InXite Health Systems Notice of Privacy

InX­ite Health Sys­tems Notice of Pri­va­cy Prac­tices ("Notice") Effec­tive
Date: Novem­ber 27, 2018
This Notice describes how med­ical infor­ma­tion about you which is Pro­tect­ed
Health Infor­ma­tion (PHI) may be used and dis­closed and how you can get
access to your PHI. Review it care­ful­ly.
We are required by law to main­tain the pri­va­cy of PHI, to pro­vide indi­vid­u­als
with notice of the legal duties and pri­va­cy prac­tices of InX­ite Health Sys­tems,
Inc. (“InX­ite”) with respect to PHI and to noti­fy affect­ed indi­vid­u­als fol­low­ing a
breach of unse­cured PHI.
If you have any ques­tions about this Notice, you may ask a mem­ber of the
staff where you receive health care ser­vices. You may also con­tact our
Pri­va­cy Office at 614–408-1680.
You may obtain our most cur­rent Notice by call­ing or writ­ing to our pri­va­cy
offi­cer to request that a copy be sent to you in the mail or by ask­ing for it when
you come in for an appoint­ment. The address for our pri­va­cy offi­cer is
pro­vid­ed at the end of this Notice.
Uses and dis­clo­sures we are per­mit­ted or required to
make. The fol­low­ing is a descrip­tion of the types of uses and dis­clo­sures of your PHI
that we are per­mit­ted or required to make. Not every use or dis­clo­sure
pos­si­ble is list­ed, but all of the ways that we are per­mit­ted to use and dis­close
your PHI will fall with­in one of these gen­er­al cat­e­gories.


We will use and dis­close your PHI to pro­vide you care man­age­ment and
coor­di­na­tion prac­tices relat­ed health­care ser­vices. This includes dis­clo­sure of
your PHI to doc­tors, spe­cial­ists, phar­ma­cies and oth­er third par­ties who are
involved in your care. For exam­ple, we will dis­close your PHI to anoth­er
physi­cian to whom you have been referred, to the physi­cian who referred you

to us or to a home health agency that will be car­ing for you. We will use your
PHI dur­ing con­tin­u­um of care coor­di­na­tion which may include, with­out
lim­i­ta­tion, physi­cians, nurs­es, care man­agers, social work­ers, phar­ma­cists,
phys­i­cal ther­a­pists, spir­i­tu­al care work­ers, nutri­tion staff, etc. who are involved
in your care.


We will use and dis­close your PHI so that we may bill for health care ser­vices
and so that pay­ment may be col­lect­ed for the health care ser­vices you
receive. This includes activ­i­ties such as com­mu­ni­cat­ing your PHI to an
insur­ance com­pa­ny.

Health care operations

We will use and dis­close your PHI as nec­es­sary for health care oper­a­tions.
For instance, we may use your infor­ma­tion to eval­u­ate the per­for­mance of
health­care pro­fes­sion­als for clin­i­cal qual­i­ty mea­sure pur­pos­es.
Addi­tion­al rights under Fed­er­al and State laws
Fed­er­al and State laws may fur­ther lim­it our uses and dis­clo­sures in the case
of your PHI. This includes HIV-relat­ed records, records of alco­hol or
sub­stance abuse treat­ment and men­tal health records. If Fed­er­al and/or State
law applies to your PHI, we will use and dis­close your PHI in com­pli­ance with
these more restric­tive laws.

Appointment reminders

We may call you on the tele­phone, send you an email, or SMS/text you to
remind you of an upcom­ing appoint­ment. We may leave you a voice mes­sage
that includes the date, time and gen­er­al infor­ma­tion about an upcom­ing
appoint­ment on your tele­phone answer­ing device. We may also send you an
appoint­ment reminder in the mail.
Treat­ment alternatives/other health-relat­ed ben­e­fits and ser­vices
We may use or dis­close your PHI to con­tact you to pro­vide you with
infor­ma­tion about treat­ment alter­na­tives or oth­er health-relat­ed ben­e­fits and
ser­vices that may be of inter­est to you.
Indi­vid­u­als involved in your care

We may dis­close your PHI to those peo­ple who are involved in your care,
such as fam­i­ly mem­bers and friends.
As required by law or legal process
We will dis­close your PHI when we are required to do so by local, state or
fed­er­al law or process of law.
To avert a seri­ous threat to health or safe­ty
We may use or dis­close your PHI for rea­sons which include pre­vent­ing a
seri­ous threat to your health and safe­ty, or the health and safe­ty of oth­ers.
Cadav­er­ic organ, eye and tis­sue dona­tion
We may dis­close the PHI of organ donors to orga­ni­za­tions that assist with
such dona­tions.

