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ADVOCATE AURORA HEALTH
NOTICE OF PRIVACY PRACTICES
THIS NOTICE OF PRIVACY PRACTICES (“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.
This Notice applies to any health care facility or medical group now or in the future controlled by
or under common control with Advocate Aurora Health and any of its affiliates or subsidiaries
(collectively referred to as "Advocate Aurora Health " and designated as an Affiliated Covered
Entity), which includes without limitation the following:
Hospitals and Medical Staffs Other
Advocate BroMenn Medical Center Advocate Home Care Products, Inc.
Advocate Christ Medical Center Advocate Home Health Services
Advocate Eureka Hospital Advocate Hospice
Advocate Condell Medical Center ACL Laboratories
Advocate Children’s Hospital, Oak Lawn Advocate High Technology, Inc.
Advocate Good Samaritan Hospital Advocate Occupational Health
Advocate Good Shepherd Hospital Advocate Family Care Network
Advocate Illinois Masonic Medical Center Dreyer Clinic, Inc.
Advocate Lutheran General Hospital
Advocate Children’s Hospital, Park Ridge
Advocate Sherman Hospital
Advocate South Suburban Hospital
Advocate Trinity Hospital
Aurora BayCare Medical Center Aurora at Home
Aurora Medical Center Manitowoc Aurora Family Services
Aurora Medical Center Oshkosh Aurora Retail Pharmacies
Aurora Sheboygan Memorial Medical Center Aurora Quick Care
Aurora Medical Center Grafton
Aurora Medical Center of Washington County – Hartford
Aurora Medical Center Summit
Aurora Sinai Medical Center
Aurora St. Luke’s Medical Center
Aurora St. Luke’s South Shore
Aurora West Allis Medical Center
Aurora Lakeland Medical Center
Aurora Memorial Hospital of Burlington
Aurora Medical Center Kenosha
Aurora Psychiatric Hospital
Medical Groups
Advocate Medical Group
Aurora Health Care Medical Group
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UNDERSTANDING YOUR MEDICAL INFORMATION
We understand that medical information about you and your health is personal. We are committed
to protecting your medical information. Each time you visit a hospital, physician, or other health
care provider, they document information about you and your visit. Typically, this record contains,
among other information, your name, symptoms, health history, examination and test results,
diagnoses, current and future treatment, and billing-related information (“Medical Information”).
This Medical Information is used to provide you with quality care and to comply with certain legal
requirements.
This Notice will tell you how we may use and disclose Medical Information about you. It also
describes your rights and certain obligations we have regarding the use and disclosure of your
Medical Information.
We are required by law to:
• Maintain the privacy of your Medical Information.
• Notify you following a breach of unsecured Medical Information.
• Provide you with this Notice of our legal duties and privacy practices with respect to
information we collect and maintain about you.
• Follow the terms of this Notice or a Notice that is in effect at the time Advocate Aurora Health
uses or discloses your Medical Information.
USES AND DISCLOSURES OF YOUR MEDICAL INFORMATION
The following categories describe different ways in which we may use and disclose your Medical
Information without your written permission. With respect to use and disclosure of your Medical
Information for Treatment, Payment and Health Care Operations, we may share your Medical
Information with any of the entities referenced in this Notice, or any physician or other health care
provider as allowed by law.
For Treatment. We may use your Medical Information to provide, coordinate or manage your
medical treatment and related services. Your Medical Information can be shared with physicians,
nurses, technicians and others involved in your care and these individuals will collect and document
information about you in your medical record. To assure immediate continuity of care, we may
disclose information to a physician or other health care provider who will be assuming your care.
For example, different departments may share your Medical Information to coordinate the different
services you may need such as prescriptions, lab work, meals and X-rays or other diagnostic tests.
To facilitate access to information for the treatment purposes of shared patients, Advocate Aurora
Health may participate in the electronic exchange of health information with other entities.
For Payment. In most cases, we may use and disclose your Medical Information so that the
treatments and services you receive may be billed and payment may be collected from you, an
insurance company or a third party. For example, we may need to give information about the
surgery you received to your health plan so your health plan will pay us or reimburse you for the
surgery. We also may tell your health plan about a treatment you are going to receive to obtain prior
approval or to determine whether your plan will cover the treatment. In certain situations, we may
disclose your Medical Information to a collection agency if a bill is not paid. Additionally, we may
also disclose your health information to another health care provider for their payment related
activities.
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For Health Care Operations. We may use and disclose your Medical Information in connection
with our health care operations including, but not limited to the following:
• Quality assessment and improvement activities. Related
functions that do not include treatment.
