IHS Privacy Policy
This notice describes how medical information about patients may be used and disclosed and about obtaining access to this information.
Please Review Carefully
If you have any questions about this notice, please contact the Integrated Health Services Chief Operating Officer at IHS c/o Integrated Health Services, Inc., 763 Burnside Avenue, East Hartford, CT 06108.
We respect the privacy of a patient’s protected health information (referred to herein simply as health information) and are committed to maintaining patients’ confidentiality. This Notice describes patients’ rights and our obligations regarding health information and describes the possible uses and disclosures of health information. This Notice applies to all information and records related to patient care that Integrated Health Services (herein as “IHS”,) has received or created. It extends to information received or created by our employees, staff, contributors and volunteers as well as by doctors and other healthcare practitioners associated with treating patients.
Our Responsibilities
We are required by law to maintain the privacy of patient health information; to provide patients this detailed Notice of our legal duties and privacy practices relating to health information; and to abide by the terms of the notice that is currently in effect.
I. HOW WE MAY USE AND DISCLOSE PATIENT HEALTH INFORMATION FOR TREATMENT, PAYMENT AND HEALTHCARE OPERATIONS.
We may use and disclose patient health information for purposes of treatment, payment and health care operations as described below.
- For Treatment
We will use and disclose patient health information in providing treatment and services and coordination patient care. Patient health information may be used by nurses, social workers, doctors, dentists, hygienists, and others involved in patient care.
- For Payment
We may use and disclose patient health information so that we can bill and receive payment for the treatment and services received. For billing and payment purposes, we may disclose patient health information to a patient’s representative, insurance or managed care company, Medicare, Medicaid or another third party payer. For example, we may contact Medicaid or your health plan to confirm a patient’s coverage or to request prior approval for proposed treatment of services. We may also use or disclose patient health information in an emergency situation.
- For Health Care Operations
We may use and disclose patient health information as necessary for IHS operations such as for management purposes and to monitor our quality of care. For example, health information of many patients may be combined and analyzed for purposes such as evaluating and improving quality of care and planning for services. Health information is used in evaluating our employees and in reviewing the qualifications and practices of doctors, nurses, social workers, dentists, hygienists and other practitioners at GHV. We also may use and disclose health information for education and training purposes.
- Medical Staff
In addition, IHS routinely shares health information with healthcare providers working with IHS staff to facilitate (i) treatment by the medical staff to patients of IHS (ii) payment for services provided by the staff at IHS; and (iii) when a provider assists IHS with certain health care operations. IHS and the IHS staff have agreed to abide by the terms of this Notice while providing services at the IHS.
II. WE ALSO MAY USE AND DISCLOSE PATIENT HEALTH INFORMATION FOR SPECIFIC PURPOSES
- Business Associates
There are some services provided in our organization through contracts with business associates. When these services are contracted we may disclose patient health information to our business associates so that they can perform the job we have asked them to do. To protect patient health information, however, we require the business associates to appropriately safeguard patient health information.
- Individuals Involved in a Patient’s Care or Payment of a Patient’s Care
Unless a patient and/or guardian objects in writing, we may disclose patient health information to a family member, a relative, a close friend or any other person identified by a patient and/or guardian, if the information relates to the person’s involvement in a patient’s health care, and to notify the person of a patient’s location or general condition or payment related to a patient’s health care. In addition, we may disclose a patient’s health information to a public or private entity authorized by law to assist in a disaster relief effort. If a patient and/or guardian is unable to agree or objects in writing to such a disclosure, we may disclose such information if we determine that it is in a patient’s best interest based on our professional judgment or if we reasonably infer that a patent would not object.
- Communication Barriers
We may use or disclose patient health information as necessary when we are unable to obtain a patient’s and /or guardian’s consent due to communication barriers if we believe that consent is intended based on the circumstances and in a patient’s best interest.
- As Required By Law
We may disclose patient health information when required by law to do so.
- Public Health Activities
We may disclose patient health information for public health activities. These activities may include, for example; - Reporting to a public health or other government authority for preventing or controlling disease, injury or disability, reporting child abuse or neglect, reporting births and deaths.
- Reporting to the federal Food and Drug Administration (FDA) concerning issues such as problems with products or for recall of a product; or
- To notify a person who may have been exposed to or at risk of spreading a communicable disease, if authorized by law.
- Reporting Victims of Abuse, Neglect or Domestic Violence
If we believe that a patient has been a victim of abuse, neglect or domestic violence, we may use and disclose a patient’s health information to notify a government authority, if authorized by law or if a patient and/or guardian agrees to the report.
- Health Oversight Activities
We may disclose patient; health information to a health oversight agency for activities authorized by law. These may include, for example, audits, investigation, inspections and licensure actions or other legal proceedings. These activities may include government oversight of the health care system, government payment or regulatory programs, and compliance with civil rights laws.
