COMPREHENSIVE COMMUNITY HEALTH CENTERS
NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION ABOUT YOU MAY BE USED
AND DISCLOSED AND HOW YOU CAN ACCESS YOUR MEDICAL INFORMATION.
PLEASE REVIEW CAREFULLY.

Comprehensive Community Health Centers, Inc. (“CCHC”) and its medical practices retain health information, including, but not limited to demographic, physical and mental health, and payment of health care information, about you and store said health information physically and electronically, by and through medical record documents, charts, images and its computers and servers. This is your medical record and health information (hereinafter, your “PHI”). While the information in the physical and electronic medical records belongs to you, the medical records themselves are the property of CCHC. We are committed to preserving the privacy and confidentiality of your PHI, which is created and/or maintained at our medical offices. State and federal laws and regulations require us to implement policies and procedures to safeguard the privacy of your PHI. This includes any information that we receive from other health care providers or facilities. This Notice describes the ways in which we may use or disclose your PHI and also describes your rights, and our obligations concerning such uses or disclosures.

HOW WE MAY USE OR DISCLOSE YOUR PHI

Treatment: We use your PHI to provide your medical care. Your PHI is disclosed on an as need basis to our employees and others who are involved in providing the care you need. For example, we may share your PHI with other physicians, health care providers, a laboratory or a pharmacist who will provide services that you need. We may also disclose your PHI in an emergency situation, or if you are incapacitated or not present, to a family member, close personal friend, authorized disaster relief agency, or any other person previous identified by you. We will use professional judgment and experience to determine if the disclosure is in your best interest. If the disclosure is in your best interest, we will only disclose the PHI that is directly relevant to the person’s involvement in your care.

Payment: We use and disclose your PHI to obtain payment for the services we provide. For example, we give your health plan the PHI it requires to receive payment for said services. We may also disclose your PHI to obtain prior approval for the services we provide to you, to determine whether your health plan will pay for the treatment, and to assist other health care providers in obtaining payment for services they have provided to you. You may restrict the disclosure of your PHI to your health plan should you choose to pay for said services out of pocket.

Health Care Operations: We may use and disclose your PHI for operation purposes. For example, your PHI may be disclosed to the medical staff, risk, financial, legal or quality improvement personnel, to, but without limitation:

• Evaluate the performance of our staff, and for training purposes;
• Assess the quality of care and outcomes in your cases and similar cases;
• Learn how to improve our facilities and services;
• Business planning, management, development and general administration activities; and
• Improve the quality and effectiveness of the health care we provide.

Appointment Reminders: We may use or disclose your PHI to contact and remind you about appointments. If you are not home, we may leave this information on your answering machine or with the person answering the phone.

Individuals Involved in Your Care or Payment for Your Care: If and when appropriate, we may share your PHI with a person who is involved in your medical care or payment for your care, or providing translation, such as a family member or a friend you may bring with you. We may make such disclosures when:

• We have your verbal agreement to do so;
• We make such disclosures and you do not object; or
• We can infer from the circumstances that you would not object to such disclosures, for example if that person comes into the exam room with you. We also may notify your family about your location or general condition or disclose such information, in an emergency, to an entity assisting in a disaster relief effort. If you are unable or unavailable to agree or object, our health professionals will use their best judgment in communication with your family and others.

Marketing: We may contact you to give you information about product or services related to your treatment, case management or care coordination, or to direct or recommend other treatments or health-related benefits and services that may be of interest to you, or to provide you with promotional items. We may encourage you to purchase a product or service when we see you.

THERE ARE CERTAIN INSTANCES IN WHICH WE MAY BE REQUIRED OR PERMITTED BY LAW TO USE OR DISCLOSE YOUR PHI WITHOUT YOUR PERMISSION.

WE MAY DISCLOSE YOUR PHI IN ACCORDANCE TO THIS SECTION IN THE FOLLOWING INSTANCES:

As Required By Law: When required by federal, state, or local law to do so. For example, among other examples, when the law requires us to report abuse, neglect or domestic violence, or respond to judicial or administrative proceeding, or to law enforcement officials.

Public Health Activities: To public health authorities that are authorized by law to receive and collect for the purpose of preventing or controlling disease, injury or disability; to report births, deaths, suspected abuse or neglect, reactions to medications; or to facilitate product recalls.

Health Oversight Activities: 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 law.

Inmates Or Individuals In Custody: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release your PHI to the correctional institution or law enforcement official. This release would be made if 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.

Judicial Or Administrative Proceedings: To courts or administrative agencies charged with the authority to hear and resolve lawsuits or disputes. We may disclose your PHI pursuant to a court order, a subpoena, a discovery request, or other lawful process.

Law Enforcement Official: In response to a request received from a law enforcement official to report criminal activity or to respond to a subpoena, court order, warrant, summons, or similar process.

Decedents: To funeral directors, coroners or medical examiners to enable them to carry out their lawful duties. For example, for identifying a deceased individual or to determine the cause of death.

Organ or Tissue Donations: If you’re an organ donor we may disclose your PHI to organizations involved in procuring, banking or transplanting organs and tissues.

Public Safety: When necessary to prevent a serious threat to the health or safety of you or other individuals pursuant to applicable law.