• Competence or qualification reviews of health care professionals.
• Training programs, accreditation, certification, licensing or credentialing activities.
Additionally, we may also disclose your Medical Information to another covered entity that you have
seen so they may improve their quality or cost, or for their other health care operations purposes.
Joint Electronic Medical Record. In an effort to improve the quality and efficiency of health care in our
surrounding communities through the adoption of interoperable electronic medical records, Advocate
Aurora Health may allow other health care providers to participate in a joint electronic medical record.
As an example, by allowing other health care providers to share an electronic medical record, they can
improve the efficiency of a patient’s health care with the ability to electronically prescribe medications or
order tests. These health care providers are also held to the same high standards for protecting the
privacy and security of Medical Information. Health care provider participants are expected to ensure
that users of the joint electronic medical record only access, use, and disclose the Medical Information
only in accordance with applicable law and policies.
Directory (Hospitals Only). When you are a patient in our hospital, we may list your name, room
location, general condition (such as fair or stable), and religious affiliation in the hospital’s inpatient
directory. This directory information, except for your religious affiliation, may be provided to
people who ask for you by name. We may disclose your name, room location, general condition,
and religious affiliation to a member of the clergy who asks for you by your name or by your listed
religious affiliation. We may also disclose your name and general condition to a member of the
media who asks for you by name. If you do not want to be listed in our hospital directory or do
not want us to give such information to members of either the clergy, media, or general public,
you must inform your nurse or a registration representative. Please note that if you are not listed
in our hospital directory, we will not confirm to those who ask for you at the visitors’ desks or who
call the operator that you are currently a patient. In addition, you will not be able to receive mail or
flower deliveries.
If you are receiving mental health or substance use services in an inpatient behavioral health unit
during this hospitalization, we will not disclose any information without your prior written
authorization.
Individuals Involved in Your Care or Payment for Your Care. We may disclose the minimum
necessary Medical Information about you to a family member, other relative, close personal friend or
any other person you identify who is involved in your medical care. We also may disclose the
minimum necessary information to someone who helps pay for your care. If you are able and
available to agree or object, we will give you the opportunity to agree or object to such uses and
disclosures. If you are not available or in the event of an emergency or other situation where you are
not able to identify your chosen person(s) to receive communications about you, we may exercise our
professional judgment to determine whether such a disclosure is in your best interest, who is the
appropriate person(s) and what Medical Information is relevant to their involvement with your health
care. We may also disclose your Medical Information to an organization, such as the American Red
Cross which is assisting in a disaster relief effort, so that your family can be notified about your
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condition, status and location. We will also use our professional judgement and our experience with
common practice to make reasonable inferences of your best interest in allowing a person to pick up
filled prescriptions, medical supplies, X-rays or other similar forms of Medical Information.
Research. Under certain circumstances, we may use or disclose your Medical Information to
identify you as a potential candidate for a research study that has been approved by an Institutional
Review Board. This approval is given after an evaluation of a proposed research project and its
uses of Medical Information, and always with an effort to balance the requirements of sound
research with patients’ need for privacy of their Medical Information. We may disclose Medical
Information about you to people preparing to conduct a research project, for example, to help them look
for patients with specific medical needs, so long as the Medical Information they review does not
leave the site. We may use or disclose your Medical Information without your consent or authorization
if an Institutional Review Board or Privacy Board approves a waiver of authorization for disclosure.
To Avert a Serious Threat to Health or Safety. We may use or disclose your Medical Information
to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.
Business Associates. We provide some services through other persons or companies that need
access to your health information to carry out these services. The law refers to these persons or
companies as our Business Associates. We may disclose, as allowed by law, your health
information to our Business Associates so that they can do the job we have contracted with them to
do. Examples of Business Associates include companies that assist with billing services or copying
medical records. We may send other business associates called registries (such as a Cancer
Registry) summarized information about patients who have been treated with similar problems such
as cancer or trauma, to help physicians improve the quality of care for other patients with similar
problems. We require through a written contract that our Business Associates use appropriate
safeguards to ensure the privacy of your Medical Information.
Fundraising. Advocate Aurora Health is a not-for-profit organization that relies on charitable gifts
to support its mission. In the continuing effort to enhance Advocate Aurora Health’s capacity to
conduct its mission of service to patients and families, periodic communications and invitations to
donate may be sent to patients’ families and friends of Advocate Aurora Health by the Advocate
Charitable Foundation or Aurora Health Care Foundation. The law allows us to share minimal
information about you with our fundraising foundations; however, we will not share your
information with other organizations for fundraising purposes. If you do not wish to receive
communications from Advocate Charitable Foundation, please write to Advocate Charitable
Foundation, 3075 Highland Parkway Suite 600, Downers Grove Illinois 60515, call 630-929-6900,
or email acf-opt-out@advocatehealth.com. If you do not wish to receive communications from the
Aurora Health Care Foundation, please visit Aurora.org/FoundationOptOut or call 877-460-8730.
