Osra Medical, Inc.

NOTICE OF PRIVACY PRACTICES

Effective Date: January 1st, 2020

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT PATIENTs OF THIS PRACTICE MAY BE USED AND DISCLOSED, AND HOW PATIENTS CAN GAIN ACCESS TO THEIR INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION.

A.  OUR COMMITMENT TO PRIVACY:

Our practice is dedicated to maintaining the privacy of individually identifiable health information (IIHI).  In conducting our business, we will create records regarding our patients and the treatment and services we provide to them. We strive to maintain the confidentiality of health information that identifies the patients. This notice explains the privacy practices that we maintain in our practice concerning IIHI.  

The terms of this notice apply to all records containing IIHI that are created or retained by our practice.  We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this notice will be effective for all of records that our practice has created or maintained in the past, and for any of your records that we may create or maintain in the future. Patients may request a copy of our most current Notice at any time.

B.  FOR QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT:

Osra Medical, Inc.

Attn: Privacy Officer

2215 Post Street, #2 

San Francisco, California 94115

C.  WE MAY USE AND DISCLOSE INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION (IIHI) IN THE FOLLOWING WAYS:

The following categories describe the different ways in which we may use and disclose IIHI, unless the patient objects:

  • Treatment.  Our practice may use IIHI to treat the patients.  For example, we may ask a patient to have laboratory tests (such as blood or urine tests), and we may use the results to help us reach a diagnosis.  We might use IIHI in order to write a prescription for the patient, or we might disclose IIHI to a pharmacy when we order a prescription. Our staff may use or disclose IIHI in order to treat or to assist others in treatment of a patient.  Additionally, we may disclose IIHI to others who may assist in the care of a patient, such as other healthcare providers, a spouse, their children or their parents.

  • Payment.  Our practice may use and disclose IIHI in order to bill and collect payment for the services and items the patient may receive from us. We do not accept or bill insurance, so we do not disclose information for the purpose of being reimbursed by insurance. However, we may use and disclose IHII to obtain payment from those that may be responsible for such costs, such as family members.  

  • Health Care Operations.  Our practice may use and disclose IIHI to operate our business.  As examples of the ways in which we may use and disclose information for our operations, our practice may use IIHI to evaluate the quality of care you received from us, to develop protocols and clinical guidelines, to develop training programs, and to aid in credentialing, medical review, legal services and insurance.  

  • Appointment Reminders.  Our practice may use and disclose IIHI to contact you and remind patients of appointments.

  • Release of Information to Family/Friends.  Our practice may release IIHI when necessary, to a friend or family member that is involved in in the care of a patient.   For example, a parent or guardian may ask that a babysitter take their child to the pediatrician’s office for treatment of a cold.  In this example, the babysitter may have access to this child’s medical information.

  • Disclosures Required by Law.  Our practice will use and disclose IIHI when we are required to do so by federal, state, or local law or regulation.

D.  USE AND DISCLOSURE OF IIHI IN CERTAIN SPECIAL CIRCUMSTANCES:

The following categories describe unique scenarios in which we may use or disclose identifiable health information:

by law to collect information for the purpose of:

  •  Health Oversight Activities.  Our practice may disclose IIHI to a health oversight agency for activities authorized by law.  Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.

  • Lawsuits and Similar Proceedings.  Our practice may use and disclose IIHI in response to a court or administrative order, if the patient is involved in a lawsuit or similar proceeding.  We also may disclose IIHI in response to a discovery request, subpoena, or other lawful process by another party involved in the dispute, but only if we have made an effort to inform the patient of the request or to obtain an order protecting the information the party has requested.

  • Law Enforcement.  We may release IIHI if required to do so by a law enforcement official:

  • regarding a crime victim in certain situations, if we are unable to obtain the person’s agreement

  • concerning a death we believe has resulted from criminal conduct

  • regarding criminal conduct at our offices

  • in response to a warrant, summons, court order, subpoena or similar legal process

  • to identify/locate a suspect, material witness, fugitive or missing person

  • in an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity or location of the perpetrator)

  • Deceased Patients.  Our practice may release IIHI to a medical examiner or coroner to identify a deceased individual or to identify the cause of death.  If necessary, we may also release information in order for funeral directors to perform their jobs.