Threats to Health and Safety: If we believe, in good faith, that the use or disclosure is necessary to prevent or lessen a serious or imminent threat to health or safety of a person or the public.

Victims of Abuse and Neglect: To a local, state, or federal government authority, including social services or a protective services agency authorized by law to receive such reports if we have a reasonable belief of abuse, neglect or domestic violence.

Workers’ Compensation: In order to comply with laws and regulations related to Workers’ Compensation.

Change of Ownership: In the event that this medical practice is sold or merged with another organization, your PHI will become the property of the new owner, although you will maintain the right to request that copies of your PHI be transferred to another physician or medical group.

Group Health Plan/Plan Sponsor Disclosures: To a sponsor of the group health plan, such as an employer or entity that is providing a health care program to you, if the sponsor has agreed to certain restrictions on how it will use or disclose the protected health information (such as agreeing not to use the protected health information for employment-related actions or decisions).

Research: For research under certain circumstances. For example, a research project may involve comparing the health of patients who receive one treatment to those who received another for the same condition. Before we use or disclose your PHI for research, the project will go through a special approval process. Even without special approval, we may permit researchers to look at records to help them identify patients who may be included in their research project for other similar purposes, as long as they do not remove or take a copy of any health information.

Additional Restrictions on Use and Disclosure: Some federal and state laws may require special privacy protections that restrict the use and disclosure of certain types of health information. Such laws may protect the following types of information: alcohol and substance use disorders, biometric information, child or adult abuse or neglect including sexual assault, communicable disease, genetic information, HIV/AIDS, mental health, minors’ information, prescriptions, reproductive health, and sexually transmitted diseases. We will follow the more stringent law, where it applies to us.

USE AND DISCLOSURES PURSUANT TO YOUR WRITTEN AUTHORIZATION

Except as described in this Notice of Privacy Practices, this medical practice will not use or disclose your PHI which identifies you without your written authorization. If you do authorize this medical practice to use or disclose your PHI for another purpose, you may revoke your authorization in writing at any time, except to the extent that we have already taken some action in reliance upon your authorization. We will request your written authorization to use or disclose any of your psychotherapy notes that we may have on file with limited exception, such as for certain treatment, payment or healthcare operation functions.

YOUR PHI

You have the following rights regarding your PHI

Right To Inspect And Copy: You have a right to inspect and copy your PHI that may be used to make decisions about your care or payment for your care. We may deny your request to inspect and copy your PHI in certain limited circumstances. If you are denied access to your PHI, you may request that the denial be reviewed. To inspect and copy your PHI, you must make your request in writing. We will charge a fee, as allowed by California law.

Rights To Amend Or Supplement: You have the right to request an amendment of your PHI that is maintained by or for our medical office and is used to make health care decision about you. We may deny your request if it is not properly submitted or does not include a reason to support your request. We may also deny your request if the information sought to be amended:

• Is inaccurate and incomplete;
• Is not part of the information which you are permitted to inspect and copy; or
• Was not created by us. unless the person or entity that created the information is no longer available to make the amendment. To request and amendment, you must make your request in writing.

Right To An Accounting Of Disclosures And Notification Of Breach: You have the right to request a list of certain disclosures we made of your PHI for purposes other than treatment, payment, and health care operations or for which you provided written authorization. To request an accounting of disclosures, you must make your request in writing. You also have a right to be notified of any breach and wrongful disclosure of your protected PHI.

Right To Request Restrictions: You have the right to request restrictions on certain uses and disclosures of your PHI. A written request is required specifying what information you want to limit and what limitations you would lie to impose on our use or disclosure of that information, except with regards to payment for services. We reserve the right to accept or reject your request. If we do agree, that agreement must be signed by you and an authorized representative of this medical practice.

Right To Request Confidential Communication: 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 contact you only by mail or at work. To request confidential communication, you must make your request in writing. We will accommodate reasonable requests submitted in writing which specify how or where you wish to receive these communications.

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.

Right To Request Alternative Method of Contact: You have the right to request in writing that we contact you at a different location or using a different method.

OUR OBLIGATIONS

• Maintain the privacy of protected health information;
• Provide you with the Notice of our legal duties and privacy practices with respect to your PHI;
• Abide by the terms in this Notice;
• Notify you if we are unable to agree to a requested restriction on how your PHI is used or disclosed; and,
• Accommodate reasonable requests you may make to communicate your PHI by alternative means or at alternative locations.

CHANGE TO THIS NOTICE

We will abide by the terms of this Notice, including any future revisions that we may make to the Notice as required or authorized by law. We reserve the right to change this Notice and to make the revised or changed Notice effective for health 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, identified by its “effective date”, in our medical office. Be sure to request a copy of the most current (amended or revised) Notice on your first visit following the effective date.

QUESTIONS OR COMPLAINTS

If you have any questions regarding this Notice or wish to receive additional information about our privacy practice, please ask the receptionist for our Privacy Officer. If you believe you privacy rights have been violated, you may file a complaint with our onsite Privacy Officer. If a favorable resolution has not been reached, you may contact our Compliance Officer at:

All complaints must be submitted in writing. Upon request the Compliance Officer will provide you with the appropriate forms. You will not be penalized for filing a complaint.

If you do not believe your complaint was properly resolved by us, you may file a complaint with the following governmental agency: