NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS INFORMATION CAREFULLY.

Hamilton Health Care System, Inc. d/b/a Vitruvian Health and its Affiliates have developed this Notice of Privacy Practices to explain:

• How your medical information is used,
• Your rights as a patient, and
• Our duties as a health care provider to protect your medical information.

When we use the word “we” or “Vitruvian” we mean Hamilton Health Care System, Inc. d/b/a Vitruvian Health and its Affiliates, including but not limited to, Hamilton Medical Center, Hamilton Physician Group, Hamilton Ambulatory Surgery Center, Hamilton Orthopedic Surgery Center, Hamilton Long Term Care, Hamilton Home Health and Hospice, Hamilton Emergency Medical Services, Hamilton Children’s Institute, Hamilton Cardiovascular Institute, Bradley Medical Center, Bradley Physician Services, and Royal Oak Community.

This Notice applies to Vitruvian along with the health care professionals, staff, volunteers, and members of the Medical Staff providing services to you at a Vitruvian facility or clinic through an Organized Health Care arrangement with Vitruvian.  Your doctor and other health care providers may use a different Notice and policy regarding the use and disclosure of your medical information in their offices.

OUR LEGAL DUTY

We are required by law:

• To keep your medical information confidential in accordance with legal requirements,
• To give you this Notice of our legal duties and privacy practices with respect to your medical information, and
• To follow the terms of the Notice that is currently in effect.

USES AND DISCLOSURES OF YOUR MEDICAL INFORMATION

We use and disclose medical information in the ways described below.

Treatment. We may use your medical information to provide medical treatment or services to you. We may disclose medical information about you to doctors, nurses, technicians, medical, nursing or other health care students, or other personnel taking care of you. We may share your medical information to schedule the tests and procedures you need, such as prescriptions, laboratory tests and x-rays.

Payment. We may use and disclose your medical information to obtain payment for the services delivered to you, determine your eligibility for benefits, or coordinate your benefits with potential third party payers. For example, we may give your health plan information about surgery you received so your health plan will pay us for the surgery. We also may tell your health plan about a treatment you are going to receive in order to obtain prior approval from your plan to cover payment for the treatment.

Health Care Operations. We may use and disclose your medical information for health care operations, such as for peer review, performance improvement, risk management, business planning and administration, grievance resolution, legal services, and our compliance with licensure, accreditation or certification requirements. For example, we may disclose your medical information to physicians on our Medical Staff who review treatment of patients. We may disclose information to doctors, nurses, technicians, medical, nursing or other health care students, and Vitruvian personnel for teaching.

Activities of an Organized Health Care Arrangements in Which We Participate.  Vitruvian may participate in Organized Health Care Arrangements (“OHCA”) with other health care providers or health plans. OHCAs typically involve clinical integration, coordinated quality improvement, utilization review, or risk sharing between the participants.  We may use or disclose information about you to other participants in an OHCA as permitted by HIPAA and other applicable law.

Health Information Exchange

To facilitate uses and disclosures of protected health information as described in this notice, we may participate in a health information network or exchange that involves other health plans or health care providers. 

Business Associates

We may disclose your information to businesses that provide services to us.  We will obtain written agreement from those businesses that they will protect your information consistent with this Notice prior to disclosing your information.

Health Services, Treatment Alternatives and Health-Related Benefits.  We may use and disclose your medical information to tell you about (i) health-related products or services that we offer, (ii) other providers participating in a health care network that we participate in, (iii) possible treatment options or alternatives, or (iv) health-related benefits or services that may be of interest to you. We also may use that information to communicate with you to coordinate your care. We may use and disclose your medical information to contact and remind you of an appointment for treatment or medical care or refill reminders.

Fundraising. We may use your medical information to raise money for Vitruvian as permitted by HIPAA. We may disclose information, including but not limited to your name, address, telephone number, gender, age and the dates you received treatment at Vitruvian, to a Vitruvian related foundation or a Business Associate so it can contact you. You have the right to opt out of receiving fundraising communications.  If you do not want to be contacted for fundraising, please notify the Vitruvian Privacy Officer listed at the end of this Notice in writing.

Facility Directory. We may include certain information about you in the facility directory while you are a patient in a Vitruvian facility. This information may include your name, your room number, your general condition (fair, stable, etc.) and your religious affiliation. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they don’t ask for you by name. Disclosure of your room will not reveal that you are in a specific unit or area of the facility, if such information would reveal that you are at Vitruvian for treatment of rape or attempted rape, HIV/AIDS, mental health or alcohol/drug abuse. Directory information, except for your religious affiliation, may be released to people who ask for you by name. This is so your family, friends and clergy can visit you and generally know how you are doing. If you do not want this information given out, please tell the Admissions Clerk.

Personal Representatives.  We may use or disclose health information to persons who are authorized by law to make health care decisions for you.  Personal representatives will be authorized to exercise rights under this Notice on your behalf.  We may choose not to treat a person as your personal representative if we have a reasonable belief of abuse, neglect or endangerment.

