When most patients think of privacy, they think of HIPAA. HIPAA provides the guidelines by which the healthcare system is required to handle the Protected Health Information (PHI) of individual patients. It also defines patients’ rights in regard to their medical records.
Those required to abide by HIPAA regulations are referred to as “covered entities.” The Administrative Simplification standards adopted by Health and Human Services (HHS) under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) apply, then, to any entity that is:
A Health care provider that conducts certain transactions in electronic form;
A Health care clearinghouse; or
In addition to the HIPAA regulations, as a certified treatment program, Sunrise also must follow the more stringent privacy regulations as outlined in Chapter 42 of the Code of federal Regulations. State and Federal laws and regulations protect the confidentiality of patient records maintained by Sunrise. This means that clinic staff may not disclose records or information about a patient to persons outside of Sunrise, UNLESS:
The patient consents in writing on a Release of Information (ROI) form. ROI's will be completed with Sunrise staff;
To the Food and Drug Administration (FDA) if there is a reason to believe that the health of the patient may be threatened by an error in the manufacturing, label, or sale of an FDA-approved product;
For internal communications between Sunrise staff members;
The patient discloses child or elder abuse or neglect, or Sunrise staff suspects child or elder abuse or neglect;
The patient presents as either a threat to harm self or others;
The patient commits a crime either at Sunrise or against any person(s) who work for Sunrise or there is a threat to commit such a crime;
There is a Qualified Service Agreement in place;
The disclosure is allowed by a court order;
The disclosure is to prevent multiple enrollments in opioid treatment program services; or
The disclosure is made to medical personnel in a bona fide medical emergency or to qualified personnel for scientific research, audit, or service evaluation processes.
There are other ways that Sunrise works to provide you with discreet treatment:
Although Sunrise conducts some commercial advertisement, patients’ information is never used in those processes. Awareness will be raised via mailers and other communications sent to appropriate community resources (i.e. medical offices, counselors, etc.).
Circumstances permitting, paper correspondence with your personal physician will be limited to a letter at the beginning of your treatment to explain the program expectations and restrictions so that they can properly assist in your care and upon your completion of or dismissal from the program.
Every attempt will be made to consistently refer to you by first name only on the phone and when you are at the office. You will also be assigned a unique patient-identifying number.
Your medical records will be kept on file even after your treatment ends. At no point will they be given to or shared with any other entity unless legally mandated or requested by you. We do reserve the right to communicate with your insurance company, as needed, to secure coverage for services and/or medication.
If someone were to ask about a patient and none of the previous conditions had been met, program staff would reply “we can neither confirm nor deny that that person is a patient at Sunrise Treatment Center.” This is done to protect your privacy and your rights under federal and Ohio law.
Sunrise is committed to making this a very discreet and professional treatment option for you. Hopefully you’ll find the location, staff and policies meet your expectations for privacy as you get the help you need.
Violation of federal law by Sunrise is a crime. Suspected violation may be reported to appropriate authorities in accordance with federal regulations.
Patient input is highly valued at Sunrise. There are several mechanisms by which Sunrise gathers input from patients including bi-annual patient satisfaction surveys and the suggestion box. Additionally, patients are free to communicate their input directly to their counselor or other program staff.
Patients are to notify program staff immediately if they identify any potential risks to themselves or other patients. Program staff will respond to such concerns within 72-hours of being notified.
All patients have the right not to be discriminated against for receiving services on the basis of race, ethnicity, age, color, religion, gender, national origin, sexual orientation, gender identity, status as a parent, physical or mental handicap, developmental disability, genetic information, human immunodeficiency virus status, or in any manner prohibited by local, state, or federal laws.
Sunrise Treatment Center is dedicated to professional behavior that respects the rights and dignity of its patients. Abuse and/or neglect of patients by employees, contract staff, student interns and volunteers are expressly prohibited by Sunrise Treatment Center. All program staff shall always follow the Code of Ethics and Business Conduct. Additionally, all direct service staff shall follow the American Counseling Association (ACA) Code of Ethics. A copy of the Code of Ethics and Business Conduct and the American Counseling Association Code of Ethics shall be available upon request.
Sunrise must maintain compliance with various federal and state laws that prescribe the standards of care and the privileges given to patients who meet certain criteria. Final authority to grant individual "exceptions" to these regulations rests, not with Sunrise staff, but with designated federal and state officials. Any patient wishing to be admitted for treatment must provide consent for treatment.
Complaints pertaining to counselor conduct should be directed to the:
Ohio Chemical Dependency Professionals Board
77 South High Street, 16th Floor
Columbus, OH 43215
Phone: (614) 387-1110
Sunrise Treatment Center supports and protects fundamental human, civil, constitutional, and statutory rights of each patient.
The right to be treated with consideration and respect for personal dignity, autonomy, and privacy.
The right to receive services that are appropriate and respectful of personal liberty.
The right to reasonable protection from physical, sexual, or emotional abuse and inhumane treatment.
The right to participate in any appropriate and available service that is consistent with an individual service plan (ISP), regardless of the refusal of any other service, unless that service is a necessity for clear treatment reasons and requires the person's participation.