  • Organ and Tissue Donation.  Our practice may release IIHI to organizations that handle organ, eye or tissue procurement or transplantation, including organ donation banks, as necessary to facilitate organ or tissue donation and transplantation if the patient is an organ donor.

  • Serious Threats to Health or Safety.  Our practice may use and disclose IIHI when necessary to reduce or prevent a serious threat to a patient’s health and safety or the health and safety of another individual or the public.  Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.

  • Military.  Our practice may disclose IIHI if the patient is a member of U.S. or foreign military forces (including veterans) and if required by the appropriate authorities.

  • Workers’ Compensation.  Our practice may release IIHI  if required for workers’ compensation and similar programs.


E.  YOUR RIGHTS REGARDING YOUR IIHI:


The health and billing records we maintain are the physical property of Osara Medical, Inc.  The information in it, however, belongs to you. You have a right to:


1.  Confidential Communications.  You have the right to request that our practice communicate with you about your health and related issues in a particular manner or at a certain location.  For instance, you may ask that we contact you at home, rather than work. In order to request a type of confidential communication, you must make a written request to the Privacy Officer, specifying the requested method of contact, or the location where you wish to be contacted.  Our practice will accommodate reasonable requests.  You do not need to give a reason for your request.


2.  Requesting Restrictions.  You have the right to request a restriction in our use or disclosure of your IIHI for treatment, payment or health care operations.  Additionally, you have the right to request that we restrict our disclosure of your IIHI to only certain individuals involved in your care or the payment for your care, such as family members and friends.  We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you.  In order to request a restriction in our use or disclosure of your IIHI, you must make your request in writing to the Privacy Officer. Your request must describe in a clear and concise fashion:



  1. the information you wish restricted;

  2. whether you are requesting to limit our practice’s use, disclosure or both; and

  3. to whom you want the limits to apply.


3.  Inspection and Copies.  You have the right to inspect and obtain a copy of the IIHI that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes.  You must submit your request in writing to the Privacy Officer in order to inspect and/or obtain a copy of your IIHI. Our practice may charge a fee for the costs of copying, mailing, labor and supplies associated with your request.  Our practice may deny your request to inspect and/or copy in certain limited circumstances; however, you may request a review of our denial. Another licensed health care professional chosen by us will conduct reviews.


4.  Amendment.  You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our practice.  To request an amendment, your request must be made in writing and submitted to the Privacy Officer. You must provide us with a reason that supports your request for amendment. Our practice will deny your request if you fail to submit your request (and the reason supporting your request) in writing.  Also, we may deny your request if you ask us to amend information that is in our opinion: (a) accurate and complete; (b) not part of the IIHI kept by or for the practice; (c) not part of the IIHI which you would be permitted to inspect and copy; or (d) not created by our practice, unless the individual or entity that created is not available to amend the information.


5.   Paper Copy of this Notice.  You may  receive a paper copy of our notice of privacy practices.  You may ask us to give you a copy of this notice at any time.  To obtain a paper copy of this notice, contact the Privacy Officer.


6.  Filing a Complaint.  If you believe your privacy rights have been violated, you may file a complaint with our practice. To file a complaint with our practice, contact:

Osra Medical, Inc. 

Attn: Privacy Officer

All complaints must be submitted in writing.  You will not be penalized for filing a complaint.


7.  Right to Provide an Authorization for Other Uses and Disclosures.  Our practice will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law.  Any authorization you provide to us regarding the use and disclosure of your IIHI may be revoked at any time in writing.  After you revoke your authorization, we will no longer use or disclose your IIHI for the reasons described in the authorization.  Please note: we are required to retain records of your care.

Again, if you have questions regarding this notice or our health information privacy policies, please contact the Privacy Officer listed above.