Notice of Privacy Practices
This notice describes how medical and mental health information about you may be used and disclosed and how you can get access to this information. Please review it carefully.
We are required by applicable federal and state law to maintain the privacy of your health information. We are also required to give you this Notice about our privacy practices, our legal duties, and your rights concerning your health information. 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 at that time. In the event that the notice is changed, a new notice will be sent to you by mail or at the time of your next appointment. You may request a copy of our Notice at any time.
This notice takes effect April 14, 2003, and will remain in effect until we replace it.
Uses and Disclosures of Protected Health Information
Uses and Disclosures of Protected Health Information Based Upon Your Written Consent
You will be asked to sign a consent form. Once you have consented to the use and disclosure of your protected health information for treatment, payment and health care operations by signing the consent form, this agency will use or disclose your protected health information as described below.
Treatment: We may use and disclose, as needed, your protected health information to provide, coordinate, or manage your health care and any related services. This includes the coordination or management of your health care with a third party that has already obtained your permission to have access to your protected health information.
Payment: We may use and disclose, as needed, your health information to obtain payment for services we provide to you. This may include certain activities that your insurance plan may undertake before it approves or pays for the mental health care services we recommend for you such as; making a determination of eligibility or coverage for insurance benefits, reviewing services provided to you and undertaking utilization review activities.
Healthcare Operations: We may use and disclose, as needed, your health information in connection with our healthcare operations. Healthcare operations include quality assessment and improvement activities, reviewing the competence or qualifications of mental healthcare professionals, evaluating practitioner and provider performance, employee review activities, conducting training programs, accreditation, certification, licensing or credentialing activities, and conducting or arranging for other business activities.
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. You may revoke this authorization, at any time, in writing. Your revocation will not affect any use or disclosures permitted by your authorization while it was in effect. Unless you give us a written authorization, we cannot use or disclose your health information for any reason except those described in the Notice.
Emergencies: We may use or disclose your protected health information in an emergency treatment situation. In the event of your incapacity or emergency circumstances, we will disclose health information based on determination using our professional judgment disclosing only health information that is directly relevant to the persons involvement in your healthcare. If this occurs, the agency will try to obtain your consent as soon as reasonably practicable after the delivery of treatment.
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 consent or authorization. These situations include:
Required by Law: We may use or disclose your protected health information to the extent that the use or disclosure is required by law. The use or disclosure will be made in compliance with the law and will be limited to the relevant requirements of the law. You will be notified, as required by law, of any such uses or disclosures.
Public Health: We may disclose your protected health information for public health activities and purposes, to a public health authority that is permitted by law to collect or receive this information.
Health Oversight: We may disclose your protected health information to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections.
Abuse or Neglect: We may disclose your protected health information to a public health authority that is authorized by law to receive reports of child abuse or neglect. In addition, we may disclose your protected health information if we believe that you have been a victim of abuse, neglect or domestic violence to the governmental entity or agency authorized to receive such information. In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.
Legal Proceedings: We may disclose protected health information in the course of any judicial or administrative proceeding, in response to an order of a court or administrative tribunal (to the extent such disclosure is expressly authorized), in certain conditions in response to a subpoena, discovery request or other lawful process.
Law Enforcement: We may also disclose protected health information, so long as applicable legal requirements are met, for law enforcement purposes.
Criminal Activity: Consistent with applicable federal and state laws, we may disclose your protected health information, if we 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. We may also disclose protected health information if it is necessary for law enforcement authorities to identify or apprehend an individual.
National Security: We may disclose to military authorities the health information of Armed Forces personnel under certain circumstances. We may disclose to authorized federal officials health information required for lawful intelligence, counterintelligence, and other national security activities. We may disclose to correctional institution or law enforcement official having lawful custody of protected health information of inmate or client under certain circumstances.
Appointment Reminders: We may use or disclose your health information to provide you with appointment reminders (such as voice mail messages, postcards, or letters).
Required Uses and Disclosures:
Under the law, we must make disclosures to you and when required by the Secretary of the Department of Health and Human Services to investigate or
determine our compliance with the requirements of Section 164.500 et.seq.
Client Rights
Access: You have the right to inspect and copy your protected health information. You may
request that we provide copies in a format other than photocopies. We will use the format you request unless we cannot practicably do so. You must submit your request in writing to obtain
access to your health information. You may obtain a form to request access by using the contact information at the end of this notice. We will charge you a reasonable cost-based fee for expenses
such as copies and staff time. If you request copies, we will charge you $.50 for each page and postage if you want the copies mailed to you. If you request an alternative format, we will charge a
cost-based fee for providing your health information in that format. Under federal law, however, you may not inspect or copy the following records; psychotherapy
notes; information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding, and protected health information that is subject to law that prohibits access to
protected health information. Restriction: You have the right to request a restriction of your protected health information. 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 be in writing and state the specific restriction requested and to whom you want the restriction to apply. If we agree to the additional restrictions,
we will abide by our agreement (except in an emergency). 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 information will not be restricted. Alternative Communication:
You have the right to request to receive confidential communications from us by alternative means or at an alternative location. You must make your request in writing.
We may also condition this accommodation by asking you for information as to how payment will be handled or specification of an alternative address or other method of contact. Amendment Request:
You have the right to request that we amend your protected health information. Your request must be in writing and explain why the information should be amended. In
certain cases, we may deny your request for an amendment. If we deny your request for 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. Disclosure Accounting: 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. Notice: You have the right to obtain a paper copy of this notice from us upon request. Questions and Complaints You may contact our Privacy Officer for further information about the complaint process. Privacy Officer The People Inc. Code of Business Ethics and Professional Conduct establishes the principles that
define the ethical behavior of all employees and staff. The Code serves as the basis for processing ethical and conduct complaints initiated against People Inc.
The Code of Business Ethics and Professional Conduct covers a wide range of business practices and procedures. It does not cover every issue that may arise, but it sets out basic principles to guide
all employees and directors as well as agents and representatives, including consultants of the agency. All of our employees must conduct themselves accordingly and seek to avoid even the
appearance of improper behavior. If a law conflicts with a policy in this Code, you must comply with the law; however, if a local custom
or policy conflicts with this Code, you must comply with the Code. If you have any questions about these conflicts, you should ask your supervisor how to handle the situation.
Those who violate the standards in this Code will be subject to disciplinary action as set forth in the employee handbook, policy 801. Compliance with Laws, Rules and Regulations The agency holds information and training sessions to promote compliance with laws, rules and regulations
. Conflicts of Interest
A "conflict of interest" exists when a person's private interest interferes in any way with the interests of the agency. A conflict situation can arise when an employee or director takes actions or has
interests that may make it difficult to perform his or her work objectively and effectively. Conflicts of interest may also arise when an employee or director, or members of his or her family, receives
improper personal benefits as a result of his or her position in the agency. It is almost always a conflict of interest for a agency employee to work simultaneously for a
consumer or supplier. The best policy is to avoid any direct or indirect business connection with our consumers or suppliers, except on behalf of the agency.
Conflicts of interest may not always be clear-cut, so if you have a question, you should consult with higher levels of management. Any employee or director who becomes aware of a conflict or
potential conflict should bring it to the attention of management team or appropriate personnel. Corporate Opportunities Competition and Fair Dealing
To maintain the agency's valuable reputation, compliance with our quality processes and safety requirements is essential. Discrimination and Harassment Health and Safety Violence and threatening behavior are not permitted. Employees should report to work in condition
to perform their duties, free from the influence of illegal drugs or alcohol. People Inc. has long-standing policies on illegal drugs and alcohol, including drug and alcohol testing and
rehabilitation alternatives. Please consult with your supervisor if you have any questions regarding these policies. Record-Keeping Many employees regularly use business expense accounts, which must be documented and recorded accurately. If you are not sure whether a certain expense is legitimate, ask your
supervisor. Rules and guidelines are available from the Accounting Department. All of the agency's books, records, accounts and financial statements must be maintained in
reasonable detail, must appropriately reflect People Inc. transactions and must conform both to applicable legal requirements and to the agency's system of internal controls. Unrecorded or "off the
books" funds or assets should not be maintained unless permitted by applicable law or regulation. People Inc. requires that its Chief Executive Officer and its Financial Director make full, fair,
accurate, timely and understandable disclosure in all periodic reports Business records and communications often become public, and we should avoid exaggeration,
derogatory remarks or guesswork. This applies equally to e-mail, internal memos, and formal reports. Records should always be retained or destroyed according to the agency's record retention
policies. In accordance with those policies, in the event of litigation or governmental investigation please consult the Director of Operations and the agency's attorney. Confidentiality Protection and Proper Use of Agency Assets Code of Professional Conduct My primary goal is to respect the dignity and promote the recovery of each client/consumer and his/her family. I have a total commitment to provide the highest quality care for those
who seek People Inc. services. I shall present a genuine interest in all client/consumers and families and do hereby dedicate
myself to the best interest of the client/consumers and to helping them to help us. I shall maintain at all times an objective, non-possessive, professional relationship with all clients.
