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.
Who We Are
This Notice describes the privacy practices of Shirley Ryan AbilityLab, including its employed physicians, nurses, allied health personnel and other personnel, including non-employed consulting physicians. It applies to services furnished to you at Shirley Ryan AbilityLab’s flagship hospital located at 355 East Erie Street, as well as its outpatient sites and DayRehab Centers™.
Shirley Ryan AbilityLab’s Privacy Obligations
We understand that your health information is personal and we are committed to protecting your privacy. In addition, we are required by law to maintain the privacy of your health information (“Protected Health Information” or “PHI”), to provide you with this Notice of our legal duties and privacy practices with respect to your Protected Health Information, and to notify affected individuals when there is a breach of their unsecured protected health information. When we use or disclose your PHI, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).
Shirley Ryan AbilityLab’s Permissible Uses and Disclosures without Your Written Authorization
In certain situations, which we describe below, we must obtain your written authorization (“Your Authorization”) in order to use and/or disclose your PHI. However, we do not need any type of authorization from you for the following uses and disclosures:
Uses and Disclosures For Treatment, Payment and Health Care Operations
We may use and disclose your PHI in order to treat you, obtain payment for services provided to you, and conduct our “health care operations” as detailed below:
- Treatment. We use and disclose your PHI to provide treatment and other services to you, i.e., to diagnose and treat your injury or illness. For example, we may share your medical information with other health care providers who are involved in your treatment, including consulting physicians who are not employees of Shirley Ryan AbilityLab, in order to coordinate the different services you may need, such as lab work or diagnostic imagine. In addition, we may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.
Shirley Ryan AbilityLab participates in the Cerner CommonWell Health Information Exchange (“HIE”) and other similar programs. This allows us to electronically and securely exchange your relevant PHI with your other established healthcare providers for treatment, payment, and operational purposes, as well as for continuity of care, when your other providers also use the same HIEs that we do. For example, if one of your healthcare providers participates in the same HIEs and needs access to your Shirley Ryan AbilityLab medical records to make a decision about your care, they will be able to access your records immediately. Shirley Ryan AbilityLab can also access your medical records from other providers, if they participate in the same HIEs. Shirley Ryan AbilityLab will not share certain medical records, such as mental health records, with any other providers, even through HIEs, unless you give your permission.
Our participation in HIEs is designed to comply with all federal and state privacy and security laws, including HIPAA. The HIE and all HIE participants are required to implement appropriate administrative, physical, and technical safeguards to reasonably protect the confidentiality and integrity of your medical information. You may request to opt out of the HIEs by submitting a Written Revocation to the Shirley Ryan AbilityLab Privacy Officer. Written Revocation forms are available and can be requested from the Privacy Officer by e-mailing privacyofficer@sralab.org. If you opt out, you may also request to opt back in by contacting the Privacy Officer at privacyofficer@sralab.org.
- Payment. We may use and disclose your PHI to obtain payment for services that we provide to you. For example, we may use your PHI for disclosures to claim and obtain payment from Medicare, Medicaid, your health insurer, HMO, or other company or program that arranges or pays the cost of some or all of your health care, or to verify that your payor will pay for health care.
- Shirley Ryan AbilityLab’s Health Care Operations. We may use and disclose your PHI for our health care operations, which include internal administration and planning and various activities that improve the quality and cost effectiveness of the care that we deliver to you. For example, we may use PHI to evaluate the quality and competence of our physicians, nurses, and other health care workers. We may access your PHI in order to resolve any concerns you may have and ensure that you have a comfortable visit with us.
We may also disclose PHI to your other health care providers when such PHI is required for them to treat you, receive payment for services they render to you, or conduct certain health care operations, such as quality assessment and improvement activities, reviewing the quality and competence of health care professionals, or for health care fraud and abuse detection or compliance.
Use or Disclosure for Directory of Individuals at the Shirley Ryan AbilityLab. We may include your name, location in Shirley Ryan AbilityLab, general health condition, and religious affiliation in our inpatient directory without obtaining Your Authorization unless you object to inclusion in the directory. Information in the directory may be disclosed to anyone who asks for you by name or to members of the clergy; provided, however, that religious affiliation will only be disclosed to members of the clergy.
