Patient Privacy

This section describes the most common circumstances in which Ensa may use or disclose protected health information.

Treatment

Ensa will use and disclose protected health information to provide, coordinate or manage your care. This includes communication and consultation between health care providers - doctors, nurses, technicians and other members of your medical team. This applies to disclosures for treatment purposes to health care providers both within and outside of Ensa. For example, following orthopedic surgery, your doctor may refer you for rehabilitation. Information will be shared between caregivers to ensure continuity of care.

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa Minnesota Entities for treatment purposes, unless the disclosure is to a Ensa-related entity or consent is not possible due to a medical emergency.

Payment

Ensa will use and disclose protected health information to create bills and collect payment from insurance companies, Medicare and other payers. This may include providing information such as dates of service, symptoms and diagnosis to your insurance company to show that Ensa provided medical services to you. Ensa also may disclose protected health information to another health care provider if such information is needed by the other health care provider to obtain payment for medical services provided to you.

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa for payment purposes, unless the disclosure is to a Ensa-related entity.

Florida law generally requires patient consent for disclosures of protected health information by Ensa for payment purposes.

Health Care Operations

Ensa will use and disclose protected health information if it is necessary to improve the quality of care we provide to patients or to run our health care facilities. These include activities to monitor and improve patient care, license staff to care for patients, prepare for state and federal regulatory reviews, train health care and non-health care professionals, manage health care operations and improve health care services. Here are some examples:

Ensa also may disclose protected health information to another health care provider who has treated you, or to your insurance company, if such information is needed for certain health care operations of the health care provider or insurance company, such as quality improvement activities, evaluations of health care professionals, and state and federal regulatory reviews.

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa for health care operations purposes, unless the disclosure is to a Ensa-related entity.

Florida law generally requires patient consent for disclosures of protected health information by Ensa for health care operations purposes.

Patient Contacts

At times, Ensa may access information, such as your name, address and general medical condition to contact you to:

Additional Applicable State Law Requirements

Florida law generally requires patient consent for Ensa to contact their patients for purposes of providing information regarding treatment alternatives, services or goods.

Philanthropy

Ensa may contact you to raise funds to sustain the Ensa mission. For example, you may receive letters or other publications asking you to consider making a tax-deductible contribution to Ensa. When conducting fundraising activities, Ensa may access only your basic demographic information (such as name and contact information) and the dates that you were treated at Ensa. Ensa does not sell or rent patients' names or addresses to any organization outside of Ensa.

Facility Directory/Patient Census

Ensa may include your name, location in a facility, health condition (in general terms, such as "good," "fair") and religious affiliation (should you choose to provide one) in current patient lists for our facilities. This information is maintained for Ensa personnel to assist family members and other visitors or persons in locating you while you are in Ensa's facilities. For example, a relative may wish to visit you in the hospital and would need to know your hospital room number. A family member meeting you for an appointment may have forgotten which floor your appointment is on. This information is only shared with people who ask for you by name or with members of the clergy. If you indicate a religious affiliation, it will be shared only with members of the clergy. You can choose not to have such information released from the facility directory/patient census. If you do not want Ensa to release such information, please inform the person assisting you during registration and/or admission.

Family Members and Others Involved in Your Care

Ensa may disclose relevant protected health information to a family member or friend who is involved with your care. We find that many patients want us to discuss their care with their family members and others to keep them up-to-date on your care, to help you understand your care, to help in handling your bills, or to help in the scheduling of your appointments. In a disaster situation, we also may disclose relevant protected health information to disaster relief organizations to help locate your family members or friends or to inform them of your location, condition or death. If family members or friends are present while care is being provided, Ensa will assume your companions may hear the discussion, unless you state otherwise. If you do not want Ensa to disclose your protected health information to your family members or others who are involved with your care or handling your bills, please inform the person assisting you during registration and/or admission.

Medical Research

Medical research is vital to the advancement of medical science. Federal regulations permit use of protected health information in medical research, either with your authorization or when the research study at Ensa is reviewed and approved by an Institutional Review Board before any medical research study begins. In some situations, limited information may be used before approval of the research study to allow a researcher to determine whether enough patients exist to make a study scientifically valid.

