to restrict how we use and share your information without your consent.  PPCP is not required to agree to your request.
• Right to ask for confidential commun-ications
• Right to ask for a paper copy of the Notice of Privacy Practices

If you believe your privacy rights have been violated, you have a right to file a complaint.  Please see the attached Notice for details.

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.

Preferred Primary care Physicians, Inc. (the “Practice”) is required by law to maintain the privacy of your medical information and to provide you with notice of its legal duties and privacy practices with respect to this information.  The purpose of this notice is to provide you with that information.

Any information that is about your health, the health care you receive, or payment for that care is considered confidential and protected by the Practice.  Such information that can identify you as an individual is “Protected Health Information” (PHI) under the law and will be treated as such by the Practice.  We are required to abide by the terms of the notice that is currently in effect at the time your medical information is used or disclosed.

We reserve the right to change the terms of this notice and to make the new notice provisions effective for all medical information that we maintain.We will post a copy of the current notice in our office.  In addition, each time you come to the Practice for treatment or health care services, you may request a copy of the current notice in effect.

The following is a description and example of the ways in which we may use and disclose your medical information, according to minimum necessary standards*, without obtaining member or member representative consent or authorization:

• Minimum Necessary Standard – the medical practice will make reasonable efforts to limit the PHI to  

        the minimum necessary amount to accomplish the intended use, disclosure or request.

• For Treatment:   We may provide medical information about you to health care providers, other Practice personnel, or third parties who are involved in the provision, management or coordination of your care.  For example:
• Health care Professionals: Your medical information will be shared among physicians and nurses involved in your care.
• Appointment Reminders:  We may use and disclose medical information to provide appointment reminders or information about treatment alternatives or other health-related benefits.
• For Payment:  We may use or disclose your medical information so that we can collect or make payment for the health care services you receive or are going to receive. For example:

• Insurance: If you participate in a health insurance plan, we will disclose necessary information to that plan to obtain preauthorization, if required, or payment for your care.

We may also disclose your medical information to another health care provider, a health plan, or a health care clearinghouse for the payment activities of that entity.  

• For Health Care Operations:  We may use or disclose your medical information for our activities and operations.  These uses and disclosures are necessary to run our practice and to make sure that all of our patients receive quality care.  For example:

• Quality Improvement: We may use or disclose your medical information to review the quality, efficiency and cost of care that we provide to our patients.  For example, we may use or disclose PHI to develop ways to assist our physicians and staff in deciding how we can improve the medical treatment we provide to others.

• Disease State Management: We may use or disclose your medical information to improve health care and lower costs for groups of people who have similar medical problems.  We may use PHI to identify groups of people with similar problems to give them information or provide educational classes about treatment alternatives.
• Cooperating with Outside Organizations: We may use or disclose your medical information to cooperate with outside organizations that evaluate, certify, or license health care staff (for example, we may use PHI so that a member of our research staff may become certified as having expertise in conducting research trials).
• Cooperating with People Who Review Our Activities: We may use or disclose your medical information to cooperate with others who review our service, such as doctors, accountants, consultants and lawyers who assist us in managing our business and complying with the law.
• Future Operations: We may use or disclose your medical information to assist us ion planning future operations.
• Resolving Grievances: We may use or disclose your medical information to assist in resolving grievances within our organization.
• Training Programs: We may use or disclose your medical information to provide training programs for students, trainees, health care providers, or non-health care professionals (for example, billing staff) to help them better learn and apply their skills.  
• Peer Review:  We may use or disclose your medical information to review the skills, qualifications and performance of health care providers caring for you and our other patients.
• Sale: We may need to disclose your medical information if we ever sell or transfer our practice.
• Business Planning and Development: We may use or disclose your medical information to assist us in business planning and development, such as cost-management analyses.
• Business Management and General Administrative Activities: We may use or disclose your medical information to assist us in business management and general administrative activities, such as managing our activities related to complying with the HIPPA Privacy and Security rules and other legal requirements.
• Creating De-Identified Information: We may use or disclose your medical information to assist us in creating de-identified information that is not identifiable to any individual.  Such information may be used in activities such as public health initiatives, quality improvement, research, market analyses and business planning.

