Resale or disclosure of information to third parties:
We do not share or otherwise disclose any personal information, including your name, address, or email addresses with other organizations. Only Intercommunity Action staff and our authorized agents have access to personally identifiable information provided by visitors to our site.
Browser information collected on our website:
As with any website operator, Intercommunity Action analyzes its websites logs to improve our website and meet the needs of our visitors. We do not gather, record, require, collect or track any Internet users’ personally identifiable information.
Personalization of Content:
Privacy of our email lists:
Intercommunity Action maintains several email lists to keep email subscribers informed about news and the latest policy developments. Individuals may also receive materials by mail or be contacted by telephone. We do not share the email addresses with anyone outside of Intercommunity Action or its authorized agents. We configure our email software to refuse to divulge the email addresses of our list subscribers to anyone but authorized Intercommunity Action staff and agents. Only Intercommunity Action staff and our authorized agents have access to personally identifiable information provided by visitors to our site.
Because we care about the safety and privacy of children online, we comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). COPPA and its accompanying FTC regulation establish United States federal law that protects the privacy of children using the Internet. We do not knowingly contact or collect personal information from children. Our site is not intended to solicit information of any kind from children. It is possible that by fraud or deception we may receive information pertaining to children. If we are notified of this, as soon as we verify the notification, we will immediately obtain parental consent or otherwise delete the information from our servers. If you want to notify us of our receipt of information by children, please contact us.
We have appropriate security measures in place to protect our site from the loss or misuse of information that we have collected from you.
All Rights Reserved
NOTICE SPECIFIC TO DOCUMENTS AVAILABLE ON THIS WEB SITE Permission to use documents (such as press releases, fact sheets, reports, policy alerts, etc.) from this Web site is granted, provided that (1) the copyright notice appears in all copies, (2) use of such documents from this Web site is for informational and non-commercial or personal use only and will not be copied or posted on any network computer or broadcast in any media, and (3) no modifications of any document are made
This notice describes Intercommunity Action, Inc.’s policy on how information about clients/consumers may be used and disclosed, and how clients/consumers can get access to this information. This notice is directed to current/potential clients/consumers. Please review it carefully.
1. Purpose of this Notice
Because you are receiving service from Intercommunity Action Inc. (Interact), we maintain a confidential clinical/medical record on your care. We also keep other confidential information related to payment for your services.
This Privacy Notice describes the types of information we collect concerning you, the safeguards we have in place to protect that information, the circumstances under which that information may be shared, and your rights concerning this information.
We understand that information about you and your health is personal and that protecting this information is important. Interact requires all of its employees, staff, volunteers, other personnel, independent contractors, and business associates to comply with these privacy practices.
You should read this Privacy Notice before signing any documents. If you have any questions or would like to discuss the issue further, please contact the person who provides your services who will direct your questions to Interact’s Compliance Officer.
2. The Use and Disclosure of Information for Treatment, Payment, and Health Care Operations.
By law, Interact is allowed to use and disclose certain medical information for most treatment, payment, and healthcare operations once we have provided you with this notice. We describe each of these categories below and provide some examples under each. Not every use or disclosure in a category will be listed.
Treatment means the provision, coordination, or case management of heath care and related services by or involving Interact. This includes coordinating care among the various clinical departments within Interact as well as coordinating care with outside health care providers. It also includes contacting you by phone or other means to remind you about an appointment or to address a specific aspect of your care.
Information obtained by a therapist, doctor, physician, case manager, or other member of your healthcare team will be recorded in your record and used to determine the plan of treatment/service that should work best for you.
Typically, this information includes your symptoms, examination and test results, diagnoses, treatment, and a plan for future care or treatment. Members of your clinical team will then record the actions they took and their observations. In that way, the team will know how you are responding to care.
We will share certain treatment information without your written Authorization. If information requiring your Authorization is requested, our staff will provide you with a written Authorization form that explains the specific treatment information requested and the purpose of the request for that information. Your signature on the authorization will provide the consent necessary for the use or release of this information.