- Judicial and Administrative Proceedings
We may disclose patient health information in response to a court or administrative order. If permitted by law, we also may disclose information in response to a subpoena, discovery request, or other lawful process.
- Law Enforcement
We may disclose patient health information for certain law enforcement purposes, including, for example, to comply with reporting requirements or report emergencies or suspicious deaths; or to comply with a court order, warrant, or similar legal process.
- Research
Patient health information may be used for research purposes, but only if the privacy aspects of the research have been reviewed and approved by the institutional Review Board, if the researcher is collecting information in preparing a research proposal, if the research occurs after a patient’s death, or if a patient and/or guardian authorizes the use or disclosure.
- Coroners, Medical examiners, Funeral Directors, Organ procurement Organizations
We may release patient health information to a coroner, medical examiner, funeral director or, if a patient is an organ donor, to an organization involved in the donation of organs and tissue.
- To Avert a Serious Threat to Health or Safety
When necessary to prevent a serious threat to a patient’s health or safety or the health or safety of the public or another person, we may use and disclose health information, limiting disclosures to someone able to help lessen or prevent the threatened harm.
- Military and Veterans
If a patient is a member of the armed forces, we will comply with any law that requires us to use and disclose the patient’s health information as requested by military command authorities or use and disclose health information about foreign military personnel as requested by the appropriate foreign military authority.
- Worker’s Compensation
We may use or disclose the patient’s health information as permitted by laws relating to workers’ compensation or similar programs.
- National Security and Intelligence Activities; Protective Services for the President and Others
We will comply with any law that requires us to disclose health information to authorized federal officials conducting national security and intelligence activities or as needed to provide protection to the President of the United States, certain other persons or foreign heads of states or to conduct certain special investigations.
- Fundraising Activities
We may use certain health information, limited to contact information such as a patient’s name, address and phone number and the date’s patient received treatment or services to contact a patient and/or guardian in an effort to raise money for IHS. We also may disclose contact information for fundraising purposes to a foundation related to IHS. A description of how to opt out of receiving any further fundraising communications will be included with any fundraising material a patient and/or guardian receives from the IHS. If a patient and/or guardian requests that a patient’s information not be used or disclosed for fundraising purposes, we will make a reasonable effort to ensure that a patient and/or guardian does not receive future fundraising communications.
- Appointment Reminders
We may use or disclose health information to remind a patient about appointments.
- Treatment Alternatives and Health-Related Benefits and Services
We may use or disclose patient health information to inform a patient about treatment alternatives and health-related benefits and services that may be of interest to a patient.
III. PATIENT AUTHORIZATION IS REQUIRED FOR OTHER USES OF HEALTH INFORMATION
Except as described in this Notice, we will use and disclose patient health information only with the written authorization of the patient and/or guardian or as permitted or required by law. While written acknowledgement of receipt of our Notice of Privacy Practices allows us to use and disclose patient health information for treatment, payment and health care operations, an authorization must specify other particular uses or disclosures that a patient and/or guardian may allow. A patient and or guardian may revoke an authorization to use or disclose a patient’s health information for the purposes covered by that authorization, except where we have already relied on the authorization.
IV. PATIENT RIGHTS REGARDING PATIENT HEALTH INFORMATION
A Patient has the following rights regarding his/her health information at IHS:
- Right to Request Restrictions
A patient has the right to request restrictions on our use of disclosure of the patient’s health information for treatment, payment or health care operations. A patient also has the right to request restrictions on the health information we disclose about the patient to a family member, friend or other person who is involved in the patient’s care or the payment of the patient’s care. We are not required to agree to a patient’s request restriction. If we do agree to accept a patient’s requested restriction, we will comply with that request except as needed to provide emergency treatment.
- Right to Receive Confidential Communications
A patient has the right to request a reasonable accommodation regarding how the patient receives communications of health information. A patient has the right to request an alternative means of communication or an alternative location where the patient would like to receive communications. A patient must submit a request in writing to the IHS, requesting confidential communications.
- Right to Access, Inspect and Copy Your Protected Health Information
A patient has the right to access, inspect and obtain a copy of the patient’s health information that is used to make decisions about the patient’s care for as long as the health information is maintained by the IHS. To access, inspect and copy the patient’s health information that may be used to make decisions about the patient, a request must be submitted in writing to IHS. If a patient requests a copy of the information, we may charge a fee for the costs of preparing, copying, mailing or other supplies associated with the request to access, inspect and copy the patient’s health information under certain limited circumstances. If we deny the request, we will provide the patient with a written explanation of the reason for the denial. The patient may have the right to have this denial reviewed by an independent healthcare professional designated by us to act as a reviewing official. This individual will not have participated in the original decision to deny the request. The patient may also have the right to request a review of our denial of access through a court of law. All requirements, court costs and attorney’s fees associated with a review of denial by a court are the patient’s responsibility. The patient should seek legal advice if he/she is interested in pursuing his/her rights through a court.