I shall be willing to recognize when it is in the best interest of the client/consumers to release them or refer them to another program or individual.
I shall adhere to all the professional rules of confidentiality of all maintenance and distributions of records, material, and knowledge concerning the client and respect the
integrity and protect the welfare of the person or group with whom I am working. I shall not in any way discriminate between client/consumers, families, or fellow professionals
based on age, color, culture, disability, ethnic group, gender, race, religion, sexual orientation, martial status, or socioeconomic status.
I shall maintain respect for People Inc. policies and management functions, but will take the initiative toward improving such policies when it will better serve the interest of the client/consumers.
I shall not participate in false or misleading advertisement, promotions that use deception or use undue influence in service choice.
I have a commitment to assess my own personal strengths, limitations, biases, and effectiveness on a continuing basis; that I shall continuously strive for self-improvement; and
that I have a personal responsibility for professional growth through further education and training. I shall not have any type of outside involvement, including sexual intimacies, with
client/consumers and I shall not counsel persons with whom I have had a personal relationship. I shall be alert to and avoid conflicts of interest that interfere with the exercise of professional
discretion and impartial judgment. I shall inform client/consumers when a real or potential conflict of interest arises and take reasonable steps to resolve the issue in a manner that will
protect the client/consumers= interest. I shall respect client/consumers= right to privacy. I shall not solicit private information unless
it is essential to providing service. Once private information is shared, standards of confidentiality apply. I shall not use derogatory language in written or verbal communications to or about
client/consumers. When I act on behalf of client/consumers who lack the capacity to make informed decisions, I shall take reasonable steps to safeguard the interests and rights of those client/consumers.
I shall respect confidential information shared by colleagues in the course of their professional relationships and transactions.
I shall advocate for adequate resources to meet client/consumers= needs. I shall be a diligent steward of the resources of People Inc. and I shall wisely conserve funds
where appropriate and never misappropriate funds for unintended purposes. I shall not participate in, condone, or be associated with dishonesty, fraud, deception, or
conduct that could affect my client/consumer relationship or the relationship of People Inc. with the community. I will not make use of the any consumer's private vehicle.
I will not consume food or drink belonging to any consumer. I will not use the consumer's telephone for personal calls.
I will not discuss personal problems, religious or political beliefs with any consumer. I will not accept any gifts or tips from any consumer.
I will not consume alcoholic beverages or use medicine or drugs for any purpose other than medical in the consumer's home or prior to service delivery. I will not smoke in the consumer's home. I will not solicit money or goods from the consumer. I will not purchase any item from the consumer even at a fair market value.
I will not assume control of the financial and/or personal affairs of the consumer. I will not remove anything from the consumer's home.
I shall cooperate with the Ethics Committee and promptly supply necessary information. I have a responsibility to myself, my client/consumers, the community and associates to
maintain my physical and mental well being and shall adopt a personal and professional stance which promotes the well being of all human beings.
