·Prescriptions for narcotics or DEA (Drug Enforcement Administration) (http://www.deadiversion.usdoj.gov/schedules/) controlled substances  (Schedule I, II, III);

·Prescriptions for medications for psychiatric illnesses; and

·Prescriptions for lifestyle medications such as erectile dysfunction or diet drugs.

Treatment means the provision, coordination or management of your health care, including consultations between health care providers relating to your care and referrals for health care from one health care provider to another.

Payment means the activities we undertake to obtain reimbursement for the health care provided to you, including billing, collections, claims management, determinations of eligibility and coverage and other utilization review activities.  For example, we may need to provide PHI to your Third Party Payor to determine whether the proposed course of treatment will be covered or if necessary to obtain payment.  Federal or state law may require us to obtain a written release from you prior to disclosing certain specially protected PHI for payment purposes, and we will ask you to sign a release when necessary under applicable law.

Health care operations means the support functions of the Physicians, related to treatment and payment, such as quality assurance activities, case management, receiving and responding to patient comments and complaints, physician reviews, compliance programs, audits, business planning, development, management and administrative activities.  For example, we may use your PHI to evaluate the performance of our staff when caring for you.  We may also combine PHI about many patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose PHI for review and learning purposes.  In addition, we may remove information that identifies you so that others can use the de-identified information to study health care and health care delivery without learning who you are.

• To provide appointment reminders for treatment or medical care.
• To tell you about or recommend possible treatment alternatives or other health-related benefits and services that may be of interest to you.
• To your family or friends or any other individual identified by you to the extent directly related to such person’s involvement in your care or the payment for your care.  We may use or disclose your PHI to notify, or assist in the notification of, a family member, a personal representative, or another person responsible for your care, of your location, general condition or death.  If you are available, we will give you an opportunity to object to these disclosures, and we will not make these disclosures if you object.  If you are not available, we will determine whether a disclosure to your family or friends is in your best interest, taking into account the circumstances and based upon our professional judgment.
• When permitted by law, we may coordinate our uses and disclosures of PHI with public or private entities authorized by law or by charter to assist in disaster relief efforts.
• We may use or disclose your PHI for research purposes, subject to the requirements of applicable law.  For example, a research project may involve comparisons of the health and recovery of all patients who received a particular medication.  All research projects are subject to a special approval process which balances research needs with a patient’s need for privacy.  When required, we will obtain a written authorization from you prior to using your health information for research.
• We will use or disclose PHI about you when required to do so by applicable law.
• In accordance with applicable law, we may disclose your PHI to your employer if we are retained to conduct an evaluation relating to medical surveillance of your workplace or to evaluate whether you have a work-related illness or injury.  You will be notified of these disclosures by your employer or the Physicians as required by applicable law.

Organ and Tissue Donation.  If you are an organ donor, we may release PHI to organizations that handle organ procurement or transplantation as necessary to facilitate organ or tissue donation and transplantation.

Military and Veterans.  If you are a member of the Armed Forces, we may release PHI about you as required by military command authorities.  We may also release PHI about foreign military personnel to the appropriate foreign military authority.

Worker’s Compensation.  We may release PHI about you for programs that provide benefits for work-related injuries or illnesses.

Public Health Activities.  We may disclose PHI about you for public health activities, including disclosures:

• to prevent or control disease, injury or disability;

• to report births and deaths;

• to report child abuse or neglect;

• to persons subject to the jurisdiction of the Food and Drug Administration (FDA) for activities related to the quality, safety, or effectiveness of FDA-regulated products or services and to report reactions to medications or problems with products;

• to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;

• to notify the appropriate government authority if we believe that an adult patient has been the victim of abuse, neglect or domestic violence.  We will only make this disclosure if the patient agrees or when required or authorized by law.

Health Oversight Activities.  We may disclose PHI to federal or state agencies that oversee our activities (e.g., providing health care, seeking payment, and civil rights).

Lawsuits and Disputes.  If you are involved in a lawsuit or a dispute, we may disclose PHI subject to certain limitations.

Law Enforcement.  We may release PHI if asked to do so by a law enforcement official:

• In response to a court order, warrant, summons or similar process;

• To identify or locate a suspect, fugitive, material witness, or missing person;

• About the victim of a crime under certain limited circumstances;

• About a death we believe may be the result of criminal conduct;

• About criminal conduct on our premises; or

• In emergency circumstances, to report a crime, the location of the crime or the victims, or the identity, description or location of the person who committed the crime.

Coroners, Medical Examiners and Funeral Directors.  We may release PHI to a coroner or medical examiner.  We may also release PHI about patients to funeral directors as necessary to carry out their duties.

National Security and Intelligence Activities.  We may release PHI about you to authorized federal officials for intelligence, counterintelligence, other national security activities authorized by law or to authorized federal officials so they may provide protection to the President or foreign heads of state.

Inmates.  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release PHI about you to the correctional institution or law enforcement official.  This release would be necessary (1) 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.

Serious Threats.  As permitted by applicable law and standards of ethical conduct, we may use and disclose PHI if we, in good faith, believe that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public or is necessary for law enforcement authorities to identify or apprehend an individual.

You have the right to request restrictions on our uses and disclosures of PHI for treatment, payment and health care operations.  However, we are not required to agree to your request unless the disclosure is to a health plan in order to receive payment, the PHI pertains solely to your health care items or services for which you have paid the bill in full, and the disclosure is not otherwise required by law.  To request a restriction, you may make your request in writing to the Privacy Officer.

You have the right to reasonably request to receive confidential communications of your PHI by alternative means or at alternative locations.  To make such a request, you may submit your request in writing to the Privacy Officer.

You have the right to inspect and copy the PHI contained in the Physicians records, except:

• ​for psychotherapy notes, (i.e., notes that have been recorded by a mental health professional documenting counseling sessions and have been separated from the rest of your medical record);

• for information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding;

• for PHI involving laboratory tests when your access is restricted by law;

• if you are a prison inmate, and access would jeopardize your health, safety, security, custody, or rehabilitation or that of other inmates, any officer, employee, or other person at the correctional institution or person responsible for transporting you;

• if we obtained or created  PHI as part of a research study, your access to the PHI  may be restricted for as long as the research is in progress, provided that you agreed to the temporary denial of access when consenting to participate in the research;

• for PHI contained in records kept by a federal agency or contractor when your access is restricted by law; and

• for PHI obtained from someone other than us under a promise of confidentiality when the access requested would be reasonably likely to reveal the source of the information.

• In order to inspect or obtain a copy your PHI, you may submit your request in writing to the Medical Records Custodian.  If you request a copy, we may charge you a fee for the costs of copying and mailing your records, as well as other costs associated with your request.

You have the right to request an amendment to your PHI but we may deny your request for amendment, if we determine that the PHI or record that is the subject of the request:

• was not created by us, unless you provide a reasonable basis to believe that the originator of PHI is no longer available to act on the requested amendment;

• is not part of your medical or billing records or other records used to make decisions about you;

• is not available for inspection as set forth above; or

• is accurate and complete.

You have the right to receive an accounting of disclosures of PHI made by us to individuals or entities other than to you for the six years prior to your request, except for disclosures:

• to carry out treatment, payment and health care operations as provided above;

• incidental to a use or disclosure otherwise permitted or required by applicable law;

• pursuant to your written authorization;

• to persons involved in your care or for other notification purposes as provided by law;

• for national security or intelligence purposes as provided by law;

• to correctional institutions or law enforcement officials as provided by law;

• as part of a limited data set as provided by law.

You have the right to receive a notification, in the event that there is a breach of your unsecured PHI, which requires notification under the Privacy Rule.