CCWB Privacy Policy

NOTICE OF POLICIES AND PRACTICES TO PROTECT  THE PRIVACY OF YOUR HEALTH INFORMATION 

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE  USED AND DISCLOSED AND HOW YOU CAN GET ACCES TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.

Rev. September 2022

Background 

The purpose of this notice (“Notice”) is to inform you of how your health information may be handled in  accordance with The Health Insurance Portability and Accountability Act of 1996 (also known by its  acronym, “HIPAA”). This law protects information about you or your medical condition that identifies you  as a patient (also referred to as “protected health information” or “PHI”). This Notice describes the privacy  practices that will be followed by Chester County Well-Being, and others who are permitted to use or  disclose your protected health information, as well as Chester County Well-Being’s legal obligations  regarding the use or disclosure of your protected health information and your rights with respect to  Chester County Well-Being’s use and disclosure of such information. 

Understanding Your Health Record & Health Information. 

Each time you visit a hospital, physician, or health care provider, a record of your visit is created. Typically,  this record contains your symptoms, examination and test results, diagnoses, treatment, and a plan for  future care or treatment. This information, often referred to as your health or medical record, serves as  a: 

• basis for planning your care and treatment; 
• means of communication among the many health professionals who contribute to your care;
• legal document describing the care you received; 
• means by which you or a third-party payer can verify that services billed were actually provided;
• tool in educating health professionals; 
• source of data for medical research; 
• source of information for public health officials charged with improving the health of the nation;
• source of data for facility planning and marketing;
• and/or tool with which we can assess and continually work to improve the care we render and the  outcomes we achieve.

Understanding what is in your record and how your health information is used helps you to: 

• ensure its accuracy; 
• better understand who, what, when, and why others may access your health information;
• and make more informed decisions when authorizing disclosure to others. 

Our Responsibilities. This organization is required to: 

• maintain the privacy of your protected health information; 
• provide you with a notice as to our legal duties and privacy practices with respect to information  we collect and maintain about you; 
• notify you following a breach of your unsecured protected health information;
• and abide by the terms of this Notice. 

We reserve the right to change this Notice and to make the revised Notice effective for all PHI currently  in our possession as well as any PHI we receive in the future. We will post a copy of the current Notice in  the facilities of each member of Chester County Well-Being and on our website. The Notice will contain  on the first page, in the top right-hand corner, the effective date. In addition, each time you register at or  are admitted to a participating entity for treatment or health care services you will be offered a copy of  the current Notice. Unless and until changes to the Notice are made, Chester County Well-Being is  required by law to comply with this Notice of Privacy Practices. You will be able to tell when changes have  been made to the Notice of Privacy Practices by referring to the upper right hand corner of the Notice,  which will include the revision date of that Notice. 

How We Use and Disclose your PHI 

Use and Disclosure of PHI For Treatment, Payment And Health Care Operations. 

We are permitted by law to use or disclose your PHI for treatment, payment and our health care  operations. Some examples of the ways in which we may use and disclose PHI for these purposes are  described below. These examples are not meant to be exhaustive, but to describe the types of uses and  disclosures that may be made by Chester County Well-Being. 

Use and Disclosure of PHI for Treatment 

Protected health information obtained or created by a physician, nurse or other member of your health  care team will be recorded in your medical record and used and disclosed to determine the course of  treatment and coordinate your care. Your physician may document a course of treatment in your record  along with his or her expectations about your response to the treatment. Members of your health care  team may then record the actions they carried out in relation to your care along with their observations  of your response to treatment. In that way, the treatment team can collaborate and understand how you  are responding to treatment. We may also provide your physician or a subsequent health care provider with copies of various reports that should assist in providing, coordination and managing your care in  other settings. 

Use and Disclosure of PHI for Payment 

A bill may be sent to you or a third-party payer or we may share information with a person who helps pay  for your care. The information on or accompanying the bill may include information that identifies you,  as well as your diagnosis, procedures, and supplies used. 

Use and Disclosure of PHI in support of our Health Care Operations 

In order to improve our health care operations, we may use and share PHI in connection with many quality  improvement activities. For example, members of the medical and clinical staff, members of the quality  improvement team, and participants in our organized health care arrangements may be use protected  health information to assess the care and outcomes in your case and others like it. This information would  then be used in an effort continually improve the quality and effectiveness of the health care and services  we provide. 

