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.
If you have any questions about this notice, please contact our ERS Privacy Officer/VP of Human Resources, at 513-271-9610 or by writing to ERS Privacy Officer 3870 Virginia Avenue, Cincinnati, OH 45227.
This Notice of Privacy Practices explains how we may use and disclose your Protected Health Information to carry out treatment, payment, or health care operations, and for other purposes permitted or required by law. It also outlines your rights to access and control your Protected Health Information. “Protected Health Information” is individually identifiable information about you, including demographic information, that relates to your past, present, or future physical or mental health or condition and related health care services. This Notice of Privacy Practices applies to Episcopal Retirement Services, which operates Marjorie P. Lee, The Deupree House and Cottages in Cincinnati, Ohio, and the Episcopal Church Home in Louisville, Kentucky.
Uses and Disclosures of Protected Health Information
We will make a good-faith effort to obtain a written acknowledgment that you received this Notice of Privacy Practices for Protected Health Information the first time we provide services to you, or as soon as reasonably practicable under the circumstances. Your Protected Health Information may be used and disclosed by us and by others outside of ERS who are involved in your care and treatment to provide health care services to you. It may also be used and disclosed to obtain payment for your health care bills and to support the operation of ERS.
Following are examples of the types of uses and disclosures of your Protected Health Information that we are permitted to make. These examples are not exhaustive but are intended to describe the types of uses and disclosures that may be made by us.
Treatment. We will use and disclose your Protected Health Information to provide, coordinate, or manage your health care and related services. This includes coordinating or managing your health care with a third party. For example, we may disclose your Protected Health Information, as necessary, to a home health agency that provides care to you. We will also disclose Protected Health Information to physicians who may be treating you. For example, your Protected Health Information may be provided to a physician to whom you have been referred to ensure the physician has the necessary information to diagnose or treat you.
In addition, we may disclose your Protected Health Information from time to time to another nursing facility or health care provider (e.g., a physician, therapy, or laboratory) who, at the request of your physician or ERS, becomes involved in your care by providing assistance with your health care diagnosis or treatment.
Payment. Your Protected Health Information will be used, as needed, to obtain payment for your health care services. This may include certain activities your health insurance plan may undertake before it approves or pays for the health care services we recommend for you, such as: determining eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity, and undertaking utilization review activities.
For example, obtaining approval for a Medicare stay may require that your Protected Health Information be disclosed to the hospital to obtain necessary information.
Healthcare Operations. We may use or disclose, as needed, your Protected Health Information to support our business activities. These activities include, but are not limited to, quality assessment, staff review, training of nursing students, licensing, and conducting or arranging other business activities.
For example, we may disclose your Protected Health Information to nursing school students or volunteers who see residents at our facility. In addition, we may use or disclose your Protected Health Information for our Social Workers or Chaplain to fulfill their responsibilities in your care. We may also use or disclose your Protected Health Information to Dining Services Staff for the operation of the Dining Services Program.
We will share your Protected Health Information with third-party “business associates” that perform various activities (e.g., billing, transcription services) for us. Whenever an arrangement between a business associate and us involves the use or disclosure of your Protected Health Information, we will have a written contract that includes terms to protect the privacy of your Protected Health Information.
We may use or disclose your Protected Health Information, as necessary, to provide you with information about treatment alternatives or other health-related benefits and services that may be of interest to you. We may also use and disclose your Protected Health Information for referral development and other marketing activities. For example, your name and address may be used to send you a publication or newsletter about us and the services we offer. You may contact our Support Services office at 513-271-9610 to request that these materials not be sent to you.
We may use or disclose your demographic information and the dates you received treatment from us, as necessary, to contact you about fundraising activities we support. If you do not want to receive these materials, please contact our Privacy Officer to request that these fundraising materials not be sent to you. If we have received your substance use disorder records subject to 42 C.F.R. (“Part 2 Records”), we will give you clear and obvious notice in advance and a choice about whether to receive fundraising communications that use your Part 2 Records.
Uses and Disclosures of Protected Health Information Based Upon Your Written Authorization
Other uses and disclosures of your Protected Health Information will be made only with your written authorization, unless otherwise permitted or required by law as described below. We will not share your information, unless you give us written authorization for marketing purposes (except as noted above), for the sale of your information, or for most uses of your psychotherapy notes. You may revoke this authorization at any time, in writing, except to the extent that we have taken an action in reliance on the use or disclosure indicated in the authorization.
Other Permitted and Required Uses and Disclosures that may be made without Your Authorization or Opportunity to Object
We may use and disclose your Protected Health Information in the following instances.
You have the opportunity to agree to or object to the use or disclosure of all or part of your Protected Health Information. If you are not present or able to agree to or object to the use or disclosure of your Protected Health Information, your physician may, using professional judgment, determine whether the disclosure is in your best interest. In this case, only the Protected Health Information relevant to your health care will be disclosed. In all cases, including those listed below, if we have your Part 2 records, we cannot use or share information in those records in civil, criminal, administrative, or legislative investigations or proceedings against you without (1) your consent, or (2) a court order and a subpoena.
Facility Directories. Unless you object, we will use and disclose, in our facility directory, your name, the location where you are receiving care, your condition (in general terms), and your religious affiliation. All of this information, except your religious affiliation, will be disclosed to people who ask for you by name. Members of the clergy will be told your religious affiliation.
