Symphony for Seniors LLC
Notice of Privacy Practices
This Notice of Privacy Practices describes how health information provided to Symphony for Seniors, LLC, an Arizona limited liability company (“Symphony”) about you or your legal dependent (collectively referred to herein as “you”), as a client of Symphony, may be used and disclosed, and how you can access your health information. The Health Insurance Portability and Accountability Act of 1996, and its implementing regulations (collectively referred to as “HIPPA”) prescribes the process whereby individuals’ protected health information, or PHI, as such term is defined by HIPAA, is protected against unauthorized use or disclosure. Symphony is not a “covered entity” as such term is defined by HIPAA, and is not required to comply with HIPAA. Despite that, Symphony’s privacy practices comply with state law regarding the confidentiality of health information, and generally conform to the HIPAA Privacy Rule. Any terms not defined herein will have the meanings ascribed to them in the then current Client Services Agreement between you and Symphony.
Please Review This Notice Carefully
Our commitment to your privacy:
1. Symphony is dedicated to maintaining the privacy of your protected health information (PHI). In conducting our business, we will create records regarding you and the Services we provide to you. This notice provides you with the following important information:
How we may use and disclose your PHI;
Your privacy rights in your PHI; and
Our commitment concerning the use and disclosure of your PHI.
The terms of this Notice apply to all records containing your PHI that are created or retained by Symphony. We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this Notice will apply to all of your records that Symphony has created or maintained in the past, and for any of your records that we may create or maintain in the future. Symphony will post a copy of our current Notice on our website, and you may request a copy of our most current Notice at any time. Symphony will always follow the Notice that is in effect at the time any action related to PHI is taken.
2. Questions about this Notice If you have questions about this notice, please contact the Symphony Privacy and Security Officer at the telephone number posted on our website.
3. The different ways in which we may use and disclose your PHI: The following categories describe the different ways in which we may use and disclose your PHI:
Services. Symphony may use your PHI to provide Services to you, such as assessing your needs and developing a support plan. Many of the people who work with Symphony—including, but not limited to, other home care agencies—may use or disclose your PHI in order to assist others in your care. Additionally, with your authorization, we may disclose your PHI to others who may assist in your care, such as your spouse, children, or parents, as documented in a written authorization for the release of PHI signed by you. To let us know with whom we have your authorization to share your PHI, please be sure to complete this authorization. We may also disclose your PHI to other healthcare providers for purposes related to your support plan, or that are otherwise in furtherance of the Services Symphony provides to you. Finally, we will maintain your PHI in our Care Platform, provided by CareTree.me, Symphony’s secure case management and communication provider. For information on the privacy policies of our Care Platform, you may access the link directly at https://caretree.me/privacy
Benefit Payments. Symphony may use and disclose your PHI in order to verify your eligibility for benefits covering services provided by our Authorized Providers. For example, we may contact your health insurer to certify that you are eligible for benefits (and for what range of benefits), and we may provide your insurer with details regarding certain items or services you desire to receive to determine if your insurer will cover, or pay for, such services. We may disclose your PHI to other healthcare providers and entities to assist in their billing and collection efforts.
Business Operations. Symphony may use and disclose your PHI to operate our business. As examples of the way in which we may use and disclose your information for operations, Symphony may use your PHI to evaluate the quality of Services you receive from us, or to conduct cost-management and business planning activities for Symphony. We may disclose your PHI to other healthcare providers and entities to assist in their healthcare delivery.
Appointment Reminders. Symphony may use and disclose your PHI to contact you and remind you of an appointment.
Health-Related Benefits and Services. Symphony may use and disclose your PHI to inform you of health-related benefits or services that may be of interest to you.
Release of Information to Family and Friends. With your authorization, Symphony may release your PHI to a friend or family member that is involved in your care, or who assists in taking care of you. We require written authorization to share your PHI with friends and family members.
Disclosures Required by Law. Symphony will use and disclose your PHI when we are required to do so by federal, state, or local law.
4. Use and disclosure of your PHI in certain special circumstances: The following categories describe unique scenarios in which we may use or disclose your PHI:
Public Health Risks. Symphony may disclose your PHI to public health authorities that are authorized by law to collect information for the purpose of:
Reporting abuse or neglect; Notifying a person regarding potential exposure to a communicable disease;
Notifying a person regarding a potential risk for spreading or contracting a disease or condition; or,
Notifying appropriate governmental agency(ies) and authority(ies) regarding the potential abuse or neglect of an adult patient (including domestic violence); however, we will only disclose this information if the patient agrees or we are required or authorized by law to disclose this information.
Lawsuits and Similar Proceedings. Symphony may use and disclose your PHI in response to a court or administrative order, if you are involved in a lawsuit or similar proceeding. We also may disclose your PHI 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 you of the request or to obtain an order protecting the information the party has requested.
Law Enforcement. We may release PHI if asked 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; and
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 Clients. Symphony may release PHI to a medical examiner or coroner to identify a deceased individual or to identify the cause of death. If necessary, we also may release information in order for funeral directors to perform their jobs.
Serious Threats to Health or Safety. Symphony may use and disclose your PHI when necessary to reduce or prevent a serious threat to your 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.
5. Your Rights regarding you PHI:
You have the following rights regarding the PHI that we maintain about you:
Confidential Communication. You have the right to request that Symphony 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 and Security Officer at the address posted on our website, specifying the requested method of contact and/or the location where you wish to be contacted. Symphony will accommodate reasonable requests. You do not need to give a reason for your request.
Requesting Restrictions. You have the right to request a restriction in our use or disclosure of your PHI for Services, benefit eligibility, or business operations. Additionally, you have the right to request that we restrict our disclosure of your PHI 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 for our provision of Services to you. In order to request a restriction in our use or disclosure of your PHI, you must make your request in writing to the Privacy and Security Officer at the address posted on the website. Your request must describe in a clear and concise fashion:
The information you wish restricted;
Whether you are requesting to limit Symphony’s use, disclosure, or both; and
To whom you want the limits to apply.
Inspection and Copies. You have the right to view, download and/or transmit to a third party online the PHI that has been provided to Symphony. To electronically access copies of any of your PHI that Symphony maintains in connection with the Services, you must register with Symphony’s Care Platform. Once you are a registered user of Symphony’s Care Platform, you will be able to view and download copies of any of your PHI that has been delivered or otherwise provided to Symphony. If you would like paper copies of any of your PHI, or copies of any of your PHI that has not been provided to Symphony, you should request such copies directly from your healthcare provider, who may charge a fee for the costs of copying, mailing, labor, and supplies associated with your request.
Right to a Paper Copy of This Notice. You are entitled to 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, please contact the Symphony Privacy and Security Officer at the telephone number posted on our website.
Right to File a Complaint. If you wish to exercise any of the rights granted to you by this Notice of Privacy Policies, or wish to lodge a complaint about how we have handled your PHI, please contact the Symphony Privacy and Security Officer at the address posted on our website. All complaints must be submitted in writing. You will not be penalized for filing a complaint.
Right to Provide an Authorization for Other Uses and Disclosures. Symphony 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 PHI may be revoked at any time in writing. After you revoke your authorization, we will no longer use or disclose your PHI for the reasons described in the authorization. Please note we are required to retain records of the Services we provide. If you have any questions regarding this Notice or our health information privacy policies, please contact our Privacy and Security Officer at the telephone number posted on our website.
Last updated: September 1, 2020