Privacy Policy

Notice of Privacy Practices Policy and Procedure

Policy Statement:
A resident has a right to adequate notice of the uses and disclosures of protected health information (PHI) that may be made by Holdrege Memorial Homes and of the resident’s rights and Holdrege Memorial Homes’ legal duties with respect to PHI. There are two exceptions to this right: exception for group health plans and exception for inmates.

Procedures:
Holdrege Memorial Homes’ Notice of Privacy Practice shall be developed and maintained by the Privacy Officer (Social Worker) and the HIPAA Compliance Officer. The Notice must be written in plain language and contain the required elements (see 164.520 (b)(1) for details):

• Holdrege Memorial Homes must promptly revise and distribute the Notice whenever there is a material change to the uses and disclosures, the resident’s rights, facility’s legal duties, or other privacy practices stated in the Notice. Except when required by law, a material change to any term of the Notice may not be implemented prior to the effective date of the Notice in which such material change is reflected.

• Holdrege Memorial Homes must make the Notice available upon request to any person. Additionally, if Holdrege Memorial Homes has a direct treatment relationship with an individual, Holdrege Memorial Homes must provide the Notice no later than the date of the first service delivery, including service delivered electronically, to such individual after the compliance date of the Privacy Rule (April 14,2003). Additionally, Holdrege Memorial Homes must have the Notice in a clear and prominent location (as determined by the Privacy Officer/Social Worker) where it is reasonable to expect individual seeking service from Holdrege Memorial Homes to read the Notice. Whenever the Notice is revised, the Notice shall be made available upon request on or after the effective date of the revision.

• Holdrege Memorial Homes must prominently post its Notice on the web site and make the Notice available electronically through the web site.

• Holdrege Memorial Homes may provide the notice to a resident by e-mail, if the resident agrees to electronic notice and such agreement has not been withdrawn. If Holdrege Memorial Homes knows that the e-mail transmission has failed, a paper copy of the Notice must be provided to the resident. The recipient of electronic notice retains the right to obtain a paper copy upon request.

• Holdrege Memorial Homes must document compliance with the Notice requirements by retaining copies of the Notices issued by the facility for six years from the date of its creation or the date it was last in effect, whichever is later. Copies of such Notices shall be maintained by the Privacy Officer or by the HIPAA Compliance Officer.