Others Involved in Your Healthcare. Unless you object, we may disclose to a member of your family, a relative, a close friend, or any other person you identify your Protected Health Information that directly relates to that person’s involvement in your health care. If you are unable to agree or object to such a disclosure, we may disclose such information as necessary if we determine, based on our professional judgment, that it is in your best interest. We may use or disclose Protected Health Information to notify or assist in notifying a family member, personal representative, or any other person responsible for your care of your location, general condition, or death. Finally, we may use or disclose your Protected Health Information to an authorized public or private entity to assist in disaster relief efforts and to coordinate uses and disclosures to family members or other individuals involved in your health care.
Emergencies. We may use or disclose your Protected Health Information in an emergency treatment situation. If this happens, we will try to obtain your acknowledgment of our Privacy Practices as soon as reasonably practicable after treatment is delivered. If we are required by law to treat you and have attempted to obtain your acknowledgment but are unable, we may still use or disclose your Protected Health Information for treatment, payment, and health care operations.
Communication Barriers. We may use and disclose your Protected Health Information if we attempt to obtain your acknowledgment of our Privacy Practices, but are unable to do so due to substantial communication barriers.
Other Permitted and Required Uses and Disclosures that may be made without Your Consent, Authorization or Opportunity to Object
We may use or disclose your Protected Health Information in the following situations without your acknowledgment or authorization. These situations include:
Your Rights
The following outlines your rights regarding your Protected Health Information and briefly describes how you may exercise these rights.
You have the right to inspect and copy your Protected Health Information. This means you may inspect and obtain a copy of your Protected Health Information in a designated record set for as long as we maintain it. You may also request an electronic copy, which we will provide if we maintain the record in the electronic form and format you request. A “designated record set” includes medical and billing records, as well as any other records we use to make decisions about you.
Under federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or used in, a civil, criminal, or administrative action or proceeding; and Protected Health Information that is subject to a law that prohibits access to Protected Health Information. Depending on the circumstances, a decision to deny access may be reviewable. In some cases, you may have the right to have this decision reviewed. Please contact our Privacy Officer if you have questions about access to your medical record.
You have the right to request a restriction on your Protected Health Information. This means you may ask us not to use or disclose any part of your Protected Health Information for treatment, payment, or healthcare operations. You may also request that any part of your Protected Health Information not be disclosed to family members or friends who may be involved in your care or for notification purposes as described in this Notice of Privacy Practices. Your request must specify the restriction and to whom it should apply.
We are not required to agree to a restriction that you may request. If we believe it is in your best interest to permit use and disclosure of your Protected Health Information, your Protected Health Information will not be restricted. If we do agree to the requested restriction, we may not use or disclose your Protected Health Information in violation of that restriction unless it is needed to provide emergency treatment. With this in mind, please discuss any restriction you wish to request with us. You may request a restriction by submitting a written request to our Privacy Officer.
You have the right not to have your health plan notified. If you pay out-of-pocket in full (i.e., you have requested that we not bill your health plan) for a specific item or service, you have the right to ask that your protected health information for that item or service not be disclosed to a health plan for payment or health care operations, and we will honor that request.
You have the right to request that confidential communications from us be sent by alternative means or to an alternative location. We will accommodate reasonable requests. We may also condition this accommodation by asking you for information about how payment will be handled or for the specification of an alternative address or other method of contact. We will not request an explanation from you regarding the basis for the request. Please make this request in writing to our Privacy Officer.
You may have the right to request that we amend your Protected Health Information. This means you may request an amendment to Protected Health Information about you in a designated record set for as long as we maintain this information. In certain cases, we may deny your request for an amendment. If we deny your request for an amendment, you have the right to file a statement of disagreement with us, and we may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal. Please contact our Privacy Officer if you have questions about amending your medical record.
You have the right to receive an accounting of certain disclosures we have made, if any, of your Protected Health Information. This right applies to disclosures for purposes other than treatment, payment, or healthcare operations, as described in this Notice of Privacy Practices. It excludes disclosures we may have made to you, for a facility directory, to family members or friends involved in your care, as part of an approved authorization, or for notification purposes. You have the right to receive specific information about these disclosures that occurred within the six years prior to the date of your request. You may request a shorter timeframe. The right to receive this information is subject to certain exceptions, restrictions, and limitations.
You have the right to choose someone to act for you. If someone has the authority to act as your personal representative, such as if someone has your medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action.
You have the right to be notified of a breach. You have the right to be notified in the event that we (or a Business Associate) discover a breach of your unsecured Protected Health Information.
You have the right to obtain a paper copy of this notice from us, upon request, even if you have agreed to accept this notice electronically.
Our Duties
We are required to abide by the terms of this Notice of Privacy Practices. We may change the terms of our notice at any time. The new notice will be effective for all Protected Health Information that we maintain both before and after the change. We will provide you with any revisions to the Notice of Privacy Practices.
Changes to the terms of this notice. We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website.
Concerns
You may file a complaint with us or with the U.S. Department of Health and Human Services if you believe your privacy rights have been violated by us. You can contact the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, by calling 1-877-696-6775, or by visiting www.hhs.gov/ocr/privacy/hipaa/complaints.
You may file a concern with us by notifying our Privacy Officer. We will not retaliate against you for filing a complaint or concern.
Contacts
For further information, you may contact our ERS Privacy Officer, at 513-271-9610 or by writing to ERS Privacy Officer 3870 Virginia Avenue, Cincinnati, OH 45227.
This notice was revised effective July 2026.