Notice of Privacy Practices

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

Doctors and other caregivers who treat patients at Summa facilities but who are not employed by us exchange information about you as a patient with other providers and Summa employees. These healthcare practitioners may also give you other privacy notices that describe their office practices.

All of these hospitals, doctors, healthcare providers, entities, facilities, associates and services ( referred to as “Summa” or “we”)  may share your health information with each other for reasons of treatment, payment, and healthcare operations as discussed below.

Summa is required by law to maintain the privacy of our patients’ personal, protected health information and to provide patients with notice of our legal duties and privacy practices with respect to personal, protected health information.  We are required to abide by the terms of this Notice so long as it remains in effect.  We reserve the right to change the terms of this Notice of Privacy Practices as necessary and to make the new Notice effective for all personal, protected health information maintained by us.  You may receive a copy of any revised Notice at any Summa point of registration or by mailing a request to a Summa Privacy Officer. Contact information is provided below. This Notice is also posted on our website

USES AND DISCLOSURES OF YOUR PERSONAL, PROTECTED HEALTH INFORMATION

Your Authorization. Except as outlined below, we will not use or disclose your personal, protected health information for any purpose unless you have signed a form authorizing the use or disclosure. You have the right to revoke that authorization in writing unless we have taken any action in reliance on the authorization.

Uses and Disclosures for Treatment.  We use and disclose your personal, protected health information as necessary for your treatment.  For instance, doctors, nurses and other professionals involved in your care will use information in your medical record and information that you provide about your symptoms and reactions to plan a course of treatment for you that may include procedures, medications, tests, etc.  We may also release your personal, protected health information to another healthcare facility or professional who is not affiliated with our organization but who is or will be providing treatment to you. For instance, if, after you leave the hospital, you are going to receive home healthcare, we may release your personal, protected health information to that home healthcare agency so that a plan of care can be prepared for you.  Summa and related physician offices make electronic medical record information and results available through electronic health systems to Summa related and affiliated providers as well as unrelated healthcare providers who agree to access the information for the purpose of patient care and treatment. 

Uses and Disclosures for Payment.  We will use and disclose your personal, protected health information as necessary for the payment purposes of those health professionals and facilities that have treated you or provided services to you.  For instance, we and the health professionals involved in your care may forward information regarding your medical procedures and treatment to your insurance company to arrange payment for the services provided to you or we may use your information to prepare a bill to send to you or to the person responsible for your payment.

Uses and Disclosures for Healthcare Operations.  We will use and disclose your personal, protected health information as necessary and as permitted by law, for our healthcare operations that include clinical improvement, professional peer review, business management, accreditation and licensing, etc.  For instance, we may use and disclose your personal, protected health information for purposes of improving the clinical treatment and care of our patients.  We may disclose protected health information to doctors, nurses, technicians, medical students, volunteers and other persons for review and learning purposes and for the operation of educational programs.  We may also disclose your personal, protected health information to another healthcare facility, healthcare professional, or health plan for such things as compliance, billing audits, quality assurance and case management, if that facility, professional, or plan also has or had a patient relationship with you or is part of the clinically integrated healthcare setting.

Health Information Exchanges.  Summa Health participates in one or more Health Information Exchanges; currently we participate in ClnicSync. CliniSync is a Health Information Exchange operated by the Ohio Health Information Partnership. Participating healthcare providers can use electronic networks to securely exchange medical information of patients for treatment, payment or other healthcare operations.  For example, if they participate in the same Health Information Exchange, the medical information from a physician you regularly visit could be available when visiting an out of town emergency room.  Patients may withdraw from participation in this Health Information Exchange during registration or at any time by notifying the System Privacy Officer at 330.375.6665.

1. Your protected health information will be disclosed to the approved health information exchanges to facilitate the provision of healthcare to you;
2. The approved health information exchanges maintain appropriate administrative, physical and technical safeguards to protect the privacy and security of protected health information;
3. Only authorized individuals may access and use protected health information from the approved health information exchanges;
4. You or your personal representative have the right to request in writing that the covered entity do either or both of the following:
   a. Not disclose any of your protected health information to the approved healthcare exchange;
   b. Not disclose specific categories of your protected health information to the approved health information exchanges;
5. Any restrictions on the disclosure of protected health information you request under (4) above may result in a healthcare provider not having access to information that is necessary for the provider to render appropriate care for you;
6. Any restrictions on the disclosure of protected health information you request as described under (4) above must be honored by the covered entity.
7. Any restrictions on the disclosure of protected health information you request as described under (4) above must be honored if the restriction is consistent with rules adopted under Chapter 3798 of the Ohio Revised Code.

