Patient Information Policy
Patient’s Right to Request to Receive Confidential
Communications by Alternative Means or at Alternative
Locations
SCOPE:
All Louisiana State University (LSU) System health care
facilities and providers including, but not limited to
hospitals, physician practices, clinics, schools, etc. on
the LSU Health Sciences Center New Orleans Academic Campus.
Nota Bene: All LSU System health care facilities and
providers including, but not limited to hospitals, physician
clinics, schools, etc. on the LSU Health Sciences Center New
Orleans Academic Campus, are referred to in this policy as
LSUHSC-NO.
PURPOSE:
To provide guidance to the health care facilities and
providers affiliated with LSUHSC-NO on a patient’s right to
request to receive confidential communications by
alternative means or at alternative locations of their
Protected Health Information, as required by the Health
Insurance Portability and Accountability Act, Standards for
Privacy of Individually Identifiable Health Information (HIPAA
Privacy Regulations), and any other applicable state or
federal laws or regulations.
POLICY:
All LSUHSC-NO health care facilities and providers must
provide patients with a right to request and must
accommodate reasonable requests by individuals to receive
confidential communications by alternative means or at
alternative locations of their Protected Health Information.
DEFINITIONS:
Protected Health Information (sometime referred to as “PHI”)
– for purposes of this policy means individually
identifiable health information, that relates to the past,
present, or future health care services provided to an
individual. Examples of Protected Health Information include
medical and billing records of a patient.
Privacy Officer – Person designated by LSUHSC-NO as the
Privacy Officer.
PROCEDURE:
| 1.0 |
A patient may make a request in writing to
LSUHSC-NO to receive communications of their
Protected Health Information by alternative means
or at alternative locations. A patient should be asked to complete
Attachment A when making such request. |
| 1.1 |
The patient cannot be required to provide an
explanation for their request. |
| 2.0 |
The request should be given to the Privacy
Officer who will be responsible for receiving
requests for confidential communications, and
communicate it to the appropriate employees. |
| 3.0 |
LSUHSC-NO is only required to handle requests
that are reasonable. The reasonableness of a
request must be determined by LSUHSC-NO solely on
the basis of the administrative difficulty of
complying with the request. |
| 3.1 |
LSUHSC-NO may condition the provision of reasonable accommodation:
- when appropriate, information as to how payment, if any, will be handled and
- specification of an alternative address or other method of contact.
|
| 4.0 |
Examples of the types of communications
subject to this policy include but are not limited
to:
- A request by the patient that LSUHSC-NO
communicate with the individual about the their
treatment at the individual’s place of
employment, by mail, or a designated phone
number;
- Mailing or telephoning of appointment
reminders to a particular location
- Sending prescription refill reminders to a
particular address
- Mailing bills or statements to a particular
address
- Request to send communications in a closed
envelope rather than a postcard.
|
| 5.0 |
Requests for confidential communication must
include the patient’s designation of the means and
location of alternative delivery of the PHI. For
example, these requests may include, but not be
limited to:
- Communication by telephone to an alternative
phone number;
- Mail to an address other than the address of
record;
- A request for only telephone communication;
- Sealed envelope delivery rather than a
postcard; or
- Mail to an alternate address.
|
| 6.0 |
The patient must be informed:
- If LSUHSC-NO is not able to meet the request
for confidential communications;
- The patient’s request for confidential
communication should be documented in the
patient’s medical and billing records and the
original copy of the request form will be
attached in the patient’s medical record.
|
REFERENCE:
45 C.F.R. § 164.522(b) (1) |
