Notice of Privacy Practices—THIS NOTICE IS EFFECTIVE APRIL 14, 2003 -- Revised 10/09

GENERAL PRIVACY PRACTICES
LFS Carolinas respects your privacy. When you visit our Web site, our computer system automatically collects a variety of non-personally identifying information such as your computer’s IP address, type of browser used, pages viewed, etc. We use a variety of data about visitors to our Web site to plan, support and complete the operations of our organization.
• We may use information shared by you such as your e-mail address, name, address and phone number to provide you with information that you request about the benefits associated with the operations of our agency.
• We do not sell, rent or lease our stakeholder lists to third parties. In order to help provide our services and benefits, we may on occasionally provide information gained on our Web site to other companies who work on our behalf.
• Please be aware that while we take reasonable steps to protect your information, no transmission of information on the Internet can be entirely secure. Always use caution when submitting personal information online.
• Our site may include links to other Web sites whose privacy practices differ from our own. We encourage you to familiarize yourself with the privacy practices of all Web sites you visit.
• We collect a variety of medical and service information about those we serve. The guidelines associated with the collection and use of that information is described in the sections that follow.

If you have questions or concerns about our privacy practices, please contact: Compliance and Improvement Director/Privacy Officer, Lutheran Family Services in the Carolinas, PO Box 12287, Raleigh, NC 27605 1-800-HELPING (435-7464)

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

RESERVATION OF RIGHT TO AMEND NOTICE RETROACTIVELY
Lutheran Family Services reserves the right to change the terms of this notice and to make the new notice provisions effective for all protected health information that the agency maintains, including such information created or received prior to the issuance of the revised notice.

You will be provided with a copy of the revised notice if the changes are significant. This notice describes Lutheran Family Services’ practices and that of:

• Any health care professional authorized to enter information into your service record;
• Any member of a volunteer group we allow to help you while you are a client with
Lutheran Family Services;
• All employees, contract employees, staff, other Lutheran Family Services personnel and foster parents;
• All sites and locations follow the terms of this notice. In addition, sites and locations may share health and service information with each other for treatment, payment or Lutheran Family Services’ operating purposes described in this notice.

OUR PLEDGE REGARDING CLIENT AND STAFF HEALTH AND SERVICE INFORMATION

We understand that health and service information about you is personal. We are committed to protecting health and service information about you. We create a record of the care and services you receive at Lutheran Family Services. We need this record to provide you with quality service and to comply with certain legal requirements. 

This notice applies to all of the records of your service/employment generated by Lutheran Family Services. This notice will tell you about the ways in which we may use and disclose health and service information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of health and service information.

We are required by law to:
• Make sure that health and service information that identifies you is kept private;
• Give you this notice of our legal duties and privacy practices with respect to health and service information about you; and
• Follow the terms of the notice that is currently in effect.

HOW WE MAY USE AND DISCLOSE HEALTH AND SERVICE INFORMATION ABOUT YOU
The following categories describe different ways that we use and disclose health and service information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use of disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.
For Service Delivery: We may use health and service information about you to provide you with services. We may disclose health and service information about you to other staff members, contract employees, foster parents, student interns, or other Lutheran Family Services’ personnel who are involved in providing services to you. For example, a staff member providing counseling services to you may need to talk with your LFS Carolinas Case Manager or the staff in the LFS group home where you are living in order to make the counseling services more effective. In addition, the staff member may need to tell the program manager about you and your services in order to arrange for appropriate transportation. The limits of this information are bound by the concept of “minimum information necessary” to do a task.