Our Patient Directory.  Each Summa Hospital maintains a patient directory listing the name, room number, general condition and, if you wish, your religious affiliation.  Unless you choose to have your personal, protected health information excluded from this directory, the information, excluding your religious affiliation, will be disclosed to anyone who requests it by asking for you by name.  This information, including your religious affiliation, may be also provided to trained members of Summa Health’s Volunteer Services who provide faith-based visits to patients who desire such visits.  You have the right during registration to have your information excluded from this directory and/or to request not to receive faith-based visits.

Family and Friends Involved in Your Care.  With your approval, we may disclose your personal, protected health information to designated family, friends, and others who are involved in your care or in payment of your care in order to facilitate that person’s involvement in caring for you or paying for your care.  If you are unavailable, incapacitated, or facing an emergency medical situation and we determine that a limited disclosure may be in your best interest, we may share limited personal, protected health information with such individuals without your approval.  We may also disclose limited personal, protected health information to a public or private entity that is authorized to assist in disaster relief efforts in order for that entity to locate a family member or other persons that may be involved in some aspect of caring for you.

Business Associates. Certain components of our services are performed through contracts with outside persons or organization such as auditing, accreditation, legal services, etc.  At times it may be necessary for us to provide some of your personal, protected health information to one or more of these outside persons or organizations who assist us with our healthcare operations.  In all cases, we require these business associates to appropriately safeguard the privacy of your information.

Fundraising.  We may contact you to donate to a fundraising effort for or on behalf of our non-profit entities.  You have the right to “opt-out” of receiving fundraising materials or communications and may do so by emailing foundation@summahealth.org, calling toll-free at 800.237.8662 or 800.23.Summa, or by sending your name and address, together with your request to be removed from one or more of our fundraising mailing lists, to Summa Foundation 525 East Market Street Akron, Ohio 44304.   Other or updated information regarding your opt-out rights may be included in fundraising or educational materials. 

Appointments and Services.  We may contact you with appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.  You have the right to request, and we accommodate reasonable requests, to receive communications regarding your personal, protected health information by alternative means or at alternative locations.  For instance, you may not want appointment reminders left on voice mail or sent to a particular address and we will accommodate reasonable requests.  You may request such confidential communication in writing and may send your request to the System Privacy Officer at Summa Health.

Health Products and Services.  We may from time to time use your personal, protected health information to communicate with you about health products and services necessary for your treatment, to advise you of new products and services we offer, and to provide general health and wellness information. 

Marketing. We do not sell your personal protected health information. We will not engage in subsidized communications about health related products or services, with the exception of face-to-face communication or promotional items of minimal value, without your authorization. You may revoke such authorization in writing.

Research.  In limited circumstances, we may use and disclose your personal, protected health information for research purposes.  For example, a researcher may wish to compare outcomes of all patients that received a particular drug and will need to review a series of medical records.  In all cases where your authorization is not obtained, your privacy will be protected by strict confidentiality requirements applied by an Institutional Review Board that oversees the research, or by representations of the researchers that limit their use and disclosure of patient information.

Other Uses and Disclosures.  We are permitted or required by law to make certain other uses and disclosures of your personal, protected health information without your authorization.  We may release your personal, protected health information:

• for any purpose required by law;
• for public health activities, such as required reporting of disease, injury, and birth and death, and for required public health investigations;
• as required by law if we suspect child abuse or neglect or if we believe you to be a victim of abuse, neglect, or domestic violence;
• to the Food and Drug Administration if necessary to report adverse events, product defects, or to participate in product recalls;
• to your employer when we have provided healthcare to you at the request of your employer; in most cases you will receive notice that information is disclosed to your employer;
• if required by law to a government oversight agency conducting audits, investigations, or civil or criminal proceedings;
• if required to do so by court or administrative ordered subpoena or discovery request; in most cases you will have notice of such release;
• to law enforcement officials as required by law to report wounds and injuries and crimes;
• to coroners and/or funeral directors consistent with law;
• if necessary to arrange an organ or tissue donation from you or a transplant for you;
• if you are a member of the military as required by armed forces services; we may also release your personal, protected heath information if necessary for national security or intelligence activities;to workers’ compensation agencies if necessary for your workers’ compensation benefit determination.