We may also use and disclose your PHI for: 

• Training purposes, to provide training and education to work force members and medical school  and other professional students involved at our facilities; 
• Appointment reminders, to contact you as a reminder that you have an appointment. 
• Health-related benefits and services, to manage and coordinate your care and inform you about  alternative treatments or other health-related benefits and services such as disease management  programs, wellness programs, or other community-based activities in which we participate,  including communications about entities affiliated with Chester County Well-Being. 

Marketing communications promoting health products or services if the communication is made face to  face with you or the only financial gain consists of a promotional gift of nominal value provided by Chester  Count Well-Being. 

Uses and Disclosures of Protected Health Information Requiring an Opportunity for You to Agree or  Object. 

We may use or disclose your PHI without your authorization in limited circumstances when you are  informed in advance of the use and disclosure and you have the opportunity to agree, object, or limit the  use or disclosure. Unless you advise us of your objection to these uses, we will assume that the use of  your PH, as described in this section of the Notice, is acceptable to you. The types of uses or disclosures  that require us to provide you with an opportunity to agree or object are set forth below. 

Directory: Chester County Well-Being does not have a facility directory in order to protect the privacy of  its pediatric patients. However, a process, to release information about the patient to the parent or  guardian is in place so information can be shared with the family or guardian over the telephone when  they are not able to be at the office. 

Notification: We may use or disclose protected health information to notify, identify, or locate a family  member, personal representative, or another person responsible for your care, to inform them of your  health status or condition, or death unless doing so is inconsistent with any prior expressed preference  that is known to us). We may disclose your protected health information to a public or private entity  authorized by law to assist in disaster relief efforts. If you are able and available to agree or object, we will  give you the opportunity to object prior to making this notification. If you are unable or unavailable to  agree or object, our health professionals will use their best judgment in communications with your family  and others. 

Communications with Family: Health professionals, using their professional judgment, may disclose to a  family member, other relative, close personal friend or any other person you identify, protected health  information relevant to that person’s involvement in your care or payment related to your care. These  disclosures will be limited to the protected health information that is directly relevant to the individual’s  involvement in your care or payment for your care. 

Other Permitted and Required Uses and Disclosures That May Be Made Without Your Authorization, or Without an Opportunity for You to Object. 

In certain circumstances, we may use or disclose your protected health information without your  authorization or objection. Some of the types of uses or disclosures that may be made without your  permission are listed below, but not every use or disclosure of this type is listed. 

Required by Law. We may disclose your protected health information to the extent state, federal, or local  law requires us to do so. 

Coroners, Medical Examiners and Funeral Directors. We may release PHI to a coroner or medical  examiner for the purpose of identifying a deceased person, determining the cause of death, or for the  coroner or medical examiner to perform other duties authorized by law. We may also disclose protected  health information about patents of Chester County Well-Being to funeral directors, as necessary to carry  out their duties. 

Workers Compensation. We may disclose your protected health information to the extent authorized by  and to the extent necessary to comply with laws relating to workers compensation or to other similar  programs established by law that provide benefits for work-related injuries or illnesses. 

Public Health. We may disclose your protected health information to public health authorities for public  health purposes. Some examples include: (i) preventing or controlling disease, injury, or disability; (ii)  reporting and prevention of abuse, neglect, or domestic violence; or (iii) providing notice to a person who  may be at risk for contracting or spreading a disease or condition and reporting disease or infection  exposure. 

Correctional Institution. Under certain circumstances, we may disclose your PHI to a correctional  institution or a law enforcement official having lawful custody of an inmate or other individual. 

Law Enforcement. We may disclose your PHI under limited circumstances for law enforcement purposes  such as: 

• identifying or locating a suspect, fugitive, material witness or missing person;
• responding to a court order, subpoena, warrant, summons or similar process;
• responding to a request for information about the victim of a crime; 
• responding to a request for information about a death we suspect may be the result of criminal  conduct; 
• responding to a request for information about criminal conduct on the premises of Chester  County Well-Being; 
• or in emergency circumstances to report a crime. 

Health Oversight Activities. Federal law makes provision for your protected health information to be  released to an appropriate health oversight agency or public health authority for oversight activities  authorized by law. 

