Notice of Privacy Practices

Our Commitment to Your Privacy

This Notice of Privacy Practices (“Notice”) describes how this Ambulatory Surgery Center (“ASC,” “we,” “our,” or “us”) may use and disclose your protected health information (“PHI”), your rights regarding your health information, and our legal obligations under the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health (HITECH) Act, and applicable Florida law.

We understand that medical information about you and your health is personal. We are committed to protecting your privacy and maintaining the confidentiality of your health information.

We are required by law to:

• Maintain the privacy and security of your protected health information.
• Provide you with this Notice of our legal duties and privacy practices.
• Follow the terms of this Notice currently in effect.
• Notify you following a breach of unsecured protected health information when required by law.

Protected health information includes information that identifies you and relates to your past, present, or future physical or mental health condition, healthcare services, or payment for healthcare services.

How We May Use and Disclose Your Health Information

The following categories describe ways we may use and disclose your health information without obtaining your written authorization.

Treatment

We may use and disclose your health information to provide, coordinate, or manage your healthcare and related services.

Examples include:

• Sharing information with physicians, surgeons, anesthesiologists, CRNAs, nurses, technicians, and other healthcare professionals involved in your care.
• Providing laboratory, pathology, radiology, or diagnostic services.
• Referring you to another healthcare provider.
• Communicating with your primary care physician or specialist regarding your treatment.

Payment

We may use and disclose your health information to obtain payment for healthcare services provided to you.

Examples include:

• Billing your insurance company.
• Determining insurance eligibility or coverage.
• Obtaining prior authorization.
• Collecting unpaid balances.
• Reviewing services for medical necessity.

Healthcare Operations

We may use and disclose health information for healthcare operations necessary to run our facility and ensure quality care.

Examples include:

• Quality assessment and performance improvement activities.
• Infection prevention and control activities.
• Risk management and patient safety programs.
• Peer review and credentialing activities.
• Accreditation surveys and compliance reviews.
• Staff training and education.
• Business planning and administrative activities.

Appointment Reminders and Follow-Up Care

We may contact you regarding:

• Upcoming procedures.
• Pre-operative instructions.
• Post-operative follow-up care.
• Satisfaction surveys.
• Information about treatment alternatives or health-related benefits and services.

Communication may occur by telephone, voicemail, text message, patient portal, email, or mail.

Individuals Involved in Your Care

Unless you object, we may disclose relevant information to:

• Family members
• Relatives
• Close personal friends
• Individuals involved in your care or payment for your care

If you are unable to agree or object due to an emergency or incapacity, we may use our professional judgment to determine whether disclosure is in your best interest.

Business Associates

We may disclose health information to contractors and vendors who perform services on our behalf, such as:

• Billing companies
• Electronic health record providers
• Quality consultants
• Accreditation consultants
• Information technology providers
• Collection agencies
• Transcription services

These organizations are required by law and contract to protect your information.

As Required by Law

We may disclose health information when required by federal, state, or local law.

Examples include disclosures required by:

• Florida Department of Health
• Florida Agency for Health Care Administration (AHCA)
• Centers for Medicare & Medicaid Services (CMS)
• Public health authorities
• Law enforcement agencies
• Court orders or subpoenas

Public Health Activities

We may disclose information for public health purposes, including:

• Reporting communicable diseases
• Reporting adverse events
• Reporting vital statistics
• Preventing or controlling disease
• Reporting abuse, neglect, or domestic violence when authorized by law

Health Oversight Activities

We may disclose information to government agencies that oversee healthcare systems, licensing, accreditation, and regulatory compliance.

Examples include:

• AHCA inspections
• Medicare surveys
• Professional licensing boards
• Office for Civil Rights investigations

Law Enforcement

We may disclose health information for certain law enforcement purposes, including:

• Compliance with court orders or warrants
• Reporting crimes occurring on our premises
• Identifying or locating missing persons
• Responding to lawful requests from law enforcement officials

Judicial and Administrative Proceedings

We may disclose health information in response to:

• Court orders
• Administrative orders
• Subpoenas
• Discovery requests
• Other lawful processes

Organ and Tissue Donation

If applicable, we may disclose information to organizations involved in organ procurement, eye donation, or tissue donation.

Research

Under certain circumstances, we may use or disclose health information for research purposes when approved by an Institutional Review Board or when otherwise permitted by law.

Serious Threat to Health or Safety

We may disclose health information when necessary to prevent or lessen a serious and imminent threat to your health and safety or the health and safety of another person or the public.

Workers’ Compensation

We may disclose health information as authorized by workers’ compensation laws and similar programs.

Uses and Disclosures Requiring Your Written Authorization

Except as described in this Notice, we will obtain your written authorization before using or disclosing your health information for:

Marketing Purposes

Most uses and disclosures for marketing purposes require your written authorization.

Sale of Protected Health Information

We will not sell your protected health information without your written authorization.

Your Rights Regarding Your Health Information

You have the following rights regarding your protected health information.

Right to Inspect and Obtain Copies

You have the right to inspect and obtain copies of your health records maintained by the ASC, subject to certain legal limitations.

Requests must be submitted in writing.

Reasonable fees may apply as permitted by law.

Right to Request Amendments

If you believe information in your record is incorrect or incomplete, you may request that we amend the information.

Requests must be submitted in writing and explain the reason for the amendment.

Right to an Accounting of Disclosures

You may request a list of certain disclosures made by us that are not related to treatment, payment, healthcare operations, or otherwise exempt under HIPAA.

Right to Request Restrictions

You may request restrictions on certain uses and disclosures of your health information.

While we are not required to agree to every request, we will comply when required by law.

If you pay for a service entirely out-of-pocket, you may request that information related solely to that service not be disclosed to your health plan for payment or healthcare operations purposes.

Right to Request Confidential Communications

You may request that communications be sent to you by alternative means or at alternative locations.

Examples include:

• Communication at a work address
• Communication by cell phone only
• Communication through a designated family member

Reasonable requests will be accommodated.

Right to Receive a Paper Copy of This Notice

You may request a paper copy of this Notice at any time, even if you previously agreed to receive it electronically.

Right to Receive Breach Notification

You have the right to be notified if your unsecured protected health information is breached in a manner requiring notification under federal or state law.

Complaints

If you believe your privacy rights have been violated, you may file a complaint without fear of retaliation.

Contact Our Privacy Officer

You may also file a complaint with:

We will not retaliate against you for filing a complaint.

Changes to This Notice

We reserve the right to change this Notice and make the revised Notice effective for all protected health information we maintain.

The current version of this Notice will be available at the facility and upon request.