Introduction
Cambridge Dental Group (referred to as “We”, “CDG”, or “Company” in this document) is dedicated to maintaining the privacy of your protected health information (PHI). “PHI” is information that may identify you and relates to your past, present, or future health and condition.
We are required by law to maintain the confidentiality of health information that identifies you. We are also required by law to provide you with this Notice concerning your PHI.
This Notice describes how we may use and disclose your protected health information to carry out treatment, payment, health care operations, and other purposes that are permitted or required by law. It also describes your rights to access and control your protected health information. Signing the form does not mean that the patient has agreed to any special uses or disclosures of their PHI. If a patient refuses to sign the form, the provider must document this fact, but they can still use and disclose the patient's PHI as permitted by HIPAA.
Please review this document carefully. There are four main sections:
- How CDG will use/disclose your PHI where your authorization is not required. For example, sending you appointment reminders.
- How CDG might use/disclose your PHI where your authorization is not required. For example, for legal purposes or as required by the government.
- How CDG could use/disclose your PHI, but your authorization is required to do so. For example, CDG does not sell or market your PHI, but if we did, we would need your written authorization.
- Your Privacy Rights - which outlines your rights to access and amend your PHI.
Notice of Privacy Practices
The terms of this Notice apply to all records containing your PHI that are created or retained by, or on behalf of, CDG. We reserve the right to amend our Notice. Any revision or amendment to this Notice will be effective for all of your records that CDG has created or maintained in the past, and for any of your records we may create or maintain in the future. Our organization will post a copy of our current notice on our web site
www.cambridgedental.net, and you may request a copy of our most current notice.
Cambridge Dental Group will use and disclose your PHI without first obtaining your written authorization only as described in this Notice. If CDG obtains your written authorization for a use or disclosure not described in this Notice, you may revoke or modify that authorization at any time by submitting the appropriate form to the Privacy & Security Officer (the “Privacy Official”). The Privacy Official will provide you with a copy of the form upon request.
How CDG Will Use Or Disclose Your PHI Without Your Authorization
- For Treatment - We will use your PHI within our office to provide you with medical care. This may include administrative and clinical office procedures designed to optimize scheduling and coordination of care between health care providers and business office staff. In addition, we may share your health information with other health care personnel providing your treatment.
- For Payment - Includes, but is not limited to, billing, obtaining payment under a contract of insurance, and related health care data processing. For example, we may use your PHI to prepare a bill to obtain payment from you or your insurance company for services we rendered.
- For Communications - Includes, but is not limited to contacting you regarding your appointments, billing, insurance, and treatment information that pertains to you or your family. Our communication methods primarily include phone calls, texts, email, and letters. You may opt out of text and email reminders at any time.
- For Health Care Operations - Includes, but is not limited to, quality assessment and improvement activities, case management and care coordination, evaluating the performance of practitioners, health care training, compliance programs, investigating and resolving complaints of privacy violations, business planning and development, business management, and general administrative activities. CDG may also disclose PHI as part of an investigation into a fraudulent claim.
- To Business Associates - We may have contracted with third parties (referred to as a business associate) to use and disclose your PHI to perform services for CDG. We will obtain each business associate's written agreement to safeguard the privacy of your PHI.
How CDG Might Use Or Disclose Your PHI Without Your Authorization
Federal law generally permits us to make certain uses or disclosures of health information without your permission. Federal law also requires us to list in the Notice each of these categories of uses or disclosures. The listing is below.
- Uses Or Disclosures Required By Law. We may use or disclose your PHI as required by any statute, regulation, court order or other mandate enforceable in a court of law.
- Disclosures For Workers’ Compensation. We may disclose your PHI as required or permitted by state or federal workers’ compensation laws.
- Disclosures To Family Members Or Close Friends. We may disclose your PHI to a family member or close friend who is involved in your care or payment for your care if (a) you are present and agree to the disclosure, or (b) you are not present or you are not capable of agreeing, and CDG determines that it is in your best interest to disclose the information.
- Disclosures For Judicial And Administrative Proceedings. We may disclose your PHI in an administrative or judicial proceeding in response to a subpoena or a request to produce documents. We will disclose your PHI in these circumstances only if the requesting party first provides written documentation that the privacy of your PHI will be protected.
