THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
At Care New England (CNE), we are deeply committed to protecting the privacy of your health information. This commitment is at the heart of our promise to provide you with exceptional and secure healthcare services. This notice explains how we handle your medical information, ensuring transparency and control for you, our valued patient. Care New England Health System encompasses all of its hospitals, healthcare entities, and physician practices that are subsidiaries. Throughout this document, “CNE,” “we,” “us,” or “our” refers to these entities. This notice applies not only to our employed healthcare professionals and staff but also to all professionals accessing your medical records within our facilities. It’s important to remember that you might receive a separate privacy notice from your personal healthcare provider, detailing their specific practices.
Care New England’s Dedication to Privacy
Protecting your Health Information (PHI) is not just a legal requirement—it’s a core value at Care New England. We are mandated by law to uphold the privacy of your PHI and are dedicated to this responsibility. Furthermore, we are legally bound to provide you with this detailed Notice outlining our legal duties and privacy practices concerning your PHI. In the event of any breach of your unsecured PHI, we are committed to notifying you promptly.
While there are specific circumstances where we may use and/or disclose your PHI, as detailed in Sections III and IV, our general principle is to only use and/or disclose the minimum necessary PHI to achieve the intended purpose. We operate strictly within the terms of this Notice.
Please be aware that this Notice may be updated periodically. Any revisions will apply to all of your PHI, including information we already possess and any PHI created or received before the issuance of a new Notice. When changes occur, we will immediately post the updated Notice prominently at our facilities, on the websites of all CNE affiliates providing healthcare services, and on the main CNE website at carenewengland.org. You can also request a hard copy of the latest Notice from any CNE affiliate where you received services or by contacting CNE Compliance Services.
How Your Health Information Is Used and Disclosed Without Your Authorization
We utilize and share your PHI for a variety of reasons essential to delivering and managing your healthcare. While some disclosures require your explicit written authorization (explained in Section IV), many essential uses and disclosures do not. Your authorization is not required for the following categories:
A. Essential Healthcare Operations: Treatment, Payment, and Operations
- For Treatment: Your PHI is vital for coordinating and delivering your care. We may share your PHI with physicians, nurses, medical students, and other healthcare providers involved in your treatment. For instance, if you are consulting with a specialist, relevant PHI will be shared to ensure coordinated and effective care. This sharing often occurs through secure, shared electronic health records, enabling seamless communication and information access among your care team.
Alt: Healthcare professionals collaborating, reviewing patient charts, and coordinating treatment plans within Care New England facilities, emphasizing integrated care.
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For Payment: To ensure the financial operations of healthcare services, we use and disclose your PHI for billing and payment processes. This may involve sharing information with your health plan to secure payment for services. We may also work with billing companies and claims processors, and in some cases, disclose PHI to other healthcare providers if necessary for them to receive payment for their services to you.
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For Healthcare Operations: To continuously improve our services and manage our operations effectively, we may use your PHI. This includes evaluating the quality of care you receive, assessing the performance of our healthcare professionals, and ensuring compliance with all applicable laws. Disclosures may be made to accountants, attorneys, and other administrative personnel essential for our operational needs.
B. Other Necessary Uses and Disclosures Without Your Authorization
Beyond treatment, payment, and operations, there are other specific situations where we may use and disclose your PHI without your authorization, always within legal and ethical boundaries.
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Legal and Regulatory Requirements: We are obligated to disclose PHI when mandated by law. This includes compliance with federal, state, or local laws, legal orders, lawful processes, and disclosures to coroners, medical examiners, or funeral directors as legally authorized.
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Public Health Activities: Protecting public health is a critical responsibility. We may disclose PHI to public health authorities for purposes such as:
- Preventing or controlling disease, injury, or disability.
- Reporting child abuse and neglect.
- Reporting abuse, neglect, or domestic violence (if we reasonably believe you are a victim).
- Reporting information related to products under the FDA’s jurisdiction.
- Alerting individuals who may have been exposed to a communicable disease.
- Reporting work-related illnesses and injuries to employers as required by law.
- Providing immunization records to schools as required by state law.