Each counselor is responsible for communicating the Code of Business Ethics and Professional Conduct to all clients/consumers during the intake process. A copy of the code will be posted in the
reception area of each People Inc. facility. Reporting any Illegal or Unethical Behavior
Complaints may be submitted by any client/consumer, staff or person, affiliated or not affiliated with People Inc. A complaint shall be initiated by completing a People Inc. Ethics Complaint Form
AD-123 obtained through program supervisors or at the reception desk at the administrative building. Complaints received by supervisors or receptionists must be submitted to the Quality Improvement
Coordinator the same day the complaint was received. For purposes of determining time limits, a complaint shall be considered filed as soon as a
completed complaint form has been received by the Ethics Committee. The Ethics committee shall be comprised of the Corporate Compliance Officer and the Quality
Improvement Coordinator from each program (BHS and DDS) for a total of five (3) members. The Ethics Committee shall respond to the complainant within 3 days of receipt of the completed
complaint form. This response shall outline the investigative process and assure the complainant that every effort will be made to correct any violations. Upon conclusion of the investigation, the
case shall be reviewed by the Ethics Committee. When the review has been completed, the Ethics Committee shall vote to take one of the actions as follows: Dismiss the charges if:
The Ethics Committee shall forward a report of their findings and recommended action to the Management Team for final review and approval. Upon receipt of final approval the Ethics
Committee shall notify the respondent, in writing, of their recommendations and that he/she may accept or appeal the findings within 10 days.
If the respondent accepts the Committee=s recommendations, the case will be closed. If the respondent appeals, the Ethics Committee will direct the matter to the Chief
Executive Officer and the Board of Directors. A full report of investigative findings shall be forwarded to the CEO for scheduling into the next regular Board of Directors meeting. The Board will review
and consider all reports before recommending action. All recommendations by the Board shall be final. The respondent will be notified within 10 days of a ruling by the Board of Directors.
All documentation will be maintained in the Quality Improvement department for the appropriate program.
You may complain to us or to the Secretary of Health and Human Services if you believe your privacy rights have been violated by us. You may file a complaint with us by notifying our privacy
contact of your complaint. We support your right to the privacy of your protected health information. We will not retaliate in any way if you choose to file a complaint with us or with the U.S. Department
of Health and Human Services.
Robin Dunn
918 775-7787
rdunn@peopleinc.org
Code of Business Practice
All employees must respect and obey the laws of the cities and states in which we operate. Although not all employees are expected to know the details of these laws, it is important to know
enough to determine when to seek advice from supervisors, managers or other appropriate personnel.
Conflicts of interest are prohibited as a matter of Company policy.
Employees and directors are prohibited from taking for themselves opportunities that are discovered through the use of agency property, information or position without the consent of the Board of
Directors. No employee may use corporate property, information, or position for improper personal gain. Employees and directors owe a duty to People Inc. to advance its legitimate interests when
the opportunity to do so arises.
We seek advantages through superior performance, never through unethical or illegal business
practices. Each employee should endeavor to respect the rights of and deal fairly with the agency's consumers, suppliers and employees. No employee should take unfair advantage of anyone through
manipulation, concealment, abuse of privileged information, misrepresentation of material facts, or any other intentional unfair-dealing practice.
The diversity of the agency's employees is a tremendous asset. We are firmly committed to providing equal opportunity in all aspects of employment and will not tolerate any illegal
discrimination or harassment or any kind.
The agency strives to provide each employee with a safe and healthful work environment. Each
employee has responsibility for maintaining a safe and healthy workplace for all employees by following safety and health rules and practices and reporting accidents, injuries and unsafe
equipment, practices or conditions.
People Inc. requires honest and accurate recording and reporting of information in order to make responsible business decisions. For example, only the true and actual number of hours worked should be reported.
Employees must maintain the confidentiality of confidential information entrusted to them by the agency and its consumers, except when disclosure is authorized by the consumer through a signed
consent or required by laws or regulations.
All employees should endeavor to protect People Inc. assets and ensure their efficient use. Theft,
carelessness, and waste have a direct impact on the agency. Any suspected incident of fraud or theft should be immediately reported for investigation. Agency equipment should not be used for
non-agency business, though incidental personal use may be permitted.
The obligation of employees to protect People Inc. assets includes business, marketing and service
plans, databases, records, salary information and any unpublished financial data and reports. Unauthorized use or distribution of this information would violate agency policy. It could also be
illegal and result in civil or even criminal penalties.
I hereby affirm that...
Employees are encouraged to talk to supervisors, managers or other appropriate personnel about
observed illegal or unethical behavior and when in doubt about the best course of action in a particular situation. It is the policy of People Inc. not to allow retaliation for reports of misconduct by
others made in good faith by employees. Employees are expected to cooperate in internal investigations of misconduct.
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