- Disclosures For Law Enforcement Purposes. We may disclose your PHI for law enforcement purposes to a law enforcement official, such as in response to a grand jury subpoena.
- Incidental Disclosures. We may use or disclose your PHI in a manner which is incidental to the uses and disclosures described in this Notice.
- Disclosures For Public Health Activities. We may disclose your PHI to a government agency responsible for preventing or controlling disease, injury, disability, or child abuse or neglect. We may disclose your PHI to a person or entity regulated by the Food and Drug Administration (“FDA”) if the disclosure relates to the quality or safety of an FDA-regulated product, such as a medical device.
- Disclosures For Health Oversight Activities. We may disclose your PHI to a government agency responsible for overseeing the health care system or health-related government benefit programs.
- Disclosures About Victims Of Abuse, Neglect, Or Domestic Violence. We may disclose your PHI to the responsible government agency if (a) the Privacy Official reasonably believes that you are a victim of abuse, neglect, or domestic violence, and (b) CDG is required or permitted by law to make the disclosure. CDG will promptly inform you that such a disclosure has been made unless CDG determines that informing you would not be in your best interests.
- Disclosures To Avert A Serious Threat To Health or Safety. We may use or disclose your PHI to reduce a risk of serious and imminent harm to you, another person, or the public.
- Disclosures To HHS. We may disclose your PHI to the United States Department of Health and Human Services (“HHS”), the government agency responsible for overseeing CDG’s compliance with federal privacy law and regulations regulating the privacy of PHI.
- Uses And Disclosures For Research. We may use or disclose your PHI for research, subject to conditions. “Research” means systemic investigation designed to contribute to generalized knowledge.
- Disclosures In Connection With Your Death Or Organ Donation. We may disclose your PHI to a coroner for identification purposes, to a funeral director for funeral purposes, or to an organ procurement organization to facilitate transplantation of one of your organs.
- Uses And Disclosures For Specialized Government Functions. We may disclose your PHI to the appropriate federal officials for intelligence and national security activities authorized by law or to protect the President or other national or foreign leaders. If you are a member of the U.S. Armed Forces or of a foreign armed forces, We may use or disclose your PHI for activities deemed necessary by the appropriate military commander. If you were to become an inmate in a correctional facility, We may disclose your PHI to the correctional facility in certain circumstances.
If applicable state law does not permit the disclosure described above, CDG will comply with the stricter State law.
CDG’s Uses or Disclosures With Your Prior Authorization
CDG is required to obtain your written authorization in the following circumstances: (a) to use or disclose psychotherapy notes (except when needed for payment purposes or to defend against litigation filed by you); (b) to use your PHI for marketing purposes; (c) to sell your PHI; and (d) to use or disclose your PHI for any purpose not previously described in this Notice. CDG also will obtain your authorization before using or disclosing your PHI when required to do so by (a) state law, such as laws restricting the use or disclosure of genetic information or information concerning HIV status; or (b) other federal law, such as federal law protecting the confidentiality of substance abuse records.
Your Privacy Rights
You may exercise the rights described below. The forms referenced below can be obtained from Cambridge Dental Group’s “Privacy Official”.
- Right To Access Your PHI. You may make an oral request to the Privacy Official to review your PHI on file with CDG, or to receive copies of it in paper or electric form, by submitting the appropriate form to the Privacy Official. The Privacy Official will provide access, or will deliver copies to you, within 30 days of your request unless the PHI is not available on-site, in which case the review will occur within 60 days of your request. CDG may extend the deadline by up to an additional 30 days. CDG will provide you with a written explanation of any denial of your request for access or copies. CDG may charge you a reasonable, cost-based fee for photocopies or for mailing. If there will be a charge, the Privacy Official will first contact you to determine whether you wish to modify or withdraw your request.
- Right To Amend PHI. You may amend your PHI on file with CDG by submitting the appropriate request form to the Privacy Official. CDG will respond to your request within 60 days. CDG may extend the deadline by up to an additional 30 days. If CDG denies your request to amend, CDG will provide a written explanation of the denial. You would then have 30 days to submit a written statement explaining your disagreement with the denial. Your statement of disagreement would be included with any future disclosure of the disputed PHI.