- Right to Amend your Protected Health Information
A patient has the right to request amendment of his/her health information maintained by IHS for as long as the information is kept by or for IHS. The request must be made in writing and must state the reason for the requested amendment. We may deny the request for amendment if the information (a) was not created by IHS, unless the originator of the information is no longer available to act on your request; (b) is not part of the health information maintained by or for IHS; (c) is not part of the information to which the patient has a right of access; or (d) is already accurate and complete, as determined by the IHS. If we deny the request for amendment, we will provide a written denial including the reasons for the denial and the right to submit a written statement disagreeing with the denial.
- Right to an Accounting of Disclosures
A patient has the right to request an accounting of certain disclosures of his/her health information. This is a listing of disclosures made by IHS or by others on our behalf, but does not include disclosures for treatment, payment and health care operations. To request an accounting of disclosures, submit a request in writing, stating a time period beginning after April 14, 2003, that is within six years from the request. An accounting will include, if requested: the disclosure date; the name of the person or entity that received the information and address, if known; a brief description of the information disclosed; and a brief statement of the purpose of the disclosure or a copy of the request, or certain summary information concerning multiple disclosures. The first accounting provided with a 12-month period will be free; for further requests, we may charge you a reasonable cost based fee.
- Right to a Paper Copy of This Notice
A patient has the right to obtain a paper copy of this Notice, even if the patient gas agreed to receive this Notice electronically. A patient may request a copy of this Notice at any time.
V. SPECIAL RULES REGARDING DISCLOSURE OF PSYCHIATRIC, SUBSTANCE ABUSE, HIV-RELATED AND MINOR INFORMATION
For disclosures concerning health information relating to care for psychiatric conditions, substance abuse or HIV-related testing and treatment, special restrictions may apply. For example, we generally may not disclose this specially protected information in response to a subpoena, warrant or other legal process unless a patient and/or guardian signs an authorization or a court orders the disclosure.
- Psychiatric Information: If needed for a patient’s diagnosis or treatment in a mental health program, psychiatric information may be disclosed based on the patient’s and/or guardian’s general consent, and limited information may be disclosed without the patient’s or guardian’s authorization, except as specifically permitted under state law.
- HIV-related Information: HIV-related information may be disclosed based on a patient’s and/or guardian’s general consent for purposes of treatment or payment, but the patient’s and/or guardian’s authorization will be necessary for other disclosures, except as permitted under state law.
- Substance abuse treatment: If a patient is treated in a specialized substance abuse program, the confidentiality of alcohol and drug abuse patient records is protected by Federal law and regulations. Generally, we may not say to a person outside the program that the patient attended the program, or disclose any information identifying the patient as an alcohol or drug abuser, unless:
- The patient’s and/or guardian’s consents in writing
- The disclosure is allowed by a court order: or
- The disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation.
Violation of these Federal laws and regulations by us is a crime. Suspected violations may be reported to appropriate authorities in accordance with federal regulations. Federal law and regulations do not protect any information about crime committed by a patient either at the substance abuse program or against any person who works for the program or about any threat to commit such a crime. Federal laws and regulations do not protect any information about suspected child abuse or neglect from being reported under state law to appropriate state or local authorities.
- Minors: We will comply with Connecticut law when using or disclosing health information of minors. For example, if a patient is an non-emancipated minor consenting to a healthcare service related to HIV/AIDS, venereal disease, abortion, outpatient mental health treatment or alcohol/drug dependence, and the patient has not requested that another person b treated as a personal representative; the patient may have the authority to consent to the use and disclosure of his/her health information.
VI. COMPLAINTS
If a patient and/or guardian believe that the patient’s privacy rights have been violated, the patient and/or guardian may file a complaint in writing with the Medical Center or with the Office of civil Rights in the U.S. department of Health and Human Services. To file a complaint with the IHS, contact: Integrated Health Services, Inc.
c/o Integrated Health Services, Inc.
763 Burnside Avenue
East Hartford, CT 06108
We will not retaliate against you if you file a complaint.
VII. CHANGES TO THIS NOTICE
We will promptly revise this Notice whenever there is a material change to the uses or disclosures of health information, your individual rights, our legal duties, or other privacy practices stated in this Notice. We reserve the right to change this Notice and to make the revised or new Notice provisions effective for all health information already received and maintained by the IHS as well as for all health information we receive in the future. You will not automatically receive a revised Notice We will post a copy of the current Notice in the IHS. You may also request a copy of the revised Notice at your next appointment.