Specialized government functions

We may use or dis­close your PHI for spe­cial­ized gov­ern­ment func­tions such
as mil­i­tary, nation­al secu­ri­ty and pres­i­den­tial pro­tec­tive ser­vices.
Work­ers' com­pen­sa­tion
We may dis­close your PHI for pur­pos­es of han­dling your work­ers'
com­pen­sa­tion claims in com­pli­ance with applic­a­ble laws, rules and

Public health activities

We may dis­close your PHI to pub­lic health enti­ties as autho­rized by law. Such
dis­clo­sures include (but are not lim­it­ed to) reports of births and deaths, child
or elder abuse and neglect, and domes­tic vio­lence.
Health over­sight activ­i­ties
We may dis­close your PHI to agen­cies of the gov­ern­ment for activ­i­ties
autho­rized by law. These activ­i­ties include mon­i­tor­ing health care sys­tems
and par­tic­i­pa­tion in gov­ern­ment pro­grams.
Law­suits and dis­putes

If you are involved in a law­suit or oth­er dis­pute, we may dis­close your PHI in
response to doc­u­ments such as a court order or when cer­tain oth­er
require­ments are met.
Law enforce­ment
We may dis­close your PHI if asked to do so by a law enforce­ment offi­cial for
rea­sons includ­ing (but not lim­it­ed to) iden­ti­fy­ing or locat­ing a sus­pect, a
wit­ness or a miss­ing per­son, or inves­ti­gat­ing crim­i­nal activ­i­ty.
Coro­ners, med­ical exam­in­ers and funer­al direc­tors
We may dis­close cer­tain PHI to a coro­ner or med­ical exam­in­er. We may also
dis­close cer­tain PHI about deceased patients to funer­al direc­tors so that they
may car­ry out their duties.
If you are an inmate of a cor­rec­tion­al insti­tu­tion or under the cus­tody of a law
enforce­ment offi­cial, we may dis­close your PHI to the respec­tive cor­rec­tion­al
insti­tu­tion or law enforce­ment offi­cial in accord with applic­a­ble laws, rules,
reg­u­la­tions and our poli­cies.
Busi­ness asso­ciates
Some of the ser­vices we pro­vide are per­formed through con­trac­tu­al
rela­tion­ships with out­side par­ties or busi­ness asso­ciates. These ser­vices may
include (but are not lim­it­ed to) finan­cial, audit­ing and legal. We ask our
busi­ness asso­ciates to sign an agree­ment that restricts the abil­i­ty of the
busi­ness asso­ciate to use or dis­clo­sure your PHI in an effort to make sure that
all PHI is appro­pri­ate­ly safe­guard­ed.


We may use or dis­close your PHI for cer­tain research pur­pos­es when such
research is approved by an insti­tu­tion­al research review board, as
Receiv­ing pay­ment for PHI
Unless allowed by law, we may not receive pay­ment direct­ly or indi­rect­ly for
your PHI with­out your autho­riza­tion.

You have rights regard­ing your PHI
Your right to inspect and copy
You have the right to inspect and receive a copy (paper or elec­tron­ic) of your
PHI that may be used to make deci­sions about your care. You may also direct
us in writ­ing to trans­mit your PHI to anoth­er enti­ty or indi­vid­ual.
To do so, you must com­plete a Patient Access Request Form. You may
obtain a copy of the form by con­tact­ing our Pri­va­cy Office direct­ly using the
con­tact infor­ma­tion at the end of this Notice. If you need assis­tance
com­plet­ing the form, please con­tact the Pri­va­cy Office at 614–408-1680 or via
email at
Note that you may be charged a rea­son­able cost-based fee. Note also that we
may deny your request to inspect and receive a copy of your PHI in very
lim­it­ed cir­cum­stances. If you are so denied, in some cas­es, you may request
that such denial be reviewed. We will com­ply with the out­come of such review.


You may also wish to grant anoth­er indi­vid­ual or enti­ty the right to access or
obtain your PHI. To do so, you must com­plete an autho­riza­tion form that
com­plies with the law.
If you pro­vide us with a writ­ten autho­riza­tion to dis­close your PHI, you may
revoke (can­cel) it at any time. Your revo­ca­tion (can­cel­la­tion) must be in
writ­ing. Con­tact our Pri­va­cy Office at 614–408-1680 for more infor­ma­tion. We
are not able to take back any uses or dis­clo­sures that we already made with
your autho­riza­tion.
With­out your autho­riza­tion, we will not dis­close your PHI for mar­ket­ing
pur­pos­es as set forth under the HIPAA rules. If we have psy­chother­a­py notes
(as defined by the HIPAA Rules), we will not dis­close them unless you sign an
You may also want to grant anoth­er indi­vid­ual or enti­ty rights to access your
PHI. If you wish to do so, you can con­tact the Pri­va­cy Office at 614–408-1680
or at and request the appro­pri­ate autho­riza­tion form for
grant­i­ng access.

