At American Esoteric Laboratories (AEL), protecting the privacy and security of personal information is essential and is fundamental to our values and to the way we do business.
AEL currently has privacy practices that meet the requirements for all our business activities of existing laws, rules and regulations. New privacy legislation, specifically the Health Insurance Portability and Accountability Act (HIPAA) that went into effect April 14, 2003, requires healthcare organizations to have policies, practices and programs in place demonstrating a strong, commonly accepted privacy standard that the public expects. These laws are based on ten internationally recognized principles. AEL is incorporating these principles into our business practices:
1. Accountability: We are all accountable to protect the privacy of personal information. AEL has designated a Privacy Officer and a HIPAA Privacy Committee charged with incorporating the principles and assuring compliance with the privacy laws that apply to us. The Privacy Officer is available to answer questions about the application of privacy laws to individual situations, as well as to receive concerns or questions about compliance. AEL trains our employees to follow written privacy policies and operational procedures, and also performs ongoing reviews of our privacy practices.
2. Identifying Purposes: AEL identifies the purposes for which it collects, uses and discloses personal information through a posted Privacy Notice located in AEL patient service centers.
3. Consent: AEL uses implied patient consent in collecting, using, disclosing, or storing personal information, providing laboratory services at the request of a healthcare practitioner.
4. Limiting Collection: AEL collects only the personal information that we need in order to provide services and manage the business. Information is collected by fair and lawful means.
5. Limiting Use, Disclosure and Retention: AEL uses or discloses personal information only for purposes identified or with the consent of the individual or as required by law. AEL retains personal information only as long as necessary or required.
6. Accuracy: AEL collects and maintains personal information that is as accurate, complete, and up-to-date as possible to be used for the identified purposes.
7. Safeguards: AEL has appropriate security, physical and administrative safeguards in place to protect personal information.
8. Openness: AEL maintains and communicates clearly defined procedures for informing individuals about our privacy policies and practices.
9. Individual Access: Upon written request, AEL informs individuals of the existence, use, and disclosure of their personal information. When appropriate, AEL provides access to that information and allows the individual to question its accuracy and completeness.
10. Challenging Compliance: Individuals may direct concerns regarding AEL's compliance with these principles to the Privacy Officer. All concerns will be investigated and the results communicated.
Uses and Disclosures of Protected Health Information (PHI)
Treatment: The protected health information (PHI) that we collect may include your Social Security number, your name, address, date of birth, phone numbers, and health care practitioner, as well as other information that is needed to process your lab tests. Using your health information, we will match your particular specimens with your lab results and report the complete information to your health care practitioner. We are committed to collecting only relevant information to help us accurately provide these services for you. We may also release your PHI to other members of your health care team or other laboratories who perform tests for us.
Payment: AEL collects payment for performing your tests from the individual or group that is responsible for you. In order to do this, we release the relevant and necessary billing information about you to the individual or group that is responsible for payment, i.e., your guardian, insurance company, a third-party payment provider, or a collection agency in the case of non-payment. In some cases, you may be responsible for your bill, and you would receive the relevant billing information. We may also share your PHI with companies we have contracted with to manage the payment operation or provide collection services. These companies have the same responsibility as AEL to safeguard your PHI.
Health Care Operations: AEL strives to improve customer service, maintain test accuracy, and develop new services. Your information may be used within the company for these purposes. Our staff is trained and sensitive to privacy issues. As such, they use only the PHI necessary to complete their work for you and others.
Research organizations are sometimes interested in the kind of work we do and may request information for research purposes. Occasionally, AEL takes part in this type of research; however, we do not release information that identifies the individuals we serve. For example, we might release the number of thyroid tests we do in a month, but we would not release information that identifies individuals who had the test done. Sometimes researchers need more details in order to be able to answer a question. In this case, we would contact you directly to ask you for your permission to release more information.
As Permitted or Required by Law: Please note the following circumstances under which we are required by law to release information without notifying you:
To the Food and Drug Administration
To Public Health or legal authorities that are concerned with preventing the spread of disease or controlling accident or injury
To organ and tissue donation organizations
For law enforcement proposes or under subpoena
Your Rights
The following section describes your rights as an individual.
Right to Access: Your health care practitioner formally requests the tests we perform for you at AEL. Your health care practitioner can be your doctor, dentist, or other medical professional that you have seen. They have your complete medical record, including your lab test results. If you wish to access your medical record, you are advised to contact your health care practitioner, as they are responsible for releasing it to you. There may be an unusual circumstance requiring you to request access to your results from AEL. We will have only your tests results and do not have access to your complete medical record. In the unlikely event that your health care practitioner is not able to give you access to lab test results, you may contact our staff or Privacy Officer to get more information about the process we have in place for accessing lab test results.
Right to Correct/Amend: If you find that your information is incorrect, you have the right to ask that it be corrected. There are some circumstances in which we are advised not to make changes. These circumstances are explained in the request form that you can obtain from us.
Right to See Who Has Accessed Your Record: You may request a list of individuals who have viewed your test result record. HIPAA requires that we document any access that is not for the purpose of the normal course of tests performance and laboratory operations.
Right to Complain: If you feel that your privacy rights have been violated, please submit your concern in writing to the Laboratory Privacy Officer or the Secretary of the U.S. Department of Health and Human Services. No negative action will be taken against you should you file a complaint.
OUR VALUES
Commit to Service Excellence Willingly to serve all those with whom we deal; with unsurpassed excellence.
Treat each other with Respect & Honesty To grow a workplace where trust, team spirit, and equity are an integral part of everything we do.
Demonstrate Responsibility & Accountability
To set an example, to take ownership of each situation to the best of our ability, and to seek help when needed.
Be Enthusiastic about Continuous Improvement
To never be complacent, to recognise limitations and opportunities for ourselves and processes; and to learn through these.
Maintain Confidentiality
To keep all information pertaining to patients, as well as professional and commercial issues, in strict confidence.
For further information regarding the Privacy Program at AEL, contact:
Amy Webster, BSMT (ASCP), Laboratory Compliance and Privacy Officer
Phone: (901) 405-8190; Fax: (901) 405-8189; E-mail: apwebster@ael.com