Individuals Involved in Your Care or Payment for Your Care. We share medical information with family or other individuals who are involved in your care, or payment for your care, to the extent of that involvement . If you are incapacitated or in an emergency, we may use our professional judgment to decide whether a disclosure to someone involved in your health care is in your best interests.  In addition, we may disclose your medical information to an entity assisting in disaster relief efforts so that your family can be notified about your condition.

Other Disclosures Authorized by Law.  We may use or disclose your information, without your permission, when required by state or federal law or where authorized by law for the following types of activities:

• Research. We may use and disclose your medical information for research purposes.

• Abuse Reporting.  We may use and disclose your information consistent with applicable laws for reporting abuse, neglect, or domestic violence.

• Avert Serious Threat to Health or Safety. We may use and disclose your medical information when necessary to prevent or lessen a serious and imminent threat to your health and safety or the health and safety of the public or another person.

• Organ and Tissue Donation. If you are an organ donor, we may release your medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to aid in its organ or tissue donation and transplantation process.

• Military and Veterans. If you are a member of the U.S. or foreign armed forces, we may release your medical information as deemed necessary by military command authorities.

• Workers’ Compensation. We may release medical information about you for workers’ compensation or similar programs as authorized by state law. These programs provide benefits for work-related injuries or illness.

• Public Health Activities We may disclose your medical information for public health purposes including to prevent or control disease, injury or disability, to report births and deaths, to report child or adult abuse, neglect or violence, to report reactions to medications or problems with products, to notify people of recalls of products they may be using, to notify a person who may have been exposed to a disease or may be at risk for getting or spreading a disease or condition, to employers, as permitted by HIPAA’s public health provisions, regarding a workplace injury or illness, or to a school, in order to provide proof of a student’s or prospective student’s immunization, with agreement from the student’s parent or legal guardian.

• Health Oversight Activities. We may disclose your medical information to a federal or state agency for health oversight activities such as audits, investigations, inspections, and licensure of Vitruvian health care facilities and of the providers who treated you there. These activities are necessary for the government to monitor the health care system, government programs, and compliance with laws.

• Lawsuits and Administrative Disputes. We may disclose your medical information to respond to a court or administrative order or a search warrant. We also may disclose your medical information in response to a subpoena, discovery request, or other lawful process by someone else involved in a dispute, but only if efforts have been made to tell you about the request and you have been provided an opportunity to object or to obtain an appropriate court order protecting the information requested.

• Law Enforcement. Subject to certain conditions, we may disclose your medical information for a law enforcement purpose upon the request of a law enforcement official. The specific conditions which apply depend on the law enforcement purpose involved, such as (a) identifying a suspect, fugitive, witness or missing person; (b) locating a suspected victim; (c) reporting a suspicious death; (d) reporting a crime on the premises; and (e) emergency reporting of a crime.

• Coroners, Medical Examiners and Funeral Directors. We may disclose your medical information to a coroner, medical examiner or funeral director so they may carry out their duties.

• Decedents.  We may use or disclose a deceased patient’s information as authorized by federal and state law, including based on the signed authorization of the estate’s personal representative (executor or court appointed administrator).

• National Security. We may disclose your medical information to authorized federal officials for national security activities authorized by law.

• Protective Services. We may disclose your medical information to authorized federal officials so they may provide protection to the President and other persons or conduct related federal investigations.

• Inmates.  If you are an inmate of a correctional institution or under the custody of a law enforcement officer, we may release your medical information to the correctional institution or a law enforcement officer. This release would be necessary for Vitruvian to provide you with health care, to protect your health and safety or the health and safety of others, or for the health and safety of the law enforcement officer or the correctional institution.

Written Authorization.  You may give us written authorization to use your information or to disclose it to anyone for any purpose. The following types of uses and disclosures of information will be made only with your written permission, unless required by law:

• Psychotherapy Notes.  Psychotherapy notes are notes that your mental health professional maintains separate and apart from your medical record. These notes require your written authorization for disclosure unless the disclosure is required or permitted by law, the disclosure is to defend the mental health professional in a lawsuit brought by you, or the disclosure is used to treat you or to train students.

• Marketing.  We must get your permission to use your information for marketing unless we are having a face-to-face talk about the new health care product or service, or unless we are giving you a gift that does not cost much to tell you about the new health care product or service. We must also tell you if we are getting paid by someone else to tell you about a new health care item or service.

• Sale of PHI. We are not allowed to sell your information without your permission and we must tell you if we are getting paid. However, certain activities are not viewed as selling your information and do not require your consent. For example, we can sell our business, we can pay our contractors and subcontractors who work for us, we can participate in research studies, or we can get paid for treating you.

Note: State and Federal Law provide protection for certain types of health information, including information about alcohol or drug abuse, mental health, genetics and AIDS/HIV, and may limit how and whether we may disclose information about you to others.  Where a State or Federal law requires authorization, an authorization will be requested from you.

If you provide us with authorization to use or disclose 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 information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the services that we provided to you.

