GREENBRIAR TREATMENT CENTER                                        NOTICE OF PRIVACY PRACTICES Effective: April 14, 2003

Update: January 2012

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.

PER THE HIPAA (Health Insurance Portability & Accounting Act) OF 1996, WE HAVE A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION. We will protect the privacy of the health information that we maintain that identifies you, whether it deals with the provision or payment of your health care. We must provide you with this notice about our privacy practices. It explains how, when and why we may use and disclose your health information. With some exceptions, we will avoid using or disclosing any more of your health information that is necessary to accomplish the purpose of the use of disclosure. We are legally required to follow the privacy practices that are described in this Notice, which is currently in effect. We reserve the right to change the terms of this Notice and our privacy practices at any time. Any changes will apply to any of your health information that we already have. Before we make an important change to our policies, we will promptly change this Notice and post a new Notice in our reception and service areas. You may also request, at any time, a copy of our Notice of Privacy Practices that is in effect at any given time, from our Compliance Officer. You may view and obtain an electronic copy of this Notice on our web site when available. We would like to take this opportunity to answer some common questions concerning our privacy practices:

QUESTION: HOW WILL THIS ORGANIZATION USE AND DISCLOSE MY PROTECTED HEALTH INFORMATION?

Answer: We use and disclose health information for many different reasons. For some of these uses or disclosures, we need your specific authorization. Below, we describe the different categories of our uses and disclosures and give you some examples of each.

Uses and Disclosures Relating to Treatment, Payment, or Healthcare Operations.

We may, by federal law, use and disclose your health information for the following reasons:

Treatment: With the possible exception of information concerning drug/alcohol and/or treatment, and HIV status (for which we may need your specific authorization), we may disclose your health information to other health care providers who are involved in your care. For example, we may disclose your medical history to a hospital if you need medical attention while at our facility or to a residential care program to which we are referring you. Reasons for such a disclosure may be to get them the medical history information they need to appropriately treat your condition, to coordinate your care, or to schedule necessary testing.

Payment: With the possible exception of information concerning drug /alcohol abuse and/or treatment, and HIV status (for which we may need your specific authorization), we may use and disclose necessary health information in order to bill and collect payment for the treatment that we have provided to you. For example, we may provide certain portions of your health information to your health insurance company, Medicare or Medicaid, managed care entity, county funded service coordination unit or the County (Drug & Alcohol Commission, MH/MR, Behavioral Health/Human Services) in order to get paid for taking care of you.

Health Care Operations: We may, at times, need to use and disclose your health information to run our organization. For example, we may use your health information to evaluate the quality of the treatment that our staff has provided to you. We may also need to provide some of your health information to our accountants, attorneys, and consultants in order to make sure that we’re complying with law. Because this information concerns drug and alcohol abuse and/or treatment, mental health disorders and/or treatment and/or HIV status, we may be further limited in what we provide and may be required to first obtain your authorization.

Other Uses and Disclosures Permitted by Federal Law. We may use and disclose your health information without your authorization for the following reasons:

When a Disclosure is required by Federal, State, or Local Law, in Judicial or Administrative Proceedings, or by Law Enforcement. For example, we may disclose your protected health information if we are ordered by a court, or if a law requires that we report that sort of information to a government agency or law enforcement authorities, such as suspected child abuse.

Public Health Activities. Under the law, we must report info. about certain diseases & about any deaths to government agencies that collect that information. With the exception of information concerning HIV (for which we may need your specific authorization), we are also permitted to provide some health information to the coroner or a funeral director, if necessary, after a client’s death.

Health Oversight Activities. We may need to provide your health information to the County /State when they oversee this program. We will also need to provide information to government agencies that have the right to inspect our offices and/ or investigate healthcare practices.

Organ Donation. If one of our clients wishes to make an eye, organ, or tissue donation after their death, we may disclose certain necessary health information to assist the appropriate organ procurement organization.

Research. In certain limited circumstances (for example, where approved by an appropriate Privacy Board or Institutional Review board under federal law), we may be permitted to use or provide protected health information for a research study.