Judicial and Administrative Proceedings. We may disclose your protected health information in the  course of any administrative or judicial proceeding, in response to a court or administrative order. In  response to a subpoena, discovery request, or other process by someone else involved in the dispute, we  may produce PHI when we receive assurances that efforts have been made to notify you and allow you  to object to the request or to obtain an order protecting the information requested. We will limit the  disclosure to the amount and type of information expressly required or authorized by the request. 

Public Safety. We may disclose your health information to appropriate persons in order to prevent or  lessen a serious and imminent threat to the health or safety of a particular person or the general public. 

National Security and Intelligence Activities. We may disclose protected health information about you to  authorized federal officials for intelligence, counterintelligence, and other national security activities  authorized by law, or other specialized government functions, for example, to protect the President,  certain other governmental persons or foreign heads of state. 

Uses and Disclosures of Protected Health Information Based Upon Your Written Authorization. 

We may make other uses and disclosures of your PHI not covered by this Notice. Unless otherwise  permitted or required by law, these uses and disclosures will be made only with your written  authorization. Such uses and disclosure requiring patient authorization include the following: 

Marketing. We must obtain your authorization prior to using or disclosing your PHI to make a  communication about a product or service that encourages recipients of the communication to purchase  or use the product or service, except as otherwise described in this Notice or as permitted by law. 

Sale of PHI. We must obtain your authorization prior to engaging in any activities that constitute a sale of  PHI not permitted under HIPAA.

Psychotherapy. Most uses and disclosure of your psychotherapy notes will require your written  authorization, except as otherwise described in this Notice or as permitted by law. 

If you give authorization for Chester County Well-Being to use or disclose your PHI, you may revoke that  authorization in writing at any time. If you revoke your authorization, we will no longer use or disclose PHI  as had been permitted by your written authorization. However, we are unable to take back any disclosures  we have already made in accordance with your authorization. 

Business Associates. 

We may disclose your PHI to third party “business associates” that perform various activities (e.g., billing,  insurance, accounting and medical transcription services) for or on behalf of Chester County Well-Being.  Our business associates may use, disclose, create, receive, transmit or maintain PHI during the course of  providing services to us. Like Chester County Well-Being, business associates are required under HIPAA  to protect your PHI. Nevertheless, we all also have a written agreement in place with business associates  governing their use and/or disclosure and the measures they must take to protect the privacy of your PHI. 

Preemption of Pennsylvania Law. 

The federal health care Privacy Regulations do not “preempt” (or take precedence over) state privacy or  other applicable laws that provide individuals greater privacy protections. As a result, to the extent state  law applies, or other federal laws that are more stringent than HIPAA, we may be required to operate  under that applicable privacy standard. 

Your Rights 

Although your health record is the physical property of Chester County Well-Being, the health care  practitioner or facility that compiled it, the PHI contained within your health record belongs to you. You  have the following rights with respect to your protected health information. 

The Right To Request Restriction Of Our Use and Disclosure. 

You have the right to request that we restrict the use or disclosure of protected health information about  you for treatment, payment or health care operations. You also have the right to request a limit on the  protected health information we disclose about your to someone who is involved in your care or the  payment or your care, like a family member or friend. For example, you could ask that we not use or  disclose information about a medication prescribed to you to a family member. However, Chester County  Well-Being is not required to agree to the restrictions that you may request. If we agree, we will comply  with your request unless the information is needed to provide you emergency treatment, or as otherwise  permitted by law. We will notify you if we do not agree to a request restriction. 

Notwithstanding the above, you may request, and unless otherwise required by law, Chester County Well Being must honor your request, to restrict disclosure of PHI to a health plan (e.g., insurance company) for payment or health care operations if you or someone other than the health plan paid in full for the related  items or services (i.e., out-of-pocket). Your request only applies to Chester County Well-Being. If you want  subsequent providers to abide by the same restriction, you must request the restriction from them and  pay out-of-pocket for items or services provided by them. Chester County Well-Being is not responsible  for notifying subsequent healthcare providers of your request for restrictions on disclosures to health  plans for items or services you pay to us out-of-pocket. 