Your right to amend

We are required to retain your PHI regard­ing the care and treat­ment that is
pro­vid­ed to you in accor­dance with applic­a­ble law. You have the right to have
us amend PHI or a record about you in a des­ig­nat­ed record set for so long as
your PHI is main­tained in the des­ig­nat­ed record set. How­ev­er, we may deny
such a request if we deter­mine that the PHI or record that is the sub­ject of the
request: (i) was not cre­at­ed by us, unless you pro­vide us with a rea­son­able
basis to believe that the orig­i­na­tor of PHI is no longer avail­able to act on the
request­ed amend­ment; (ii) is not part of the des­ig­nat­ed record set; (iii) would
not be avail­able for inspec­tion under 45 CFR 164.524; or (iv) is accu­rate and
com­plete. Gen­er­al­ly, we must respond in writ­ing to your request with­in six­ty
(60) days. How­ev­er, we may extend the time for such action by no more than
thir­ty (30) days as pro­vid­ed under HIPAA. If we do not agree to your request,
you have the right to sub­mit a state­ment of dis­agree­ment that we must add to
your med­ical record. Con­tact our pri­va­cy offi­cer at 614–408-1680 to request
an amend­ment.

Your right to an accounting of disclosures

You have the right to an account­ing of dis­clo­sures. This is a list (account­ing)
of the times we've dis­closed your health infor­ma­tion for six years pri­or to the
date you ask, who we've shared it with and why. In com­pli­ance with the law,
we will include all the dis­clo­sures except for those about treat­ment, pay­ment,
and health care oper­a­tions, and cer­tain oth­er dis­clo­sures (such as any you
have asked us to make). We will pro­vide you with an account­ing of
dis­clo­sures if you request it and in accord with the law. Con­tact our pri­va­cy
offi­cer at 614–408-1680 to make such a request.

Your right to notification

We are required by law to main­tain the pri­va­cy and secu­ri­ty of your PHI. We
will let you know prompt­ly if a breach occurs that may have com­pro­mised the
pri­va­cy or secu­ri­ty of your infor­ma­tion. This will be done by mail or by oth­er
means if nec­es­sary.

Your right to request restrictions

You have the right to request restric­tions on the PHI we use or dis­close about
you for treat­ment, pay­ment and health care oper­a­tions. We are not required to
agree to your request, and gen­er­al­ly, we will not accept requests for such
As required by law, if you have paid out of pock­et for a health care ser­vice or

item, you have the right to ask us to not tell your insur­ance com­pa­ny about
such ser­vice or item for pur­pos­es oth­er than treat­ment. We will not share the
PHI regard­ing such care with your insur­er for pur­pos­es of pay­ment or health
care oper­a­tions.

Your right to request confidential communications

You have the right to make a rea­son­able request that we com­mu­ni­cate with
you regard­ing your PHI in a cer­tain way or at a cer­tain loca­tion (for exam­ple,
home or office phone). Such rea­son­able requests may include, when
appro­pri­ate, how infor­ma­tion as to pay­ment for ser­vices we pro­vide to you will
be han­dled. We may require you to make this request in writ­ing to the
man­ag­er of your care site.

Your right to a paper copy of this Notice

Gen­er­al­ly, you have a right to obtain a paper copy of this Notice. You may ask
us to give you a copy of this Notice at any time, even if you have agreed to
receive this Notice elec­tron­i­cal­ly. You may also obtain a paper copy of this
Notice at the reg­is­tra­tion desk at your next appoint­ment.

Changes to this Notice

We may change this Notice at any time. We may make the revised or
changed Notice effec­tive for PHI we already have as well as any PHI we
receive in the future. We will post a cur­rent copy of this Notice on our
com­pa­ny web­site You will find the effec­tive date of that
Notice at the top of the Notice.
If we make a mate­r­i­al change to uses and dis­clo­sures, your rights, our legal
duties or oth­er pri­va­cy prac­tices stat­ed in this Notice, we will prompt­ly revise
and dis­trib­ute our changed Notice. Except when required by law, a mate­r­i­al
change to any term of this Notice may not be imple­ment­ed pri­or to the
effec­tive date of the revised Notice.


If you believe your pri­va­cy rights have been vio­lat­ed, you may file a com­plaint
with our pri­va­cy offi­cer and/or the sec­re­tary of the U.S. Depart­ment of Health
and Human Ser­vices. We have pro­vid­ed both address­es on the last page of
this Notice. To file a com­plaint with the Pri­va­cy Office, please call 614–408-

1680. InX­ite val­ues your right to pri­va­cy. You will not be retal­i­at­ed against for
fil­ing a com­plaint.
Oth­er uses of your PHI
Oth­er uses and dis­clo­sures of your PHI not cov­ered by the cat­e­gories
includ­ed in this Notice or applic­a­ble laws, rules or reg­u­la­tions will be made
only with your writ­ten per­mis­sion or autho­riza­tion.
We are required to abide by the terms of this Notice.
The address for our pri­va­cy office is:
InX­ite Health Sys­tems — Pri­va­cy Office
1 East Cam­pus View Blvd, Suite 320
Colum­bus, OH 43235
The address for the Unit­ed States Depart­ment of Health and Human
Ser­vices is:
U.S. Depart­ment of Health and Human Ser­vices
200 Inde­pen­dence Ave. SW
Wash­ing­ton, DC 20201

Last Revi­sion Date: Novem­ber 27, 2018