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Health Oversight Activities: To ensure accountability and quality within the healthcare system, we may disclose PHI to government agencies for health oversight activities, such as investigations and inspections of healthcare providers and organizations.
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Organ Donation: To support life-saving organ and tissue donation and transplantation, we may disclose PHI to organ banks and similar entities as permitted by law.
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Research: Advancing medical knowledge is vital. We may use and disclose PHI for research purposes, always adhering to ethical guidelines and legal requirements. Depending on the nature of the research and applicable state laws, we may seek your authorization before using or disclosing your PHI for research.
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Preventing Serious Harm: In situations where there is a serious threat to health or safety, we may disclose PHI to law enforcement or other appropriate authorities to prevent harm to an individual or the public.
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Government Functions: For essential government functions, we may disclose PHI for military and veteran activities, national security and intelligence purposes, protective services for the President, and in correctional facility settings.
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Workers’ Compensation: To comply with workers’ compensation laws, we may use and disclose PHI related to workplace injuries or illnesses.
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Appointment Reminders and Health-Related Services: To enhance your healthcare experience, we may use your PHI to provide appointment reminders, updates on registration and insurance, billing and payment information, pre-procedure assessments, test results, and information about treatment options and other health services or benefits we offer.
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Fundraising Activities: To support and expand our community health services, we may contact you for fundraising purposes. Donations help us enhance healthcare programs and services. You have the right to opt out of fundraising communications by calling (401) 921-8526 and providing your contact information. Your decision will not affect your treatment or payment for services.
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Integration with Affiliated Healthcare Providers: To ensure seamless and coordinated care, we may share your PHI with healthcare providers affiliated with Care New England. This sharing facilitates efficient treatment, payment processes, and overall healthcare operations across our network.
Uses and Disclosures Requiring Your Written Authorization
For any uses and disclosures of your PHI beyond those described in Section III, we are required to obtain your written authorization. You have the right to revoke this authorization at any time, stopping any future uses or disclosures of your PHI under that authorization. To revoke, submit a written request to the CNE affiliate where you received services or contact CNE Compliance Services.
A. Highly Confidential Information
Certain categories of your health information are considered “Highly Confidential Information” and are subject to even stricter privacy protections under state and federal laws. This includes:
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Psychotherapy Notes: Notes recorded by a mental health professional during therapy sessions are generally protected. We will not disclose these notes without your authorization, except for very specific purposes:
- Use by the mental health professional for your treatment.
- Use in mental health counseling training within our facilities.
- Use in defense of legal proceedings initiated by you.
- Disclosures required by law, for public health, health oversight, or to prevent harm.
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Mental Health Treatment Information: Information related to your mental health treatment is also carefully protected. Disclosures are primarily for treatment purposes and payment processing. Limited information may be shared with legal guardians or family members if deemed in your best interest and unless you object. Disclosures may also be made under court order or as required by law, such as in cases of suspected child abuse or to regulatory agencies. In emergencies, mental health treatment information may be disclosed to prevent harm.
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Drug and Alcohol Treatment Records: Federal law provides stringent confidentiality protections for PHI related to alcohol and drug abuse treatment maintained by our substance abuse programs. Disclosure of this information requires your written consent, a court order, or is limited to medical emergencies, research, audits, or program evaluations. Violations of these confidentiality regulations are a crime and can be reported to authorities. These protections do not extend to information about crimes committed within the substance abuse program or threats to program personnel, nor do they prevent reporting of suspected child abuse or neglect as mandated by state law. (Refer to 42 U.S.C. 290dd-3 and 42 U.S.C. 290ee-3 for federal laws and 42 CFR part 2 for Federal regulations.)
B. Marketing
We will not use your PHI for marketing purposes without your explicit written authorization. This means we will not accept payments from third parties in exchange for communicating with you about treatments, products, or services, unless you have authorized us or the communication is legally permitted. However, we may provide refill reminders for prescribed medications or communicate about currently prescribed drugs if any payment received is reasonably related to the cost of communication. We may also engage in face-to-face marketing and offer promotional gifts of nominal value.