For Payment: We may use and disclose health and service information about you so that the services you receive at Lutheran Family Services may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about residential services you received at Lutheran Family Services so your health plan will pay us or reimburse you for the service. We may also tell your health plan about a service you are going to receive to obtain prior approval or to determine whether your plan will cover the service.
For Health Care Operations: We may use and disclose health and service information about you for Lutheran Family Services’ operations. Health Care Operations includes all financial/billing operations, all Quality Management Operations, including Incident management, and all supervisory functions. These uses and disclosures are necessary to run the agency and make sure that all of our clients receive quality services. For example, we may use health and service information to review our services and to evaluate the performance of our staff in caring for you. We may also combine health and service information about many Lutheran Family Services’ clients to decide what additional services Lutheran Family Services should offer, what services are not needed, and whether certain new services are effective. We may also disclose information to staff members, volunteers, students, foster parents, and other Lutheran Family Services personnel for review and learning purposes. We may also combine the health and service information we have with health and service information from other organizations to compare how we are doing and see where we can make improvements in the care and services we offer. Other than for treatment/care, payment, or health care operations, we will remove information that identifies you from this set of health and service information so others may use it to study services and service delivery without learning the identity of specific clients.
Appointment Reminders: With your consent, we may use and disclose health and service information to contact you as a reminder that you have an appointment for services at Lutheran Family Services. Where you have consented or where there is a legal guardian, we may release health and service information about you to a friend or family member who is involved in your care. We may also give information to someone who helps pay for your care. In addition, we may disclose health and service information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location. Where feasible we will attempt to secure our permission for release of this information.
Research: Under certain circumstances, we may use and disclose health and service information about you for research purposes. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of health and service information, trying to balance the research needs with clients’ needs for privacy of their health and service information. We will always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at Lutheran Family Services.
As Required By Law: We will disclose health and service information about you when required to do so by federal, state or local law. This would include a court subpoena or a situation of a national emergency
To Avert a Serious Threat to Health or Safety: We may use and disclose health and service information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.
SPECIAL SITUATIONS: There are other special situations that allow us to release health and service information about you, such as military involvement, workers’ compensation, public health risks, health oversight activities (e.g., audits, investigations, licensure, etc.), in response to a subpoena or court or administrative order, in the interest of national security or protection of the President, or if you are an inmate of a correctional institution or under the custody of a law enforcement official. For additional information about these special situations, please ask your worker or contact our Privacy Officer.

AUTHORIZATION
Other than the uses and disclosures described above, we will not use or disclose health care information about you without a valid “authorization” – or signed permission from you or your personal representative. In some instances, we may wish to use or disclose health care information about you and we may contact you to ask you to sign an authorization form. In other instances you may contact us to ask us to disclose health care information and we will ask you to sign an authorization form. If you sign a written authorization allowing us to disclose health care information about you, you may later revoke (or cancel) your authorization (except in very limited circumstances related to obtaining insurance coverage). If you would like to revoke your authorization, we will follow your instructions except to the extent that we have already relied upon your authorization and take some action. The authorization form in your record will have the word “VOID” written across it and the effective date of your request.

YOUR RIGHTS REGARDING HEALTH AND SERVICE INFORMATION ABOUT YOU.  You have the following rights regarding health and service information we maintain about you:

Right to Inspect and Copy: You have the right to inspect and copy health and service information that may be used to make decisions about your care. Usually, this includes service and billing records. To inspect and copy health and service information that may be used to make decisions about you, you must submit your request in writing to your therapist, Program Director, or LFS Case Manager. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to service information, you may request that the denial be reviewed. Another licensed health care professional chosen by Lutheran Family Services 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 the review.

Right to Amend: If you feel that health and service information we have about you in incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for Lutheran Family Services. To request an amendment, your request must be made in writing and submitted to your therapist, Program Director, or LFS Case Manager. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request 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 health and service information kept by or for this agency;
Right to an Accounting of Disclosures: You have the right to request an “accounting of disclosures”. This is a list of the disclosures we have made of health and service information about you. To request this list or accounting of disclosures, you must submit your request in writing to your therapist, Program Director, or LFS Case Manager. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicated in what form you want the list (for example, on paper, electronically). Your first request within a 12-month period will be free. For additional lists within that 12-month period, we may charge you for the costs of providing the list. We will notify you of the costs involved prior to acting on your request and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions: You have the right to request a restriction or limitation on the health and service information we use to disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the health and service information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a counseling session you had.

If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. To request restrictions, you must make your request in writing to your therapist, Program Director, or LFS Case Manager. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosure to your spouse.

Right to Request Confidential Communications: You have the right to request that we communicate with you about health and service matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to your therapist, Program Director, or LFS Case Manager. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted and, if requested by Lutheran Family Services, you must advise us as to how payment will be made.

Right to 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. To obtain a paper copy of this notice, contact your therapist, Program Director, LFS Case Manager of the Privacy Officer.

YOU MAY FILE A COMPLAINT ABOUT OUR PRIVACY PRACTICES
If you believe your privacy rights have been violated or if you are dissatisfied with our privacy policies or procedures, you may file a complaint with Lutheran Family Services or with the federal government. We will not take any action against you or change our treatment of you in any way if you file a complaint. All complaints must be filed in writing. To file a complaint with Lutheran Family Services, you may bring your complaint to your worker; his/her supervisor, or Privacy Officer or you may mail it to the following address:

Compliance and Improvement Director/Privacy Officer
Lutheran Family Services in the Carolinas
PO Box 12287, Raleigh, NC 27605