Advocate Charitable Foundation, mission and spiritual care, Aurora Health Care Foundation
representatives, or others on their behalf may on occasion visit you during your stay in the hospital in
order to inquire about the quality of your stay or to offer any needed assistance. If you do not want
Advocate Charitable Foundation or Aurora Health Care Foundation representatives, mission and
spiritual care, or others on their behalf to be informed about your hospital stay, please inform your
nurse or a registration representative during your stay at the hospital.
Other Communications with You. We may use and disclose your Medical Information to contact
you at the address and telephone numbers you give us about scheduled or canceled appointments
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with your physicians or other health care team members, registration or insurance updates, billing
and/or payment matters, information about patient care issues, treatment choices and follow-up care
instruction, and other health-related benefits and services that may be of interest to you. This may
include leaving messages at your home or on voicemail or mailing you postcard reminders. Such
communications may be sent to you via text message or email, to the extent that we have been
provided with a cell phone number or email address.
SPECIAL SITUATIONS
We may also use and disclose your Medical Information without your written permission for the
following purposes:
Organized Health Care Arrangement. Advocate Aurora Health participates in the About Health
Organized Health Care Arrangement (OHCA), an organized system of health care in which more than
one covered entity participates in the joint arrangement. The purpose of the participation includes
conducting quality assessment and improvement activities, conducting utilization review, and
performing other clinically integrated network activities. Your Medical Information may be shared
with other About Health OHCA participants for these purposes.
Lawsuits and Disputes. We may disclose your Medical Information in the course of a judicial and
administrative proceeding, in response to an order of a court or other tribunal to the extent that such
disclosure is authorized and, in certain conditions, in response to a subpoena, discovery request or
other lawful process.
Law Enforcement. We may disclose your Medical Information to the police or other law
enforcement officials as part of law enforcement activities, in investigations of criminal conduct, in
response to a court order, in emergency circumstances, or when otherwise required to do so by law.
Required by Law. We may disclose your Medical Information when required by law to do so.
Disaster Relief Efforts. We may disclose your Medical Information to organization for the purpose
of disaster relief efforts.
Coroners, Medical Examiners and Funeral Directors. We may release Medical Information about
you to a coroner or medical examiner as necessary to identify a deceased person or to determine the
cause of death. We also may release your Medical Information to funeral directors as necessary for
them to carry out their duties.
Organ and Tissue Donation. If you are an organ donor, we may release your Medical Information to
organizations that obtain organs or handle organ, eye or tissue transplantation. We may also release
your Medical Information to an organ bank to arrange for organ or tissue donation and
transplantation.
Military and Veterans. If you are a member of the military or a veteran, we may release your
Medical Information to the proper authorities so they may carry out their duties under the law.
Inmates. If you are an inmate in a correctional institution or in the custody of a law enforcement
official, we may disclose Medical Information about you to the correctional institution or law
enforcement official as necessary so that their duties can be carried out under the law.
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Workers Compensation. We may disclose your Medical Information as allowed or required by state
law relating to workers’ compensation benefits for work-related injuries or illness or to other similar
programs.
Public Health Activities. We may disclose your Medical Information for the following public
health activities: (1) to report health information to public health authorities for the purpose of
preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to
public health authorities or other government authorities authorized by law to receive such
reports; (3) to report information about products and services under the jurisdiction of the U.S.
Food and Drug Administration; (4) to alert a person who may have been exposed to a
communicable disease or may otherwise be at risk of contracting or spreading a disease or
condition; and (5) to report information to your employer as required under laws addressing
work-related illnesses and injuries or workplace medical surveillance. The appropriate
government authorities may also be notified if we reasonably believe a patient has been the victim of
elder abuse, neglect or domestic violence.
Health Oversight Activities and Specialized Government Functions. We may disclose your Medical
Information to local, state or federal government authorities or agencies that oversee health care
systems and ensure compliance with the rules of government health programs, such as Medicare or
Medicaid and, under certain circumstances, to the U.S. Military or U.S. Department of State.