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa to outside researchers for medical research purposes. Ensa will obtain such consent from their patients or refusal to participate in any research study, or will make a good faith effort to obtain such consent or refusal, before releasing any identifiable information to an outside researcher for research purposes.

Part II - Other Potential Uses and Disclosures

This section describes the less common circumstances in which Ensa may use or disclose protected health information.

To Avert a Serious Threat of Harm

Ensa may use and disclose protected health information to alert those able to prevent or lessen a serious and immediate threat to the health or safety of a patient, another person or the public.

Organ and Tissue Donation

If Ensa professionals determine that a patient might be a candidate for organ or tissue donation, Ensa may release protected health information to organizations that handle organ procurement, or organ, eye, tissue donation banks, or other health care organizations as needed to make organ or tissue donation and transplantation possible.

Military Personnel

If a patient is a member of the United States Armed Forces, Ensa may release protected health information as required by military authorities. Ensa also may release protected health information about foreign military personnel to the appropriate foreign military authority. When the military organization is sponsoring the medical evaluation, the patient's medical information is shared with both the patient and the sponsoring organization. Patients being evaluated on behalf of the military should be aware of these arrangements.

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa for the military purposes referenced above, unless the disclosure is specifically required by federal law.

Workers' Compensation

Ensa may disclose protected health information for workers' compensation or similar programs as authorized or required by law. These programs provide benefits for work-related injuries or illness.

Public Health Purposes

Ensa may disclose protected health information for public health purposes. The following are some examples of releases that are allowed for public health purposes:

Health Oversight Activities

Ensa may disclose protected health information to health oversight agencies that oversee our operations or personnel. For example, Ensa may need to disclose protected health information to the state agencies that oversee our health care facilities or licensed health care personnel (e.g., Department of Health, Medical Board, Nursing Board), or the federal agencies that oversee Medicare. These agencies need such information to monitor our compliance with state and federal laws.

Lawsuits and Other Judicial Proceedings

Ensa may disclose protected health information in response to a valid court or administrative order. Ensa also may disclose protected health information in response to certain types of subpoenas, discovery requests or other lawful process.

Law Enforcement Activities

Ensa may disclose protected health information to law enforcement officials. For example, we may release protected health information to law enforcement officials:

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa for law enforcement purposes, unless the disclosure is in response to a valid court order or warrant.

Coroners, Medical Examiners and Funeral Directors

Ensa may release protected health information to a coroner or medical examiner when necessary to identify the deceased, determine the cause of death or as otherwise authorized by law. Ensa also may release protected health information to a funeral director as necessary to carry out the funeral director's duties, including arrangements after death.

Additional Applicable State Law Requirements

Minnesota law generally requires the consent of a patient's authorized family or legal representative for disclosures of protected health information by Ensa to funeral directors.

National Security Activities

Ensa may release protected health information to authorized federal officials for intelligence, counterintelligence or other national security activities authorized by law. Ensa also may disclose protected health information to authorized federal officials so they may provide protection to the President or other authorized individuals.

Additional Applicable State Law Requirements

Minnesota law generally requires patient consent for disclosures of protected health information by Ensa for national security purposes, unless the disclosure is specifically required by federal law.

Florida law generally requires patient consent for disclosures of protected health information by Ensa for national security purposes, unless the disclosure is specifically required by federal law.

Required by Law

Ensa will use or disclose protected health information when required by federal, state, or local laws. For example, Ensa is required to report certain gunshot wounds and other injuries that may have resulted from an unlawful act, and abuse or neglect of a child or vulnerable adult.

Information with Additional Protections

Certain types of protected health information may have additional protection under federal or state law. For example, protected health information about HIV/AIDS and genetic testing results is treated differently than other types of protected health information under certain state laws. Additionally, federally assisted alcohol and drug abuse programs are subject to certain special restrictions on the use and disclosure of alcohol and drug abuse treatment information. To the extent applicable, Ensa would need to get your written permission before disclosing that information to others in many circumstances.