For quality-related or fraud and abuse activities, if you have or had a relationship with another health care provider, a health plan, or a health care clearinghouse, we may also disclose your medical information to that entity for those types of health care operations.

I.    The following is a description of ways in which we may use and disclose your information or which an authorization or an opportunity to agree or object is not required:

• As Required By Law: We may use or disclose your medical information to the extent required by law, provided that the use or disclosure complies with and is limited to the relevant requirements of such law.

• Public Health Activities: To the extent authorized or required by law, we may disclose your medical information to a public health authority to report a birth, death, disease or injury, as part of a public health investigation, or to report child or adult abuse, or domestic violence.

To the extent authorized or required by the Food and Drug Administration (“FDA”), we may disclose your medical information to a person or organization authorized to report adverse events, track products, enable product recalls, repairs, or replacement, and/or conduct post marketing surveillance.  This means we may disclose to non-governmental persons information about the quality, safety and effectiveness of FDA regulated products and activities.

• Victim of Abuse, Neglect or Domestic Violence:  If we believe you have been a victim of abuse, neglect or domestic violence, we may disclose your medical information to a government authority.  We will make this disclosure if it is necessary to prevent serious harm to you or other potential victims, you are unable to agree due to your incapacity, you agree to the disclosure, or when required by law.

• Health Oversight Activities:  We may disclose medical information to a health oversight agency for activities authorized by law.  These oversight activities include but are not limited to, audits, investigations, inspections, and licensure.  These activities are necessary for appropriate oversight of the health care system, government benefit and regulatory programs, and compliance with civil rights laws.

• Judicial and Administrative Proceedings: We may disclose medical information about you as required by a court or administrative order, or under certain circumstances in response to a subpoena, discovery request or other legal process.

• Law Enforcement:  We may release medical information to law enforcement officials as required by the law. Under limited circumstances we may release your medical information to report a crime or in response to a court order, grand jury subpoena, warrant, or administrative request.

• Decedents: Consistent with applicable law, we may release medical information to a coroner, medical examiner, or funeral director.

• Organ, Eye and Tissue Donation: For the purpose of facilitating organ, eye or tissue donation and transplantation, we may use or disclose medical information to organizations that engage in procurement, banking, or transplantation of cadaveric organ, eye or tissue transplantation.

• Research: If a researcher has obtained the required waiver, from the Institutional Review Board or the Privacy Board, and has demonstrated that the information is necessary to the research and possesses a minimal risk of inappropriate use or disclosure, we may use and disclose medical information about you for research purposes.  If a researcher has not obtained the required waiver, we will not disclose your medical information without your written authorization, other than in a limited data, set as described below.

• Limited Data Set:  For purposes of research, public health, or health care operations, it may be necessary to use or disclose some of your medical information for activities or to persons we are not otherwise authorized to give your information to.  In this situation, we may use your medical information to create a limited data set in which certain required direct identifiers (such as your name) have been removed.  We will disclose the information in the limited data set for these purposes only if we have obtained satisfactory assurances from the recipient that the recipient will only use or disclose the information for limited purposes.

• To Avert a Serious Threat to Health or Safety:  We may use and disclose medical information about you when we believe in good faith disclosure is necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. 

• Specialized Government Functions:  Medical information may be disclosed for military and veterans affairs, for national security and intelligence activities, or for correctional activities.

• Workers’ Compensation:  We may release medical information about you as necessary to comply with laws relating to workers’ compensation or similar programs that are established by the law to provide benefits for work-related injuries or illness without regard to fault.

• Business Associates:  We may disclose your information to a person or organization that performs a function or activity on behalf of the Practice that involves the use or disclosure of protected health information, such as a billing services company.  In addition, no later than April 14, 2004, if a business associate is not a person or organization that we are otherwise permitted to disclose medical information to, we will only use or disclose your information to that person or organization if we have obtained adequate assurances that the business associate will appropriately safeguard the information. 

• Personal Representative: We may disclose your information to a person who has the authority, under the law, to act on your behalf in making decisions related to health care.

