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Commonwealth Medical Group will provide an individual with a notice written in plain language of the uses and disclosures of protected health information that may be made by Commonwealth Medical Group and of the individual's rights and Commonwealth Medical Group's legal duties with respect to protected health information.
Commonwealth Medical Group will maintain the privacy of protected health information, will abide by the terms of the notice currently in effect and will provide the individual with any applicable revisions to the notice.
Commonwealth Medical Group Compliance Committee has developed and implemented a notice of privacy practices written in plain language and containing the elements required by the federal privacy rule.
Note: The federal privacy rule does not require Commonwealth Medical Group to provide the notice to an inmate.
Commonwealth Medical Group will make the Notice available on request to any person and to individuals as required by the federal privacy rule.
If Commonwealth Medical Group maintains a web site that provides information about their customer services or benefits, Commonwealth Medical Group will prominently post its Notice on the web site and make the Notice available electronically through the web site.
Commonwealth Medical Group may provide the Notice to an individual by e-mail, if the individual agrees to electronic Notice and the agreement has not been withdrawn. If Commonwealth Medical Group knows that the e-mail transmission has failed, a paper copy of the Notice will be provided to the individual.
When requested, Commonwealth Medical Group will provide a paper copy to an individual who is the recipient of an electronic Notice.
If Commonwealth Medical Group has a direct treatment relationship with an individual, Commonwealth Medical Group will provide the Notice:
- No later than the date of the first delivery of service, including service delivered electronically to such individual after the compliance date.
- In an emergency situation as soon as reasonably practicable after the emergency treatment situation. Document the emergency situation and the inability to obtain the individual’s written acknowledgement. Refer to Written Acknowledgement form
- Electronically if the first service of delivery to an individual is electronic. Commonwealth Medical Group will provide electronic Notice automatically and contemporaneously in response to the individual's first request for service.
If Commonwealth Medical Group has a direct treatment relationship with the individual, Commonwealth Medical Group will make a good faith effort to obtain a written acknowledgement of receipt of the Notice. Obtaining a written acknowledgement is not required in an emergency treatment situation. However, the acknowledgement will be obtained as soon as reasonably practicable after the emergency treatment situation. If the acknowledgement was not obtained, Commonwealth Medical Group will document its good faith efforts to obtain the acknowledgement and the reason why it was not obtained.
Commonwealth Medical Group will maintain the documentation of the written acknowledgement, the deferred acknowledgement due to an emergency treatment situation and/or that the acknowledgement was not obtained and the reason it was not obtained.
If Commonwealth Medical Group maintains a physical service delivery site, Commonwealth Medical Group will:
- Have the Notice available at the delivery site for the individual to request to take with them; and
- Post the Notice in a clear and prominent location where it is reasonable to expect the individual to be able to read the Notice.
If Commonwealth Medical Group revises the Notice, Commonwealth Medical Group will make the Notice available upon request on or after the effective date of the revision and promptly comply with the requirements of the federal privacy rule.
If Commonwealth Medical Group maintains a web site that provides information about their customer services or benefits, Commonwealth Medical Group will prominently post its Notice on the web site and make the Notice available electronically through the web site.
Commonwealth Medical Group may provide the Notice to an individual by e-mail, if the individual agrees to electronic Notice and the agreement has not been withdrawn. If Commonwealth Medical Group knows that the e-mail transmission has failed, a paper copy of the Notice will be provided to the individual
When requested, Commonwealth Medical Group will provide a paper copy to an individual who is the recipient of an electronic Notice.
Commonwealth Medical Group Compliance Committee will review the Notice annually or as needed to ensure compliance with the federal privacy rule.
To enable Commonwealth Medical Group to make changes in a privacy practice that is stated in the Notice, the Notice will contain a statement that Commonwealth Medical Group reserves the right to make changes in its privacy practices.
If Commonwealth Medical Group makes a change to the Notice, Commonwealth Medical Group will promptly make the appropriate revisions to the Notice and make the revised notice available in accordance with the federal privacy rule.
If the Notice does not contain a statement reserving the right of Commonwealth Medical Group to change a privacy practice that is stated in the Notice, Commonwealth Medical Group is bound by the privacy practices as stated in the Notice with respect to protected health information created or received while the notice is in effect.
Commonwealth Medical Group may change a privacy practice and the related policies and procedures without having reserved the right to do so provided that:
- Such change meets the implementation requirements under the Administrative Requirement standard that allows a change in a privacy practice under the federal privacy rule; and
- The change is only effective with respect to protected health information created or received after the effective date of the Notice.
Commonwealth Medical Group will promptly revise and distribute its Notice whenever there is a material change to:
- The uses or disclosures;
- The individual's rights;
- Commonwealth Medical Group's legal duties; or
- Other privacy practices stated in the Notice.
Except when required by the federal privacy rule, a material change to any term of the Notice may not be implemented prior to the effective date of the Notice in which the material change is reflected.
Employees will be trained on the policies and procedures related to the Notice of Privacy Practices.
Commonwealth Medical Group will file a copy of the original Notice and a copy of all revised Notices in Commonwealth Medical Group’s compliance file. If the Notice is in writing or electronic, Commonwealth Medical Group will retain a copy of the written or electronic Notice in Commonwealth Medical Group’s compliance file.
Note: Commonwealth Medical Group is not required to file a copy of the Notice in the patient’s chart.
Since Commonwealth Medical Group is a direct treatment provider, Commonwealth Medical Group will retain any written acknowledgements of receipt of the Notice or documentation of good faith efforts to obtain such written acknowledgement.
The documentation will be maintained for eight years from the date of its creation or the date when it was last in effect, whichever is greater. |
