Privacy Policy

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We are required by law to maintain the privacy of your protected health information (PHI), to provide you with this Notice explaining our legal duties and privacy practices regarding your PHI, and to notify you following a breach of any unsecured PHI. This Notice describes how we may use and disclose your PHI and your rights and the obligations we have regarding the use and disclosure of your PHI.


We may use and disclose your PHI for treatment, payment and health care operations without your written authorization, for example:

Treatment – We may use or disclose your PHI information to arrange for your treatment or the coordination of your care within the Agency and others involved in your care, such as your attending physician and other healthcare professionals who agreed to assist the Agency in coordinating your care. For example, we may disclose PHI information to your physicians, pharmacists/pharmacies, and/or suppliers of medical equipment.

Payment – We may use and disclose your PHI to pay for the treatment and services you receive from the Agency; to determine your eligibility for benefits and to process claims for health care services you receive; including coordination of other benefits you may have. For example, thAgency may be required by your health insurer to provide information regarding services rendered so that the insurer can reimburse you or the agency. The Agency may also need to obtain approval from your insurer and may need to explain the personal assistance services required for your care.

Health Care Operations We may use and disclose your health information for certain internal business activities. For example, we may review the information we receive from your health care providers to evaluate how well our programs are working or to determine the need for and quality of health care services provided to you. Additionally, regulatory and accrediting organizations may review your PHI to ensure compliance with their requirements.

For Reminders and Other Information We may use your PHI to contact you to remind you about your appointments with providers who treat you, to give you information on treatment alternatives, and to provide you with information on other health-related benefits and services.


We are permitted and/or required to share your PHI, without your authorization in the following situations when certain conditions have been met:

Required by Law We may use or disclose your health information when and to the extent we are required by law to do so.

Business Associates Sometimes we arrange with individuals and businesses that are not part of Agency to perform certain functions on our behalf. These individuals and businesses (referred to as our “Business Associates”) are required to sign a contract with us to protect the privacy of your information and are not allowed to use or disclose any information other than as specified in our written agreement with them.

To Avert Serious Threat to Health/Safety We may use or disclose information when necessary to prevent a serious threat to your health or safety or the health and safety of the public or another person. Any disclosure, however, must be to someone who may be able to help prevent the threat.

Specialized Government Functions We may disclose your PHI requested by the federal government for specialized functions such as national security and intelligence activities, protective services for the President and others, and military and veteran activities.

Public Health Purposes We may disclose your PHI for public health purposes to a public health authority that is legally authorized to collect or receive your PHI for the purpose of preventing or controlling diseases, injury or disability, including but not limited to the reporting of diseases, births, and deaths.

Reporting Abuse/Neglect/Domestic Violence When required by law, we may disclose to authorities the PHI of anyone who we reasonably believe is a victim of abuse or neglect. Under Pennsylvania law, we are not permitted to report domestic violence to authorities without your written consent.

Health Oversight Activities We may disclose your PHI to a health oversight agency for activities authorized by law such as audits, investigations, licensing and inspections. These activities are needed for the government to oversee the healthcare system.

Judicial and Administrative Proceedings We may disclose your PHI in response to a court order, subpoena or administrative request.

Law Enforcement In certain circumstances, we may disclose your PHI to law enforcement officials in response to a court order, subpoena, warrant, or similar process. We also may disclose limited health information to law enforcement to identify or locate a suspect, fugitive, witness, or victim of a crime or to report a crime on our premises.

Research We may use or disclose your PHI for research purposes without your permission only after a special approval process that protects patient safety and confidentiality or if information that may directly identify you is removed. We also may allow researchers to look at records in our offices to help develop their research project or for related purposes, as long as the researchers do not remove the records from our offices or copy any PHI.

Food and Drug Administration (FDA) We may disclose your PHI to the FDA about problems with food, supplements, product and product defects, or post marketing surveillance information so that the FDA may call for product recalls, repairs, or replacements.

Workers Compensation We may disclose your health information as authorized by law to comply with laws relating to worker’s compensation or other similar programs established by law.

Coroners, Funeral Directors and Organ Donation We may disclose your information to a coroner or medical examiner for identification purposes, cause of death determinations, organ donation, and related reasons. We also may disclose information to funeral directors as needed to carry out their duties.