The right to receive services in the least restrictive, feasible environment.
The right to be informed of one's own condition.
The right to be informed of available program services.
The right to give informed consent to, refuse, or expression of choice regarding any service, treatment, or therapy, release of information, concurrent services, composition of the service delivery team, or involvement in research projects, including medication absent an emergency.
The right to participate in the development, review, and revision of one's own individualized treatment plan and receive a copy of it.
The right to freedom from unnecessary or excessive medication, and to be free from restraint or seclusion unless there is an immediate risk of physical harm to self or others.
The right to freedom from abuse, financial or other exploitation, retaliation, humiliation, and neglect.
The right to be informed and the right to refuse any unusual or hazardous treatment procedures.
The right to be advised and the right to refuse observation by others and by techniques such as one-way vision mirrors, tape recorders, video recorders, television, movies, photographs, or other audio and visual technology. This right does not prohibit an agency from using closed-circuit monitoring to observe seclusion rooms or common areas, which does not include bathrooms or sleeping areas.
The right to consult with an independent treatment specialist or legal counsel at one's own expense.
The right to confidentiality of communications and personal identifying information within the limits and requirements for disclosure of patient information under state and federal laws and regulations.
The right to have access to one's own client record unless access to certain information is restricted for clear treatment reasons. If access is restricted, the treatment plan shall include the reason for the restriction, a goal to remove the restriction, and the treatment being offered to remove the restriction.
The right to access or referral to legal entities for appropriate representation, self-help support services, and advocacy support services.
The right to adherence to research guidelines and ethics when persons served are involved.
The right to privacy.
The right to have access to information pertinent to the person served and sufficient time to facilitate his or her decision-making and one's own patient record in accordance with program procedures.
The right to be informed a reasonable amount of time in advance of the reason for terminating participation in a service, and to be provided a referral, unless the service is unavailable or not necessary.
The right to be informed of the reasons for denial of a service.
All patients have the right to freedom from discrimination for receiving services on the basis of an individual’s inability to pay; whether payment for those services would be made under Medicare, Medicaid, or CHIP; the basis of race, ethnicity, age, color, religion, gender, national origin, sex, sexual orientation, gender identity, status as a parent, physical or mental handicap, developmental disability, genetic information, human immunodeficiency virus status, or in any manner prohibited by local, state, or federal laws.
The right to know the cost of services.
The right to be verbally informed of all client rights, and to receive a written copy upon request.
The right to exercise one's own rights without reprisal, except that no right extends so far as to supersede health and safety considerations.
The right to file a grievance.
The right to investigation and resolution of alleged infringement of rights.
The right to have oral and written instructions concerning the procedure for filing a grievance, and to have assistance in filing a grievance if requested.
The right to consult with an independent treatment specialist or legal counsel at one's own expense.
The right to have a review of any restrictions of rights or privileges reviewed by the clinical team. This may or may not result in a change in status of such restrictions.
All grievances must be written, dated and signed by the patient or the person filing the grievance on behalf of the patient and should include the date, approximate time, description of the incident and names of the individuals involved in the incident/situation being grieved.
Grievances should be given to Corporate Compliance Officer John Campbell at:
6460 Harrison Ave., Suite 300
Cincinnati, OH 45247
Office Hours are:
Monday, Wednesday, and Friday 7 A.M. - 3 P.M.
Tuesdays and Thursdays 9:30 A.M. - 5:30 P.M.
In the event the Corporate Compliance Officer is not on the premises, the grievance can be given to the facility’s Program Director. They will assist you in filing a grievance upon your request. Within 21 calendar days of receiving the grievance, the program will make a resolution decision on the grievance. Any exceptions that cause this time period to be extended will be documented in the grievance file and written notification will be given to the patient or persons filing grievances on the patient’s behalf. Records of patient grievances will be maintained for 2 years from date of resolution and include: a copy of the grievance, documentation reflecting the process used, resolution/remedy of the grievance and documentation, and if applicable, documentation of the justification for extending the time period for resolving the grievance beyond 21 calendar days.
Within 3 working days of receiving the grievance, the program will provide the patient with a written acknowledgment that includes: [a] the date the grievance was received, [b] a summary of the grievance, [c] an overview of the grievance investigation process, [d] a timetable for completing the investigation and notification of the resolution, and [e] the treatment provider contact person’s name, address and telephone number.
At any time, patients or persons filing grievances on a patient’s behalf have a right to file a grievance, in addition to, or instead of, with any outside organization that include, but are not limited to the following:
Ohio Mental Health and Addiction Services (OHMAS)
30 E. Broad St., Suite 742
Columbus, Ohio 43215
Region V - Chicago (Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin) Office for Civil Rights
U.S. Department of Health and Human Services
233 N. Michigan Ave., Suite 240
Chicago, IL 60601
Voice Phone (312) 886.2359
FAX (312) 886.1807
TDD (312) 353.5693
Ohio Disability Rights Service
200 South Civic Center Dr., Suite 300
Columbus, Ohio 43215
Hamilton County ADAMH Board
2350 Auburn Avenue
Cincinnati, OH 45219
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