Uses and Disclosures Not Covered in this Notice. Other uses and disclosures of your Medical
Information will be made only with your written permission unless otherwise permitted or required
by law. If you provide us with permission to use or disclose Medical Information about you, you
may revoke that permission in writing at any time. If you revoke your permission, we will no longer
use or disclose Medical Information about you for the reasons covered by your written permission.
Please understand that we are unable to take back any disclosures already made with your
permission and that we are required to retain the records of the care provided to you.
USES AND DISCLOSURES REQUIRING YOUR WRITTEN AUTHORIZATION
Use or Disclosure with Your Authorization. We must obtain your written authorization for most
uses and disclosures of psychotherapy notes, uses and disclosures of Medical Information for
marketing purposes and disclosures that constitute the sale of Medical Information. Additionally,
other uses and disclosures of Medical Information not described in this Notice will be made only
when you give us your written permission on an authorization form (“Your Authorization”). For
instance, you will need to sign and complete an authorization form before we can send your PHI to a
life insurance company.
Uses and Disclosures of Your Highly Confidential Information. Federal and state laws require
special privacy protections for certain highly confidential information about you (“Highly
Confidential Information”). This Highly Confidential Information may include the subset of your
Medical Information that is maintained in psychotherapy notes. Other Highly Confidential
Information may include HIV test results, mental health or substance use information regulated by
other laws. These state and federal laws may have more restrictive requirements. In most cases, in
order for us to disclose your Highly Confidential Information for a purpose other than those
permitted by law, we must have Your Authorization.
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Revocation of Your Authorization. You may withdraw (revoke) Your Authorization or any written
authorization regarding your Highly Confidential Information (except to the extent we have taken
action in reliance upon it) by delivering a written statement to the Privacy Officer identified below.
YOUR RIGHTS REGARDING YOUR MEDICAL INFORMATION
You have the following rights regarding the Medical Information we maintain about you:
Right to Inspect and Copy. You may request access to your medical record and billing records
maintained by us in order to inspect and request copies of the records. Under limited circumstances,
we may deny you access to a portion of your records. If you would like to access your records, you
must submit your request in writing.
• To obtain a copy of your Medical Information contact the medical records department at the
facility where you receive care.
• To obtain your billing information, contact the billing department
• To request information from a retail pharmacy or vision center, inquire at the counter.
If you request a copy of your Medical Information, we may charge you a cost-based fee, consistent
with applicable state law, that includes labor for copying the Medical Information; supplies for
creating the paper copy or electronic media if you request an electronic copy on portable media; our
postage costs, if you request that we mail the copies to you; and if you agree in advance, the cost of
preparing an explanation or summary of the Medical Information. If you are denied access to your
Medical Information, you may request that the denial be reviewed. A licensed health care
professional chosen by Advocate Aurora Health will review your request and the denial. The person
conducting the review will not be the person who denied your request. We will comply with the
decision that is the outcome of the review.
Right to Amend. If you feel that the Medical Information we have on record is inaccurate or
incomplete, you have the right to request an amendment as long as the information is kept by or for
Advocate Aurora Health. If the Medical Information is kept by another hospital or provider, we
cannot act on your request. You must contact them directly. Your request for an amendment must be
in writing and must state the reasons for the request. The written request can be made using the
amendment request form available in the medical records department at each Advocate Aurora
Health site of care. We may deny your request for an amendment if it is not in writing or does not
include a reason to support the request. We are not obligated to make all requested amendments, but
will give each request careful consideration. If your request is denied, you have the right to send a
letter of objection that will then be attached to your permanent medical record. Please note that even
if we accept your request, we may not delete any information already documented in your medical
record.
Right to an Accounting of Disclosures. You have the right to ask us for an “accounting of
disclosures.” This is a listing of certain individuals or entities that have received your Medical
Information from Advocate Aurora Health.
The listing will not cover Medical Information that was given to you or your personal representative
or to others with your permission. In addition, it will not cover Medical Information that was given
in order to:
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• Provide or arrange care for you;
• Facilitate payment for your healthcare services; and/or
• Assist Advocate Aurora Health in its operations.
Your request for an accounting of disclosures must be made in writing. The list you receive will
include only the disclosures made for the time period indicated in your request, but may not exceed a
six-year period prior to the date of your request. The first list you request within a 12-month period
will be free. For additional lists, we may charge you for the reasonable costs associated with
providing the list. We will notify you of costs involved. You may choose to withdraw or modify
your request at any time before costs are incurred.