YOUR RIGHTS

Access to Your Personal, Protected Health Information.  You have the right to receive a copy and/or inspect much of the personal, protected health information that we retain on your behalf.  All requests for access must be made in writing and signed by you or your representative.  We may charge you a reasonable fee if you request a copy of the information.  We may also charge for postage if you request a mailed copy. You have the right to electronic copies of your health information when it is stored in electronic format. Patients or their legal representatives may request access to their personal, protected health information by completing the Authorization for Release of Information Form.  which is available from the Medical Records Department, the Patient Accounts Department, and under Visitor Information on the Summa Health System website. 

Amendments to Your Personal, Protected Health Information.  You have the right to request in writing that personal, protected health information we maintain about you be amended or corrected.  We are not obligated to make all requested amendments but will give each request careful consideration.  All amendment requests, in order to be considered by us, must be in writing, signed by you or your representative, and must state the reasons for the amendment/correction request.  If we make an amendment or correction that you request, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary.  Amendment request forms may be obtained from the Medical Records Department.

Accounting for Disclosures of Your Personal, Protected Health Information.  You have the right to receive an accounting of certain disclosures made by us of your personal, protected health information.  Requests must be made in writing and signed by you or your representative.  Accounting request forms are available from the Medical Records Department.  The first accounting in any 12-month period is free; you will be charged a reasonable fee for each subsequent accounting you request within the same 12-month period.

Restrictions on Use and Disclosure of Your Personal, Protected Health Information.  You have the right to request restrictions on certain uses and disclosures of your personal, protected health information for treatment, payment, or healthcare operations by contacting the Privacy Officer.  We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate.  We retain the right to terminate an agreed-to restriction if we believe such termination is appropriate.  In the event of a termination by us, we will notify you of such termination.  You also have the right to terminate, in writing or orally, any agreed-to restriction by sending such termination notice to the Privacy Officer.  Any agreed-to restriction will not limit patient directory disclosures unless you exclude yourself from the patient directory. You may ask a provider to restrict certain disclosures of protected health information to a health plan or insurance company, for purposes of payment or healthcare operations, if you have paid that provider in full for the healthcare item or service, out of pocket. 

Complaints.  If you believe your privacy rights have been violated, you can file a complaint with the Privacy Officer, Patient Liaison, or the Compliance Hotline.  You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services in Washington, D.C. in writing within 180 days of a perceived violation of your rights.  There will be no retaliation for filing a complaint.

Notice of Breach.  You will receive notification if there has been an impermissible use or disclosure  resulting in the compromise of your unencrypted personal health information.

PROVIDERS AND LOCATIONS

The professionals and entities comprising an Organized  Healthcare Arrangement and sharing information for treatment, payment and healthcare operations include, but are not limited to :  Summa Health System – Akron Campus/Summa Health System – St. Thomas Campus, Summa Health System – Barberton Campus, Summa Health Medical Group, Summa Rehab Hospital, Summa Health Wadsworth-Rittman Medical Center, Summa Health Centers,  Summa Emergency Centers, Summa At Home Healthcare,  physicians and other healthcare professionals who are members of our medical staffs, whether employed or independent, as they provide services at one or more of the above locations.

FOR MORE INFORMATION

If you have any questions or need further assistance regarding this Notice, you may contact the System Privacy Officer at 330.375.6665.

You may also call the Compliance Hotline of Summa Health System at 800.421.0925.

You have the right to a paper copy of this Notice of Privacy Practices, even if you have requested such copy by e-mail or other electronic means.

EFFECTIVE April 14, 2003

UPDATED: 9/3/10
REVIEWED: 6/28/06, 8/31/11
REVISED September 2013, January 2018, April 2021