Avoid Harm or Report Abuse. If one of our staff members believes in good faith that it is necessary to protect you, or to protect another person or the public as a whole, we may provide protected health information to the police or others who may be able to prevent or lessen the possible harm.

Specific Government Functions. Similarly, with the possible exception of information concerning drug and alcohol abuse and/or treatment, and HIV status (for which we may need your specific authorization), we, may also disclose the health information of military personnel or veterans where required by U.S. military authorities.

Workers’ Compensation. We may provide your health information as described under the workers’ compensation law, if your condition was the result of a workplace injury for which you are seeking compensation.

Certain Uses and Disclosures Require You to Have the Opportunity to Object.

Disclosures to Family, Friends, or Others Involved in your Care. With your signed Consent to Release Information, we may provide a limited amount of your health information to a family member, friend, or other person known to be involved in your care or in the payment for your care. The private health information released is limited to that allowed by 4 PA Code Section 255.5 (posted throughout the building).

Disclosures to Notify a Family Member, Friend, or Other Selected Person. When you first started our program, we asked that you provide us with an emergency contact person in case something should happen to you while you are at our facilities. Unless you tell us otherwise, and only with a signed Consent, we will disclose limited health information about you to your emergency contact or another available family member.

Appointment Reminders and Health-Related Benefits or Services. Unless you tell us that you would prefer not to receive them, we may use or disclose your information to provide you with appointment reminders or alternative programs /treatments that may help you.

Other Uses and Disclosures Require Your Prior Written Authorization. In situations other than those categories of uses and disclosures mentioned above, or those disclosures permitted under federal law, we will ask for your written authorization before using or disclosing any of your protected health information. If you choose to sign an authorization to disclose any of your health information, you can later revoke it to stop further uses and disclosures to the extent that we haven’t already taken action relying on the authorization, so long as it is revoked to the nursing or medical records departments.

QUESTION: WHAT RIGHTS DO I HAVE CONCERNING MY PROTECTED HEALTH INFORMATION?

Answer: You have the following rights with respect to your protected health information:

Right to Request Limits on Uses and Disclosures of Your Health Information: You have the right to ask us to limit how we use and disclose your health information. We will certainly consider your request, but you should know that we are not required to agree to it. If we do agree to your request, we will put the limits in writing and will abide by them, except in the case of an emergency. Please note that you are not permitted to limit the uses and disclosure that we are required or allowed by law to make.

Right to Choose How We Send Health Information to You or How We Contact You. You have the right to ask that we contact you at an alternate address or telephone number (for example, sending information to your work address instead of your home address) or by alternate means. We must agree to your request so long as we can easily do so.

Right to See or to Get a Copy of Your Protected Health Information. In most cases, you have the right to look at or get a copy of health information that we have, but you must make the request in writing. A request form is available at the nurses’ station or medical records department and must be submitted to the Project Director, Director of Nursing or your therapist. If you are inpatient, we will respond to your request within a reasonable period, otherwise we will respond to you within 30 days after receiving your written request. If we do not have the health information that you are requesting but we know who does, we will tell you how to get it. In certain situations, we may deny your request. If we do, we will tell you, in writing, our reasons for the denial. In certain circumstances, you may have a right to appeal the decision. If you request a copy of any portion of your protected health information, we will charge you for the copy on a per page basis, only as allowed under applicable federal and Pennsylvania state law. We need to require that payment be made in full before we will provide the copy to you. If you agree in advance, we may be able to provide you with a summary or an explanation of your records instead. To the extent permitted by applicable federal and Pennsylvania state law, there will be a charge for the preparation of the summary or explanation, including charge for staff time to develop the summary.