Right to Request Restrictions. You have the right to ask us to restrict or limit the Medical
Information we use or disclose about you for treatment, payment or healthcare operations. In
addition, if you pay for a particular service in full, out-of-pocket, on the date of service, you may ask
us not to disclose any related Medical Information to your health plan for payment or health care
operations purposes. Unless required by law, we are not required to agree to all requests. If we do
agree, we will comply unless the information is needed to provide emergency treatment. Requests
for a restriction must be made in writing and may be submitted to the medical record department at
the location where you receive health services, or at the point of care for requests for restrictions to
your health plan for services that were paid out-of-pocket.
Right to Request Confidential Communications. You have the right to ask us to communicate
with you about medical matters in a certain way or at a certain location. For example, you may
ask that we contact you only by sending materials to a P.O. Box instead of your home address.
We will not ask the reason for your request and we will accommodate all reasonable requests.
Your request should be made at the point of care at the location where you receive health services
and must specify how or where you wish to be contacted.
Right to a Paper Copy of this Notice. Upon your request, you may obtain a copy of this Notice,
either by email or in paper format. To do so, please submit your request to Privacy Officer,
Advocate Aurora Health, 3075 Highland Parkway, Suite 600, Downers Grove, Illinois 60515,
phone: 630-929-5922 or to Privacy Officer, Advocate Aurora Health, 750 W. Virginia Street,
Milwaukee, WI 53204, phone: 877-592-7996. You also may access a copy of this Notice on our web
site at www.AdvocateAuroraHealth.org.
EFFECTIVE DATE AND DURATION OF THIS NOTICE
This Notice is effective on April 1, 2018, unless and until it is revised by Advocate Aurora Health.
We reserve the right to change our privacy practices, policies and procedures and our Notice of
Privacy Practices at any time. We also reserve the right to make the revised privacy policies,
procedures and Notice effective for Medical Information we already have about you as well as any
information we receive in the future. We will post a copy of the current Notice in Advocate Aurora
Health facilities and on our Internet site. You may also obtain any new notice by contacting the
Privacy Officer. In addition, each time you register or are admitted to Advocate Aurora Health as an
inpatient or outpatient, a copy of the current Notice will be available.
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RIGHT TO FILE A COMPLAINT
If you would like more information about your privacy rights, if you are concerned that we
may have violated your privacy rights, or if you disagree with a decision that we made about
access to your Medical Information, you may contact our Privacy Officer. Also, you may
make a complaint by calling our Privacy Officer at 630-929-5922 for Advocate facilities or 877-
592-7996 for Aurora facilities. You may also file written complaints with the Director, Office
for Civil Rights of the U.S. Department of Health and Human Services. Upon request, the
Privacy Officer will provide you with the correct address for the Director. We will not
retaliate against you if you file a complaint with us or the Director.
PRIVACY OFFICER
You may contact the Chief Privacy Officer at:
Advocate facilities
Chief Privacy Officer
Advocate Health Care
3075 Highland Parkway, Suite 600
Downers Grove, Illinois 60515
Phone: 630-929-5922
Aurora facilities
Chief Privacy Officer
Aurora Health Care
750 W. Virginia Street
Milwaukee, WI 53204
Phone: 877-592-7996
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Notice of Nondiscrimination
Advocate Aurora Health complies with applicable Federal civil rights laws and does not discriminate on
the basis of race, color, national origin, age, disability, sex, sexual orientation, or gender identity. Advocate
Aurora Health does not exclude people or treat them differently because of race, color, national origin, age,
disability, sex, sexual orientation, or gender identity.
Advocate Aurora Health:
• Provides free aids and services to people with disabilities to communicate effectively with us, such as:
○ Qualified sign language interpreters
○ Written information in other formats (large print, audio, accessible electronic formats, other
formats)
• Provides free language services to people whose primary language is not English, such as:
○ Qualified interpreters
○ Information written in other languages
If you need these services at an Advocate Aurora Health location, notify a facility representative.
If you believe that Advocate Aurora Health has failed to provide these services or discriminated in another
way on the basis of race, color, national origin, age, disability, or sex, sexual orientation, or gender
identity, you can file a grievance with:
Advocate Health Care locations:
Contact a hospital operator and ask for Patient Relations
Aurora Health Care locations:
Civil Rights Coordinator
750 W. Virginia Street, Milwaukee, WI 53234
Phone: 1-888-568-6845
Email: [email protected]
You can file a grievance in person or by mail, or email. If you need help filing a grievance, a Patient
Relations Representative or the Civil Rights Coordinator is available to help you.
You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office
for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at
https://ocrportal.hhs.gov/ocr/portal/lobby.jsf , or by mail or phone at:
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Room 509F, HHH Building
Washington, D.C. 20201
1-800-368-1019, 800-537-7697 (TDD)
Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.html .