Substance Use and Treatment Information.  Records created by a program that provides diagnosis, treatment or referral for treatment related to substance use disorders are subject to additional protections under 42 C.F.R. Part 2 (“Part 2”).  Some departments and practitioners at Vitruvian are considered Part 2 programs and Vitruvian may receive records subject to Part 2 from Part 2 Programs. We will only disclose records subject to Part 2 as permitted by your written authorization.  We may obtain written authorization from you to allow the disclosure, including re-disclosure, of Part 2 records for treatment, payment and health care operations purposes as described in this Notice.  Records subject to 42 C.F.R. Part 2 will not be used or disclosed in civil, criminal, administrative, or legislative proceedings against you unless based on written authorization or a court order after notice and opportunity to be heard.

YOUR PRIVACY RIGHTS

Right to Review and Right to Request a Copy. You have the right to review and obtain a copy of medical information in your medical and billing records. You may make this request in writing to our Medical Records Department.  We are permitted to charge a reasonable, cost-based fee for your records. Vitruvian will tell you if it cannot fulfill your request. If you are denied the right to see or copy your medical information, you may ask us to reconsider the decision. Depending on the reason for the decision, we may ask a licensed health care professional to review your request and its denial. We will comply with this person’s decision.

Right to Amend. If you feel your medical information in our records is incorrect or incomplete, you may ask us in writing to amend the information. You must provide a reason to support your requested amendment. We may deny your request only for certain reasons. If we deny your request, we will provide you a written explanation. If we accept your request, we will make your amendment part of your medical information and use reasonable efforts to inform others of the amendment who we know may have and rely on the unamended information to your detriment, as well as persons you want to receive the amendment. The Contact Person listed below can help you with your request.

Right to an Accounting of Disclosures. You have the right to make a written request for a list of certain disclosures Vitruvian has made of your medical information. This list is not required to include all disclosures we make. Certain disclosures for treatment, payment, or health care operations/administrative purposes, disclosures made more than six years prior to the request, disclosures made to you or which you authorized, and other disclosures are not required to be listed. If you request this accounting more than once in a 12-month period, we may charge you a reasonable, cost-based fee for responding to your additional requests. The Contact Person listed below can help you with this process.

Right to Request Restrictions on Disclosures. You have the right to make a written request to restrict or put a limitation on the medical information we use or disclose about you for treatment, payment or health care operations.   We are not required to agree to your request, except for limited circumstances where you wish to pay for medical services out-of-pocket in full at the time of service and have requested that we not disclose information to your health plan. If we agree, we will comply with your request unless the information is needed to provide you with emergency treatment or to make a disclosure that is required under law. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your adult children.

Right to Request Confidential Communications. You have the right to make a written request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we contact you only at work or by mail. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.  The Contact Person listed at the end of this Notice can help you with these requests if needed.

Right to a Paper Copy of This Notice. You have the right to receive a paper copy of this Notice at any time even if you have agreed to receive this Notice electronically. You may obtain a copy of this Notice at our website, www.Vitruvianhealth.com or a paper copy from the Admissions Office.

Right to Receive Notice of Breach of Unsecured PHI.  Affected individuals have the right to receive written notice following a breach of their unsecured protected health information.

Right to Decline Participation in Health Information Exchange: We may choose to share information electronically with other health care providers or health plans through private, regional or state health information exchanges. You may choose not to allow your information to be shared through health information exchanges by contacting the Privacy Officer to opt out of the exchange. This means that it may take longer for your health care providers to get information they may need to treat you. However, even if you do not want to participate in a health information exchange, certain state law reporting requirements, such as an immunization registry, will still be fulfilled through health information exchange, and some states still allow health care providers to access your information through a health information exchange if needed to treat you in an emergency. If you have any questions regarding our participation in exchanges or how to opt out, please contact the Privacy Officer.

CHANGES TO THIS NOTICE

We reserve the right to change this Notice and to make the revised or changed Notice effective for medical information we already have about you as well as for any information we receive in the future. We will post the current Notice at Vitruvian health care delivery sites and at our website at www.vitruvianhealth.com.  The effective date of this notice is July 1, 2025.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a written complaint with Vitruvian or with the Secretary of the Department of Health and Human Services (HHS). Generally, a complaint must be filed with HHS within 180 days after the act or omission occurred. To file a complaint with Vitruvian, inform the Health Information Management Department or the Vitruvian Privacy Officer listed below. You will not be denied care or be discriminated against by Vitruvian for filing a complaint.

Contact Persons

If you have any questions about this Notice, please contact:

Hamilton Health Care System
[email protected]
706-278-1910

Hamilton Medical Center Privacy Officer
706-272-6625
1200 Memorial Drive
Dalton, GA 30720

*for Hamilton Medical Center, Hamilton Physician Group, Hamilton Ambulatory Surgery Center, Hamilton Orthopedic Surgery Center, Hamilton Emergency Medical Services, Hamilton Long Term Care, Royal Oak Community, and Hamilton Children’s Institute.

Bradley Medical Center Privacy Officer
423-559-6000
2305 Chambliss Avenue
Cleveland, TN 37311
*for Bradley Medical Center and Bradley Physician Group.