Right to Receive a List of Certain Disclosures of Your Health Information that we have made. You have the right to get a list of certain types of disclosures that we have made of your health information. This list would not include uses or disclosures for treatment, payment or healthcare operations, disclosures to you or with your written authorization, or disclosures to your family for notification purposes or due to their involvement in your care. This list also would not include any disclosures made for national security purposes, disclosures to corrections or law enforcement authorities if you were in custody at the time, or disclosures made prior to April 14, 2003. You may not request an accounting for more than a six (6) year period. To make such a request, we require that you do so in writing; a request form is available upon asking at your location of service. We will respond to you within 60 days of receiving your request. The list that you may receive will include the date of the disclosure, the person or organization that received the information (with their address, if available), a brief description of the information disclosed, and a brief reason for the disclosure. We will provide such a list to you at no charge; but, if you make more than one request in the same 12-month period, you will be charged for each additional request within that 12-month period.

Right to Ask to Correct or Update Your Health Information. If you believe that there is a mistake in your health information (incorrect, irrelevant or outdated) or that a piece of important information is missing, you have a right to ask that we make an appropriate change to your information. You must make the request in writing, with the reason for your request, on a form called an Amendment Form that is available from nursing or medical records departments and submitted to the Privacy Officer or your therapist. We will respond within 60 days of receiving your request. If we approve your request, we will make the change to your health information, tell you when we have done so, and will tell others that need to know about the change. We may deny your request if your protected health information: (1) is accurate and complete; (2) was not created by us; (3) is not allowed to be disclosed to you; or (4) is not part of our records. Our written denial will state the reasons that your request was denied and explain your right to file a written statement of disagreement with the denial. If you do not wish to do so, you may ask that we include a copy of your request form, and our denial form, with all future disclosures of that health information.

QUESTION: WHAT RIGHTS DO I HAVE CONCERNING MY TREATMENT?

Answer: For a complete listing of patient’s rights, please read “Patient’s Legal and Human Rights” provided in your admission packet.

QUESTION: HOW DO I COMPLAIN OR ASK QUESTIONS ABOUT THIS ORGANIZATION’S PRIVACY PRACTICES?

ANSWER: If you have questions about anything discussed in this Notice or about any of our privacy practices, or if you have any concerns or complaints, please contact the Privacy Officer at 724-225-9700. You also have the right to file a written complaint with the Secretary of the U.S. Department of Health and Human Services. We cannot take any retaliatory action against you if you lodge any type of complaint.


GREENBRIAR TREATMENT CENTER                                       PATIENT’S LEGAL AND HUMAN RIGHTS


The plan for patient’s rights ensures that Greenbriar Treatment Center supports and protects the fundamental human, civil, constitutional and statutory rights of each patient. The following policies and procedures shall describe the rights of patients and methods in which these rights are protected.

POLICY: Admission, the provision of services and referrals of clients shall be made without regard to race, color, religious creed, disability, ancestry, national origin (including limited English proficiency) age, or sex

PURPOSE: Greenbriar shall establish and maintain an environment that enhances the positive self-image of the patient and preserves human dignity.

PATIENT’S LEGAL AND HUMAN RIGHTS:

1. Program services shall be made accessible to eligible persons with disabilities through the most practical and economically feasible methods available. These methods include, but are not limited to; equipment redesign, the provision of aides, and the use of alternative service delivery locations. Structural modifications shall be considered only as a last resort among available methods. Any individual/client/patient/student and/or their guardian who believes they have been discriminated against may file a complaint of discrimination with:

Clinical Director or Nursing Director Greenbriar Treatment Center 800 Manor Dr Washington PA 15301

The Joint Commission of Hosp Accreditation One Renaissance Blvd. Oakbrook Terrace IL 60181

Dept of Public Welfare Bureau of Equal Opportunity Western Region 301 Fifth Ave, Ste 410 Piat PlacePittsburgh Pa 15222

Bureau of Equal Opportunity, DPW Room 223 Health & Welfare Bldg P.O. Box 2675 Harrisburg PA 17105

Washington Co D&A Commission 90 W. Chestnut St Suite 310 Washington Pa 15301

Quality Assurance Coordinator /bureau of Drug & Alcohol Programs Human Services BldgOne Smithfield St. Pgh PA 15222

PA Human Relations Commission 301 Fifth Avenue Ste 390 Piatt Place Pgh Pa 15222

Office of Civil Rights Dept of Health & Human Svc Office or Civil Rights Region III Suite 372 Public Ledger Bldg150 S. Independence Mall WestPhiladelphia PA 19106-9111

2. You have the right to be treated in an environment free of sexual harassment from staff and/or other patients in the facility. If you feel you are being sexually harassed, either physically or verbally, an investigation will be conducted into the allegations.