Payment mainly refers to the activities Interact undertakes to obtain reimbursement for services provided to you. Payment also can include activities related to determining eligibility for services from your insurer, coordination of benefits with other insurers, billing, claims management, collection, medical necessity review activities, utilization review activities, and disclosures to consumer reporting agencies. The term payment also covers any co-pay or fee due directly to Interact as a requirement of your primary medical coverage.
A bill may also be sent to a third-party payer. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, procedures, and treatment provided. Interact may also be asked to disclose healthcare information to your insurer to determine whether the services provided to you were medically necessary.
Health care operations cover a variety of activities performed by Interact or its business associates that are necessary to quality treatment and services. These include, but are not limited to, conducting quality assessment and improvement activities, including outcomes evaluation and development of clinical guidelines; peer review; credentialing and licensing; training programs; legal and financial services; business planning and development; management activities related to Interact’s privacy practices; customer services; internal grievances; creating de-identified information for data aggregation or other purposed; fundraising; certain marketing activities; and, due diligence activities.
Representatives of the Quality Assurance team may use information in your medical record to assess the care and outcomes in your case and others like it. The team will use this information to continually improve the quality and effectiveness of the healthcare and service we provide.
3. The Use and Disclosure of Information for Other Purposes Not Requiring Authorization or Consent.
Under the circumstances listed below, Interact is permitted b law to use or disclose treatment information without Consent or Authorization:
- To those actively engaged in treating you, or to persons at other facilities, if you are being referred to that facility and a summary or portion of the record is necessary to provide for continuity of proper care and treatment. If applicable, this includes professional treatment staff of State Correctional Institutions and county prisons.
- To third-party payers, both those operated and financed in whole or in part by any governmental agency and their agents or intermediaries, or those who you identified to Interact as payer or co-payer for your services and who require information to verify that services were actually provided. Information to be released without consent or court order is limited to the staff names, the dates, types, and costs of therapies or services, and a short description of the general purpose of each treatment session or service.
- To reviewers and inspectors, including accrediting and credentialing agencies and Commonwealth licensure or certification, when necessary to obtain certification as an eligible provider of services.
- To those participating in Professional Service Review Organizations or Utilization Reviews.
- To the administrator, under his or her duties under applicable statutes and regulations.
- To a court or mental health review officer, in the course of legal proceedings authorized by statute or regulations.
- In response to a court order, when the production of the documents is properly ordered by law.
- To appropriate regulatory agencies responsible for handling child or patient abuse.
- In response to an emergency medical situation when release of information is necessary to prevent serious risk of bodily harm or death. Only the specific minimum necessary information pertinent to the relief of the emergency may be released on a nonconsensual basis.
- To parents or guardians and others when necessary to obtain consent to medical treatment.
- To attorneys assigned to represent the subject of a commitment hearing.
- To Business Associates with whom we contract for services. Examples include physician laboratory tests, microfilm production, and ambulance transportation. When these services are contracted, we may disclose your health information to business associates so they can perform the job they have been engaged to do, and bill you or your third-party payer for services rendered. To protect your health information, however, we require the business associate to appropriately safeguard your information.
- As required by law, Interact may disclose your health information to public health or legal authorities charged with preventing or controlling disease or injury. Examples include adverse reactions to medications [and communicable diseases].
- To governmental healthcare oversight entities. Healthcare oversight activities include audits; civil, administrative, or criminal investigations; inspections; licensure or disciplinary actions; and, other administrative and judicial actions undertaken by the government (or their contractors) by law to oversee the health care system. Interact may be required to share medical information with a health oversight agency for these activities.
Information available under these circumstances is limited to that information which is minimal and necessary to the purpose for which the information is sought. The information may not, without your consent, be released to additional persons or entities, or used for additional purposes.
4. Authorizations for Other Uses and Disclosures of Your Medical Information
Unless Interact is required to use your medical information for the reasons listed above, we must obtain your Authorization before making any disclosure. An Authorization is a written document that specifies the exact information that Interact can disclose, the person or entity to which it may be disclosed, and an expiration date or event for the authorization. You have the right to revoke the authorization except to the extent that we have already used or disclosed information in reliance of the authorization, or your Authorization was obtained as a condition of obtaining insurance coverage.