VIII. EFFECTIVE DATE
This Notice went into effect on July 1, 2007
IX. FOR FURTHER INFORMATION
If you have any questions about this Notice or would like further information concerning your privacy rights, please contact the Integrated Health Services Privacy Officer at the address above.
Jesse has worked in the Healthcare industry since 2003, primarily in the medical device space. He has direct experience in device management across a wide portfolio of technologies including medical imaging, general biomedical, and surgical instruments. Hands on experience leading teams focused on maintenance, device tracking, lifecycle management and capital planning for replacement. He has held national roles overseeing supply chain, logistics, contracting, pricing/marketing, customer contact center, and a wide range of back off support functions.
Christopher Sour is an Investment Analyst currently working at CVS Health. As an alumni of the CVS Financial Leadership Development Program, Chris has worked in Internal Audit, Corporate Treasury, and Investment Management. In his current role, Chris aids in the management of hedge fund, CLO, equity portfolios, and pension plan assets. Responsibilities include making new investments across the asset classes, managing risk, on-going monitoring of investments and allocating capital across the asset classes.
Jeff Walsh is a graduate of Babson College in Wellesley, MA, with a degree in Accounting. Prior to joining CRT as their CFO, Jeff worked in public accounting for 19 years, specializing in non-profit and governmental audits throughout the northeast region. Jeff has extensive experience with the Federal Single Audit and State of Connecticut Single Audit requirements, in addition to Form 990 preparation and indirect cost rate calculations. 
James Cornell is the Senior Manager of Accounting Compliance at Hartford Steam Boiler. For the last 17 years, he has provided his assurance and financial analysis experience to healthcare and insurance entities in Connecticut. He joined the IHS board in May 2023.
Dr. Saunders is a staff psychologist working at the Institute of Living/Hartford Hospital and is also Board Certified in Clinical Psychology. She is the Director of the new initiative, the Center for Gender Health at Hartford Healthcare. In 2015, Dr. Saunders was named Employee of the Year for Hartford Hospital and in 2019, she was the recipient of the Ned Graffagnino Award for distinguished service in the areas of community-oriented work and collaboration with other mental health professionals. Her areas of expertise include LGBTQ mental health, child psychopathology, behavior management, parent training, and family therapy. She appears regularly in local TV news to provide psychological input on topics relevant to youth and families and currently has two weekly segments on WFSB/Ch. 3 Great Day CT, related to child mental health. 
Stephanie Begen retired in 2021 after 44 years as an educator in the greater Hartford region. She began her career as an elementary Special Education Teacher in Hartford and wrapped up the last 22 years of her career as a middle school Special Education Teacher in Berlin. Along the way she also worked at the Capitol Region Education Council, the University of Connecticut, Division of Child and Family Studies, and at Newington Children’s Hospital as a Patient/Team Coordinator for the PEDAL program. Stephanie was a passionate educator working with families/caregivers, service providers and outside agencies to ensure that her students’ educational, emotional, and healthcare needs were met. 
Yanira Nazario is a Universal Banker at M&T Bank, with over 15 years of experience in banking. She is passionate about the community she serves and dedicated her time volunteering in and around Hartford County. 
Nestor Leon has over 25 years of workforce development experience. He has designed, implemented and monitored programs that provide pathways to economic self-sufficiency. He has coordinated programs in multiple states such as Connecticut, Massachusetts, Rhode Island, New York, and Virginia that resulted in improved access for low-income customers. He is currently working with the Connecticut State College and Universities (CSCU) on a 35-million-dollar statewide healthcare and social work initiative.
Dr. Andrew Feller is a Family Physician who currently works with Trinity Health of New England. For the last 20+ years, he has split his time working as a family doctor in East Hartford, taking care of hospitalized patients at St. Francis Hospital, and teaching residents and medical students at University of CT in Farmington. 
Matthew Cholewa is an attorney with over 30 years of experience. Matt has spent about half his career in private practice and half in the title insurance industry and is currently employed with Old Republic National Title Insurance Company as First Vice President & Senior Underwriting Counsel for its Commercial Agency Services office based in Hartford, Connecticut. While in private practice, Matt’s practice consisted of commercial and residential real estate transactions, real property related litigation, zoning, tax appeals and other small business matters.
Joe Murphy is a Certified Financial Planner™ at Gateway Financial Partners. He has over 40 years of experience in Wealth Management and Investment Planning, including working with teams in the bank investment arena. 
Kareen Wilson is a team leader, owner, and patient-therapist at Contemporary General Dentistry in West Hartford, CT, and Smile Studio Dentistry in Hartford, CT. Kareen also works as an adjunct professor in the leadership program at Goodwin University. She has over twenty-five years of experience in clinical dental hygiene and office management. 
For over 25 years Doug Edwards has been a family services consultant who designs and facilitates fatherhood-focused programs. He provides professional development and training for family workers at state and non-profit human services agencies.