II.   The following is a description of ways in which we may use and disclose your information after we have given you an opportunity to object.  We will attempt to obtain your permission prior to making a disclosure for these purposes.  This permission may be oral.  If we are unable to obtain your permission because you are incapacitated or we are unable to reach you, we may use or disclose some or all this information, if (1) based on our professional judgment use or disclosure is in your best interest or (2) use or disclosure of this information is consistent with your previously expressed preference.

• Individuals Involved in Your Care or Payment for Your Care:  We may release relevant medical information about you to a friend or family member who is involved in your medical care.  We may also notify these individuals of your location, general condition, or death.

• Disaster Relief: 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.

Other uses and disclosure of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization.  You may revoke this authorization, in writing, at any time.  However, this revocation will not apply to the extent we have taken action in reliance on that authorization.  In addition, if the authorization was obtained as a condition of obtaining insurance coverage, the insurer will have a right to contest a claim under the policy.

• Right to Request Restrictions:  You have the right to request a restriction or limitation on the medical information we 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 for notification purposes or to someone who is involved in your care or the payment of your care, like a family member or friend.

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 a restriction, you must make your request in writing to our Privacy Officer.  The requested restriction will not be effective unless and until it has been reviewed and approved by the Privacy Officer.  For purposes of ensuring proper documentation, we may require that you make your request using a form that we give you.

We may terminate an agreed upon restriction without your consent.  In that situation, the restriction will only apply to protected health information created or received before you were informed of the termination of the restriction.

• The Right to Receive 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 our 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.  To comply with this request we may ask you to (1) provide information as to how payment will be handled and (2) specify an alternative method of contact.  For purposes of ensuring proper documentation, we may require that you make your request using a form that we give you.

• Right to Inspect and Copy:  You have the right to inspect and obtain a copy of most of your medical information maintained at the Practice; you must submit your request in writing to our Privacy Officer.  For purposes of ensuring proper documentation, we may require that you make your request using a form that we give you.  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 inspect and obtain a copy in certain limited circumstances.  If you are denied access, you may have the right to request that the denial be reviewed.  Another licensed health care professional* chosen by the Practice 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.

* Licensed Health Care Professional – may be a licensed physician within the Practice, other than the personal physician of the patient or the individual who denied access to the PHI.

• 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 the Practice.  To request an amendment, your request must be made in writing and submitted to our Privacy Officer.  In addition, you must provide a reason that supports your request.  For purposes of ensuring proper documentation we may require that you make your request using a designated form.

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 (1) was not created by us; (2) is not part of the medical information kept by or for the Practice; (3) is not part of the information which you would be permitted to inspect and copy; or (4) is accurate and complete.

• Right to an Accounting of Disclosures:  You have the right to request an accounting of certain disclosures.  This is a list of the disclosures we made of medical information about you. You have the right to request an accounting of certain disclosures by the covered entity that were made after April 14, 2003 and for a period of time less than six years from the date of your request.  To request an accounting you must submit a written request to our Privacy Officer.  Your request should indicate in what form you want the list (for example, on paper, electronically).  We will comply with your request within sixty (60) days or we will provide you with an explanation for the delay.  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. 

The right to an accounting does not apply to all disclosures.  For example, you do not have a right to an accounting of disclosures pursuant to an authorization, disclosures to carryout treatment, payment, or health care operations, or disclosures of a limited data set.

• 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.  Preferred Primary Care Physicians, Inc. maintains a Web site.  You may view an electronic copy of this notice on our website, www.ppcp.org.  To obtain a paper copy of this notice, you may print one from our website, ask for a copy at registration when you visit the Practice for services, or you may contact our Privacy Officer.

• Complaints: If you believe your privacy rights have been violated, you may file a complaint with the Practice or with the Secretary of the Department of Health and Human Services.  To file a complaint with the Practice, you must submit complaint in writing to our Privacy Officer at:

Privacy Officer
Preferred Primary Care Physicians, Inc.
1910 Cochran Road
Manor Oak II
Suite 490
Pittsburgh, PA 15220
(412) 531-2902
Fax (412) 531-2948
You will not be retaliated against for filing a complaint.

Questions?  For further information about matters covered by this notice you may contact our Privacy Officer at the above address or by telephone at: 412-429-7727 or 412-561-0692.