C. Sale of PHI
We do not sell your PHI under any circumstances without your written authorization.
Your Rights Regarding Your Health Information
You have significant rights concerning your PHI. Care New England is committed to upholding these rights and providing you with control over your medical information.
A. Requesting Restrictions on Use and Disclosure
You have the right to request limits on how we use or disclose your PHI for treatment, payment, and healthcare operations. While we will consider your request, we are not legally obligated to agree unless the disclosure is to a health plan for payment or healthcare operations and pertains to services you have paid for fully out-of-pocket. If we do agree to your restrictions, we will honor them, except in emergency situations or when legally required.
B. Choosing How We Communicate PHI
You can request to receive communications of PHI at a different address (e.g., work instead of home) or via different methods (e.g., email instead of mail). We will accommodate reasonable requests as long as we can readily provide the information as requested. You can also request us to send a copy of your PHI directly to a designated person. Such requests must be in writing, signed by you, and clearly specify the recipient and delivery details.
C. Accessing and Obtaining Copies of Your PHI
You have the right to inspect and obtain a copy of your PHI. Requests must be submitted in writing. In limited circumstances, we may deny your request, in which case we will provide a written explanation of the reasons and any appeal rights. We will respond within 30 days of your request. We may charge a reasonable fee for copies, as permitted by law. We may also offer a summary or explanation of your PHI if you agree in advance.
D. Receiving an Accounting of Disclosures
You have the right to request a list of instances where we have disclosed your PHI. This list will not include certain disclosures, such as those for treatment, payment, healthcare operations, disclosures authorized by you, disclosures made directly to you or your family, directory disclosures, national security disclosures, disclosures to law enforcement or correctional personnel, or disclosures made before April 14, 2003. We will provide this list for disclosures made within the last six years, unless you request a shorter period. The accounting will include the date of disclosure, recipient identity, information disclosed, and the reason for disclosure. The first request in any 12-month period is free; subsequent requests may incur a reasonable fee. Written requests should be directed to the CNE affiliate where you received services.
E. Correcting or Updating Your PHI
If you believe there is an error in your PHI or that it is incomplete, you can request an amendment or correction. Requests must be in writing, include a reason for the request, and be sent to the CNE affiliate where you received services or to CNE Compliance Services. We will respond within 60 days. We may deny your request if the PHI is accurate, was not created by us, is not accessible to you, or is not part of our records. If we deny your request, we will provide a written explanation. You have the right to file a statement of disagreement, which will be attached to future disclosures of your PHI along with your original request and our denial. If we approve your request, we will amend your PHI and notify you and relevant parties of the change.
F. Receiving a Paper Copy of This Notice
Even if you have agreed to receive this Notice electronically, you are entitled to request a paper copy at any time. This Notice is also available on our website at carenewengland.org.
Minors and Personal Representatives
Parents, guardians, and legal representatives can generally exercise the rights described in this Notice on behalf of minors (children under 18). However, in certain situations, minors may exercise these rights themselves, and their parents or guardians may not.
Filing a Complaint About Our Privacy Practices
If you believe your privacy rights have been violated, you have the right to file a complaint. You can contact the CNE affiliate where you received services or the CNE Privacy Officer (contact information below). You can also submit a written complaint to the U.S. Department of Health and Human Services. Filing a complaint will not affect the care you receive at Care New England.
Contact Information for Privacy Inquiries
For questions about this Notice, to request a new Notice, to file a complaint, or to exercise your rights regarding your PHI, please contact the CNE Privacy Officer:
CNE Privacy Officer
Care New England Compliance Services
800 Butler Drive
Providence, RI 02906
(401) 277-3660
[email protected]
Care New England Affiliates: Butler Hospital, Care New England Medical Group, Kent Hospital, The Providence Center, VNA of Care New England, Women & Infants Hospital. Other affiliates may also be included.
For a Spanish version of this Notice, please click here.
Effective Date of this Notice: September 4, 2018
Alt: Care New England logo representing the health system’s brand and commitment to patient care and privacy, linking to their official privacy notice documentation.