To request restrictions, you must make your request in writing to our Privacy Officer, whose contact  information can be found at the end of this notice. In your request, you must tell us: 

• what information you want to limit, 
• whether you want to limit our use, disclosure or both, and 
• to whom you want the limits to apply – for example, disclosures to your spouse.

The Right To Request Alternative Means of Communication. 

You have the right to request that we communicate with you about medical matters by alternate means  or at an alternate location. For example, you may ask that we only contact you at your office or only by  mail. If your request is reasonable, we will accommodate it. To request alternative means or locations for  confidential communications, you must make your request in writing to our Privacy Officer, whose contact  information can be found at the end of this Notice. Your request must specify how and/or where you wish  to be contacted. 

The Right To Inspect And Copy Your Health Record. 

You have the right to inspect and obtain a copy of your PHI that may be used to make decisions about  your care. This information includes medical record, but does not include psychotherapy notes,  information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or  proceeding, or protected health information that is subject to a law prohibiting your access to such  information. 

To inspect and obtain a copy of protected health information, you must submit your request in writing to  our Privacy Officer and you may specify that you want your PHI in an electronic format. Chester County  Well-Being will provide you with a copy in a readable electronic format that Chester County Well-Being is readily able to produce. If you request a copy of the information, we may charge you a reasonable fee  for the costs of labor for copying, mailing, or other supply costs associated with your request. 

We may deny your request to inspect and obtain a copy in certain limited circumstances. If you are denied  access to protected health information, you may be able to request a review of that decision. Depending  on the circumstances, the decision to deny access may or may not be reviewable. If you make such a  request, we will notify you as to whether the decision is reviewable. If reviewable, a different licensed  health care professional chosen by Chester County Well-Being 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 that review. 

The Right To Amend Your Health Record. 

You have a right to request that Chester County Well-Being amend your health information that is used  to make decisions about you if you believe that it is incorrect or incomplete. You have the right to request  an amendment for so long as Chester County Well-Being keeps the information. 

To request an amendment, your request must be made in writing and submitted to our Privacy Officer. In  addition, we will require you to provide us with a reason for your request. 

We may deny your request for amendment if it is not in writing. We may also deny your request if it does  not include a reason to support the request. In addition, we may deny your request, in whole or in part,  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 protected health information used by Chester County Well-Being to make  decisions about you; 
• is not part of the information which you would be permitted to inspect and obtain a copy;
• or is accurate and complete. 

If your request to amend your medical information is denied, you may file a statement of disagreement  with us. You also have a right to a copy of our rebuttal statement, if we choose to prepare one. 

The Right To An Accounting of Disclosures. 

You have a right to receive an accounting of the disclosures of your protected health information made  by Chester County Well-Being. However, Chester Count Well-Being does not have to account for the  disclosures made: 

• for the purpose of treatment or payment or in support of health care operations unless HIPAA  provides otherwise; 

• to you or with your authorization; 
• incident to a use or disclosure otherwise permitted by this Notice; 
• so that we could include you in our directory listing, or notify or communicate with your family  members or others involved in your care as provided elsewhere in this Notice; 
• in support of national security and intelligence activities; 
• as part of a limited data set;
• or to correctional institutions or law enforcement officials as permitted by this Notice. 

To request an accounting of disclosures, you must submit your request in writing to our Hospital Privacy  Officer, whose contact information can be found at the end of this notice. Your request must include a  time period of no longer than six years for which you are requesting an accounting of disclosures. We will  provide an accounting for the period you request unless the period or right to receive the accounting is or may be limited under HIPAA. The first accounting you request within a 12-month period will be free.  For additional requests, we may charge you for the costs of providing the accounting. 

The Right To Notice of a Breach. 

You have the right to receive notice of any breach (i.e., the unauthorized use or disclosure) of your  unsecured PHI, as defined under HIPAA. 

The Right To A Paper Copy Of This Notice. 

You have a right to a paper copy of this Notice of Privacy Practices. Paper copies are available at our  administrative office of Chester County Well-Being. 

Complaints. If you believe your privacy rights have been violated, you can file a complaint with the Privacy Officer at:

There will be no retaliation for filing a complaint. For More Information. If you have questions and would like additional information, you may contact the  Privacy Officer at the address and telephone number listed above.

For More Information. If you have questions and would like additional information, you may contact the Privacy Officer at the address and telephone number listed above.