Reports If an employee or Business Associate believes in good faith that we engaged in unlawful conduct or otherwise violated professional or clinical standards and are potentially hurting individuals, workers or the public, we may disclose your PHI to an appropriate health oversight agency, public health authority or attorney.

Breach Notification We may use your contact information and other health information to investigate and notify you or government authorities of an unauthorized acquisition, use, or disclosure of or possible access to your health information.


In any situation not described above, we will not use or disclose any of your PHI without your written authorization. At any time, you may revoke your authorization, in writing. Your revocation will stop any future uses and disclosures of your PHI, except to the extent that uses/disclosures have been made prior to the revocation. We will not use or disclose your PHI for marketing and fundraising purposes without your authorization. This Agency will not sell your PHI.

You have the following rights regarding your PHI:

Right to Request Restrictions on the Use and Disclosure of your PHI
You have the right to ask us to limit the PHI we use or disclose about you for treatment, payment, or health care operations. You also have the right to ask us to limit PHI that we share with someone who is involved in your care or payment for your care, like a family member or friend. All requests to restrict how we use and disclose your PHI must be made in writing. We are not required to agree to your request. If we agree, we will comply with your request unless we notify you otherwise or the information is needed to provide you with emergency treatment.

To Receive Confidential Communications
You have the right to request that we communicate with you in certain ways (such as by letter or phone) or at a certain location. For example, you may ask that we only contact you at home or at work. Your request must be in writing and specify how or where you wish to be contacted. We will accommodate reasonable requests.

Right to Inspect and Receive a Copy of your PHI
You have the right to inspect and receive a copy of your PHI maintained and used by us to make decisions about your care. This includes your right to request a copy of your electronic medical record in electronic form. To inspect or receive a copy of your PHI, submit a written request to the address listed below. With a few exceptions, within the limits of confidentiality laws and regulations, we may deny your request to inspect and receive a copy of your PHI. If your request is denied, we will notify you in writing as to the reasons why. A reasonable fee may be charged for the expense of fulfilling your request as permitted under HIPAA and/or State law.

Right to Amend your PHI
If you feel that the PHI we maintain about you is incomplete or incorrect, you may request that we amend it. For example, if your date of birth is incorrect, you may request that the information is corrected. Your request to amend and/or correct your PHI must be made in writing and include the reason that supports your request. If we deny your request for an amendment, we will provide you with a written explanation as to why.

Right to Request an Accounting of Disclosure
You have the right to request an accounting of disclosures”. This is a list of persons or organizations to which we have disclosed your PHI to for certain purposes. Your request must be in writing and may cover any disclosures made in the six years before the date of your request. The agency will provide the first accounting request during any 12-month period without charge; while subsequent accounting requests may be subject to a reasonable costbased fee.

Services Paid for by You
Where you have paid for your services out of pocket in full, at your request, we will not share information about those services with a health plan for purposes of payment or health care operations.

Notification of Breach
You have a right to be notified in the event there is a breach of your unsecured PHI as defined by HIPAA.

Right to Ask for a Copy of this Notice
You may ask for a copy of this Notice at any time, including both paper and/or electronically. You can also access this Notice on our website.

In the event that a breach of your unsecured PHI occurs, you will be provided with written notification as required by law. If you believe your privacy has been violated by us, you may file a confidential complaint directly with us. You can do this by contacting the Privacy Officer at (215) 4277800 ext.1414. You also may file a complaint with:

V&V Management Solutions
2701 N Broad St 2nd Floor
Philadelphia, PA 19132
(267) 866-7300

U.S. Department of Health and Human Services
200 Independence Ave. S.W.
Washington, DC 20201
(800) 368-1019

Office of the State LongTerm Care Ombudsman
Pennsylvania Department of Aging
555 Walnut Street, 5th Floor
Harrisburg, PA 17101-1919
(717) 783-8975

You will not be retaliated against for filing a complaint.

The Agency is required to abide by the terms of this Notice of its duties and privacy practices. The Agency also reserves the right to change the terms of this Notice and to make the new Notice provisions effective for all PHI that it currently maintains as well as PHI that we receive in the future. The revised Notice will be posted on our websitat You may also obtain a revised notice by contacting us.

This Notice is effective 2012; Revised: 04/01/18

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