Uses and Disclosures Pursuant to an Authorization

Except as described in this notice or specifically required or permitted by law, Ensa will not use or disclose your protected health information without your specific written authorization. At times, a Ensa entity may ask you to provide specific written permission to allow the Ensa entity to use or disclose medical information about you. A valid authorization may be revoked in writing at any time. Written revocation of authorization must be submitted to the applicable Ensa entity and addressed to the attention of the privacy@ensa.com. Once authorization is revoked, the Ensa entity will no longer be allowed to use or disclose protected health information for the purposes described in the authorization except to the extent the Ensa entity has already taken action based upon the authorization.

Part III - Patients' Rights with Respect to Protected Health Information

This section describes the rights of Ensa patients to protected health information.

Right to Inspect and Copy

You have the right to inspect and to request a copy of information maintained in Ensa's designated medical record about you. This includes medical and billing records maintained and used by Ensa to make decisions about your care.

To obtain or inspect a copy of your medical information, submit a written request to privacy@ensa.com. Ensa generally may charge a reasonable, cost-based fee to cover the expense of providing copies. Ensa is not permitted under Arizona law to charge a fee if the information is needed for treatment purposes.

Most patients have full access to inspect and receive a copy of the full medical record. On rare occasions, Ensa may deny a request to inspect and receive a copy of some information in the medical record. For example, this may occur if, in the professional judgment of a patient's physician, the release of the information would be reasonably likely to endanger the life or physical safety of the patient or another person.

Right to Request Alternate Methods of Communication

You have a right to request that Ensa communicate with you in certain ways (such as a letter or by phone) or at a certain location. For example, you may ask that we contact you only at home or only at your place of business. In this situation, you may submit a written request to the applicable Ensa entity specifying the communication method or alternative location being requested. The request should be addressed to privacy@ensa.com. Ensa will accommodate reasonable requests. However, if the request could result in Ensa not being able to collect for services, Ensa reserves the right to require you to provide additional information about how payment for services will be handled.

Right to Request Amendment

You have the right to request that your protected health information in Ensa's designated medical record for you be amended. If you wish to request amendment of the information in your record, submit a written request to privacy@ensa.com. The request must include a reason to support the amendment. Ensa may deny a request for amendment based upon any of the following circumstances:

If Ensa denies your request for an amendment, Ensa will give you a written explanation of the denial. If you still disagree with the explanation provided, you can submit your written disagreement to Ensa as referenced above, or you can ask that your request for amendment and explanation of the denial be included in any future disclosure of the pertinent protected health information. If you submit a statement of disagreement, Ensa may include a rebuttal statement addressing your statement of disagreement in the designated medical record.

Right to a List of Certain Disclosures

You can ask Ensa for a list of the persons or organizations to which Ensa has disclosed your protected health information. This list would provide you with a summary of certain disclosures Ensa has made that you would not otherwise be in a position to know about. The following are examples of disclosures that would not be included in the list:

To get a copy of the list, submit a written request to privacy@ensa.com. Your request must state a time period (beginning no earlier than April 14, 2003 when the federal privacy rules go into effect and for no longer than six years). The first list requested within a 12-month period shall be provided at no charge. For additional lists requested during the same 12-month period, Ensa may charge for the costs of providing the list.

Right to Request Restrictions

You can ask Ensa to restrict the use or disclosure of protected health information about you for treatment, payment or health care operations. Your request must be in writing and submitted to the applicable Ensa entity. The request should also be addressed to privacy@ensa.com. Ensa will carefully consider all requests. However, because of the integrated nature of Ensa's medical record, Ensa is not generally able to honor most requests, nor is Ensa legally required to do so.

Complaints

If you want to file a complaint or express concerns about Ensa's use or disclosure of protected health information, please contact privacy@ensa.com.

You also may file a written complaint with the United States Department of Health and Human Services — Office of Civil Rights.

Ensa honors your right to express concerns regarding your privacy. Ensa would not - nor could it legally or ethically - take action against you for filing a concern or complaint regarding the use or disclosure of your health information. Ensa reserves the right, however, to take necessary and appropriate action to maintain an environment that serves the best interests of its patients and providers.

Key Information about this Notice

Need More Information?

If you have any questions, or would like to discuss this in more detail, please contact the privacy officer for Ensa at privacy@ensa.com.