Interact cannot categorically guarantee that a third party named in your Authorization will abide by Interact’s Privacy Notice with respect to your confidential treatment information released to them.
5. Your Health Information Rights
Although your medical record is the physical property of Interact, you have the following rights concerning it:
Restrictions: You have the right to request that Interact restrict uses and disclosures for treatment, payment, or healthcare operations, including consultations with other healthcare providers. Interact, however, is not required to comply with this request if we do not believe we can or should comply with it. If we do agree to your restrictions, we will do so in writing, and we will honor those restrictions except in emergency situations. At times, we may also ask you to revoke a restriction. If you would like to request a restriction, please contact your therapist or case manager who will assist you in this process.
Confidential Communications: You have the right to request that Interact restrict the way in which we communicate with you. We typically will contact you at the numbers you provide (home, work, and/or mobile) to confirm or reschedule appointments, and will send correspondence with Interact logo, address, and/or brand identification to the (mailing and or e-mail) address specified by you for confidential communications your home. You have the right to restrict these communications. For example, you may request we only contact you at home and not work. If you would like to request a restriction, you must do so in writing. Please contact you therapist or case manager who will assist you in this process.
Access to your Record: You have the right to inspect and copy the information contained in your record. If you request a copy of information in your record, we will normally comply within 30 days and charge a reasonable copying fee. We may request that a clinical professional be present to review the record with you if you request inspection or prior to releasing copies of information to you. In the following very limited instances, we may deny access to part or all of your record.
- when the treatment team leader documents that disclosure of specific information concerning treatment will constitute a substantial detriment to your treatment
- when disclosure of specific information will reveal the identity of persons or breach the trust or confidentiality of persons who have provided information upon an agreement to maintain their confidentiality
- the above limitations are applicable to parents, guardians, and others who may control access over records, except that the possibility of substantial detriment to the parent, guardian, or other person may also be considered.
You may appeal our denial. If you would like to request to inspect or copy your record, please contact your case manager who will assist you in this process of documenting this request in writing.
Amending your Record: You have the right to request that Interact correct or amend information in the record which you believe is inaccurate, irrelevant, outdated, or incomplete. Corrections or amendments agreed to by Interact will be documented within 60 days of your written request. Interact reserves the right to deny requests for amendments when the treatment team finds any one of the following:
- The existing documented treatment information is accurate.
- Interact is not the author of the requested treatment information to be amended.
- The request to amend changes or alters the accuracy of the treatment information.
You have a right to appeal this denial within 30 days of its receipt. You may also have the right to enter written data or memoranda qualifying or rebutting information in your record, which you believe to be erroneous or misleading. Your written data or memoranda will accompany all released records. To exercise any of these rights, please contact your therapist or case manager who will assist you in making the request.
Accounting: You have the right to request a copy of any authorization you sign to disclose information from your record. We will offer you with a copy at the point of your request. This accounting does not include disclosures made for treatment, payment, or healthcare operations.
Complaints: You may follow Interact’s grievance procedure if you have complaints concerning any disclosure of your personal information. You may also complain to the Secretary of the federal Department of Health and Human Services if you believe Interact, its employees, or its agents has violated any of your rights. Under no circumstances will Interact take any retaliation against you for filing a complaint. If you would like to file a grievance or make a complaint, please contact your therapist or case manager who will assist you in this process and/or provide you with the appropriate form.
6. Interact’s Duties and Responsibilities
Interact will date and comply with the Privacy Notice currently in effect. We reserve the right to amend and/or update our Privacy Notice from time to time upon change in practices or revision of laws. If Interact revises the Privacy Notice, we will post copies of the revised and dated Privacy Notice in Interact service areas, and will make them available through the Interact Compliance Officer at:
Intercommunity Action, Inc. 6122 Ridge Avenue Philadelphia, PA 19128 (215) 487-0904