3. You have the right of access to the building, treatment rooms and bathrooms. Reasonable accommodations will be made to ensure your accessibility to these areas if you have a physical disability.

4. You have the right to privacy in your treatment, in your care, and in the fulfillment of your personal needs.

5. You have the right to be fully informed of all services available to you and of any charges for those services at Greenbriar Treatment Center.

6. You have the right to be fully informed of your rights as a patient and of all rules and regulations governing your conduct as a patient

7. You have the right to manage your personal financial affairs. If you desire assistance, staff can arrange appropriate assistance for you.

8. You have the right to know about your physical condition.

9 . You have the right to participate in the development of your treatment plan.

10. You have the right to receive information necessary to give informed consent prior to the start of any procedure and/or treatment.

11. You have the right to refuse treatment and/or medication to the extent permitted by law and to be informed of the consequences of this right. Should such refusal be a prescribed treatment and/or safety issue, Greenbriar Treatment Center reserves the right to facilitate discharge or transfer to another facility.

12. You have the right to continuity of care. You will not be discharged or transferred except for medical reasons, for your personal welfare, or for the welfare of others. Should your transfer or discharge become necessary, you will be given reasonable advance notice unless an emergency situation exists.

13. You have the right to voice opinions, recommendations and grievances in relation to policies and services offered by the facility, without fear of restraint, interference, coercion, discrimination or reprisal.

14. You have the right to be free of physical, chemical and/or mental abuse.

15. You have the right to refuse to perform any service for the facility, or for other patients, unless it is a part of your therapeutic plan of treatment which you have approved.

16. You have the right to retain and use your personal clothing and belongings, as space permits, unless to do so would infringe upon the rights and safety of others or to be contrary to our written plan of treatment. All clothing must conform to the dress code.

17. You have the right of choice of persons with whom you associate and communicate, publicly and privately, unless the treatment staff feels some or all such associations are detrimental to your welfare. Under certain clinical situations, your associations may be restricted. You will be informed of any such restrictions, and given an explanation for this restriction.

18. You have the right to have visitors with your consent, regardless of age, at designated visiting times, unless contraindicated and documented. If visitor restrictions are necessary, you will be informed of any such restrictions with an explanation why.

19. You have the right to send uncensored mail. Staff reserves the right to have incoming mail and packages opened in staff presence. Staff reserves the right to confiscate alcohol, drugs or other items that are detrimental to your recovery or the recovery of others.

20. You have the right to speak privately by telephone as designated by the rules.

21. You have the right to be informed in advance of any visitors to Greenbriar and the right to privacy if you do not wish to see visitors or participate in activities while visitors are present in the facility. If, during the above times, the patient requests privacy, the request shall be granted within the facility’s limits.

22. You have a right to request pastoral visitation within the time frames permitted by the treatment schedule

23. Every patient has the right to air a grievance and expect timely resolutions when he or she feels that any of the following criteria are met by staff:

  • Physical or verbal abuse; Ignoring the client’s communication; Sexual and/or seductive behavior; Ignoring appointments; Failure to follow doctor’s prescribed orders; Failure to follow prescribed treatment plans; Failure to follow through on routine procedures on information gathering, treatment planning, and referral services; Infringement on the patient’s legal, human or civil rights; Unauthorized release of information about the patient; Denial or termination of services; Level of Care determination; Length of stay in treatment or case coordination
  • 24. You have a right to inspect your own record. The Project Director may temporarily remove portions of the records prior to inspection if they

determine that the information may be detrimental. Reasons will be kept on file. You have a right to submit rebuttal information to your record.