- Right To An Accounting Of Disclosures Of Your PHI. You may request an accounting of CDG’s disclosures of your PHI by submitting the appropriate form to the Privacy Official. CDG will provide the accounting within 60 days of your request. CDG may extend the deadline by up to an additional 30 days. The accounting will exclude the following disclosures: (a) disclosures for “treatment,” “payment” or “health care operations”, (b) disclosures to you or pursuant to your authorization, (c) disclosures to family members or close friends involved in your care or in payment for your care; (d) disclosures as part of a data use agreement; and (e) incidental disclosures. CDG will provide the first accounting during any 12-month period without charge. We may charge a reasonable, cost-based fee for each additional accounting during the same 12-month period. If there will be a charge, the Privacy Official will first contact you to determine whether you wish to modify or withdraw your request.
- Right To Request Additional Restrictions On The Use Or Disclosure Of Your PHI. You may request that CDG place restrictions on the use and disclosure or your PHI for “treatment,” “payment” or for “health care operations” in addition to the restrictions required by federal law by submitting the appropriate request form to the Privacy Official. CDG will notify you in writing within 30 days of your request whether it will agree to the requested restriction. CDG is not required to agree to your request unless (a) you request that CDG not disclose your PHI to a health insurance company, Medicare or Medicaid for payment or health care operations purposes; (b) you, or someone on your behalf, has paid CDG in full for the health care item or service to which the PHI pertains; and (c) CDG is not required by law to disclose to the insurer, Medicare, or Medicaid the PHI that is the subject of your request.
- Right To Request Communications By Alternative Means Or To An Alternative Location. CDG will honor your reasonable request to receive PHI by alternative means, or at an alternative location, if you submit the appropriate request form to the Privacy Official. We will accommodate a request if you tell us that not doing so would endanger you.
- Right To Receive Notice Of A Breach Of Your Unsecured PHI: If we discover a breach of your unsecured PHI, the Plans will notify you of the breach and provide the information required by law.
- Right To A Paper Copy Of This Notice. You may request at any time that the Privacy Official provide you with a paper copy of this Notice.
A Note About Personal Representatives
All of the rights described above may be exercised by your personal representative after the personal representative has provided proof of his or her authority to act on your behalf. Proof of authority may be established by (a) a power of attorney for health care purposes, or a general power of attorney, notarized by a notary public, (b) a court order appointing the person to act as your conservator or guardian, or (c) any other document which the Privacy Official, in his or her sole and absolute discretion, deems appropriate.
Your Right To File A Complaint
If you believe that your privacy rights have been violated because CDG has used or disclosed your PHI in a manner inconsistent with this Notice, because CDG has not honored your rights as described in this Notice, or for any other reason, you may file a complaint in one, or both, of the following ways:
- Internal Complaint: Within 180 days of the date you learned of the conduct, you can submit a complaint directly to our Privacy Official, Evan Berube (contact information provided below).
- Complaint To HHS: Within 180 days of the date you learned of the conduct, you may submit a complaint by mail to the Secretary of the U.S. Department of Health and Human Services, Hubert H. Humphrey Building, 200 Independence Ave., S.W., Washington, D.C. 20201.
Company’s Anti-Retaliation Policy
Cambridge Dental Group will not retaliate against you for submitting an internal complaint, a complaint to HHS, or for exercising your other rights as described in this Notice or under applicable law.
Whom To Contact For More Information About Company’s Privacy Policies And Procedures
If you have any questions about this Notice, or about how to exercise any of the rights described in this Notice, you should contact our Privacy Official:
Evan Berube
By mail: 126 Inman St, Cambridge, MA 02139
By phone: 617-492-8210
By email:
evan@cambridgedental.net
Revisions To The Privacy Policy And To The Notice
CDG has the right to change this Notice or CDG’s privacy policies and procedures at any time. If the change to CDG’s privacy policies and procedures would have a material impact on your rights, CDG will notify you of the change by promptly mailing or e-mailing (either electronically or by U.S. Postal Service) a revised Notice to you, in accordance with applicable regulations, which reflects the change. Any change to CDG’s privacy policies and procedures, or to the Notice, will apply to your PHI created or received before the revision.
Effective Date Of This Notice: April 1, 2021