PROCEDURE:

1. Patient’s Legal & Human Rights shall be prominently posted on the unit.

2. All patients shall be made aware of their rights and they shall be fully explained during orientation.

3. Each patient shall receive a copy of their rights given to them during the admission process.

4. Whenever any rights are denied, it is necessary for the Greenbriar Treatment Center staff to document which rights were denied and the reasons for denial. The patient must be notified which rights have been denied and the same documented. Also, the patient must be informed at what time the rights will be restored. This must also be documented by the Greenbriar Treatment Center Staff.

5. You have a right to obtain an outside advocate in the event you believe any of the above rights are being denied.

6. Should a patient feel that he, she, or any family / friends visiting have a reason to file a grievance based on the above criteria, the following will apply:

  • The patient will report the incident or grievance to their therapist; in the absence of the therapist, the patient will report this grievance directly to the Clinical Director
  • The therapist is responsible for reporting the incident to the Clinical Director and any other appropriate or involved staff.
  • The appropriate expiration and disposition of the incident will be made by the Clinical Director, Director or Nursing or Chief Operating Officer
  • A meeting will be held with the patient and the Clinical Director, Director of Nursing or Chief Operating Officer within 2 working days of the reported incident. At that time, the patient will be informed of the disposition of the situation.
  • In the event the patient is dissatisfied with the disposition, he or she may request in writing a meeting with the CEO or designee for the purpose of appealing the decision or clarifying the issue. The final decision for the disposition rests with the CEO.

WASHINGTON COUNTY RESIDENTS MAY:

  • Discuss any grievance (complaint) with the Case Manager responsible for your case and attempt to get the problem resolved. This should occur within 15 working days.
  • If you and the Case Manager do not agree on a satisfactory resolution, the Case Management Supervisor or a supervisor not related to the situation will attempt to resolve the problem to the mutual satisfaction of you and your case manager. This should occur within 15 working days.
  • In the event the problem is not settled in the first or second step, write down the problem including your name, your incident if something happened that you want to appeal, a description of the incident and the location of the incident. Send it to our Executive Director, who is not directly involved in the dispute, at Washington Drug and Alcohol Commission, Inc. 90 W. Chestnut St, Washington PA 15301. An attempt will be made to resolve the problem to the mutual satisfaction of you and your chosen advocate. The client and Bureau of Drug and Alcohol Programs will be notified of the decision with 7 days upon receipt of the grievance via the BDAP approved form.
  • Any grievance that remains unresolved will be submitted to an independent review panel made up of three members of the Westmoreland Drug and Alcohol Commission, the Executive Director, Deputy Director and the Case Management Supervisor. None of these members have any financial, occupational or contractual relationship with the SCA. This review panel will make a final decision in writing and mail it to you and to the Bureau of Drug and Alcohol Programs within 7 days upon the receipt of the grievance via the BDAP approved form. Copies of the decision will be provided to the Executive Director, Case Management Supervisor and your Case Manager at Washington Drug and Alcohol Commission for the case file. Address your second level appeal to: Westmoreland Drug and Alcohol Commission. Mon Valley Community Health Center. Eastgate 8 Monessen, PA 15062
  • You have the right to access all documentation pertaining to the resolution of the grievance within the confines of state and federal confidentiality regulations
  • You have the right to be involved in the process and have representation by means of a client advocate, case manager, or any other individual chosen by you at each level of appeal
  • You will need to sign a consent form so that confidential information relating to the appeal can be provided to an independent review board for the purpose of rendering a decision on the appeal

(rev 9/2013)


GREENBRIAR TREATMENT CENTER POLICY

111 PATIENT CARE

ADMISSIONS

PRIORITY POPULATIONS

Effective Date: 4/1/2004

Revision Date: 8/2/2015

POLICY

Greenbriar Treatment Center prioritizes the treatment of certain patients, in accordance with the Pennsylvania Department of Drug and Alcohol Programs Treatment Manual. Pregnant injection drug users, pregnant substance abusers, injecting drug users, overdose survivors and veterans are priority populations. Substance abusers with co-occurring mental health disorders are also a priority, and then all others. Greenbriar assures appropriate referrals, ancillary services, and if necessary, interim services for these populations.