Disclosure to Relatives, Close Friends and Other Caregivers. We may use or disclose your PHI to a family member, other relative, a close personal friend, or any other person identified by you if we (1) obtain your agreement; (2) provide you with the opportunity to object to the disclosure and you do not object; or (3) reasonably infer that you do not object to the disclosure. If you are not present, or the opportunity to agree or object to a use or disclosure cannot be provided because of your incapacity or an emergency circumstance, we may exercise our professional judgment to determine whether a disclosure is in your best interest. If we disclose information to a family member, other relative or a close personal friend, we would disclose only information that we believe is directly relevant to the person’s involvement with your health care or payment related to your health care. We may also disclose your PHI in order to notify (or assist in notifying) such persons of your location or general condition.
Fundraising Communications. We may use certain information (for instance, name, address, telephone number, age, date of birth, gender, dates of service, insurance status, department of service, treating physician, and outcome information) to contact you in the future regarding fundraising for Shirley Ryan AbilityLab. If you do not want to receive any fundraising requests in the future, you may contact the Shirley Ryan AbilityLab’s Privacy Office at 312.238.0766 or privacyofficer@sralab.org, or Advancement at 312.238.4000 or advancement@sralab.org.
Public Health Activities. We may disclose your PHI 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 the Illinois Department of Children and Family Services 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 Illinois Department of Public Health is authorized by law to develop and maintain an immunization data registry to collect, store, analyze, release and report immunization data. We will provide your PHI to the I-CARE Illinois Immunization Registry. If you do not want your PHI provided to the I-CARE Illinois Immunization Registry you may contact the Shirley Ryan AbilityLab Privacy Office at 312.238.0766 to complete an opt-out/exemption form.
Victims of Abuse, Neglect or Domestic Violence. If we reasonably believe you are a victim of abuse, neglect, or domestic violence, we may disclose your PHI to the Illinois Department of Children and Family Services, the Illinois Department of Human Services, the Illinois Department of Aging, or any other governmental authority, including a social service or protective services agency, authorized by law to receive reports of such abuse, neglect, or domestic violence.
Health Oversight Activities. We may disclose your PHI to a health agency that oversees the health care system and is charged with responsibility for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.
Judicial and Administrative Proceedings. We may disclose your PHI in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.
Law Enforcement Officials. We may disclose your PHI to the police or other law enforcement officials as required or permitted by law or in compliance with a court order or a grand jury or administrative subpoena.
Coroner/Medical Examiners. We may disclose your PHI to a coroner or medical examiner as authorized by law.
Organ and Tissue Procurement. We may disclose your PHI to organizations that facilitate organ, eye, or tissue procurement, banking, or transplantation.
Data Analysis. We may use or disclose your PHI to Northwestern University or another organization, to be included in a database of clinical and research data for research, clinical quality, healthcare operations, or medical education purposes.
Research. We may contact you to tell you about research studies for which you may be eligible and invite you to participate. If you decide to participate, we may use or disclose your PHI for research with Your Authorization. In addition, there are certain circumstances in which HIPAA allows us to use or disclose your PHI for research without Your Authorization. For example, we may use and disclose your PHI without Your Authorization:
- With the permission of an Institutional Review Board (“IRB”). An IRB is an independent board that oversees any human research study to ensure it is appropriate. An IRB is allowed to waive the authorization requirement under certain circumstances.
- To help researchers get ready to conduct a study; for example, designing the study and identifying patients that may be eligible to participate in the study.
- To ask you about your interest in taking part in a specific research study.
- If we remove certain directly identifying information about you (like your name) and only use or disclose indirectly identifying information and document that researchers will follow certain requirements in how they use the information we share.
- Should you pass away, but additional protections will still apply.
Health or Safety. We may use or disclose your PHI to prevent a serious and imminent threat to a person’s or the public’s health or safety.
Specialized Government Functions. We may use and disclose your PHI to units of the government with special functions, such as the United States Armed Forces or the U.S. Department of State under certain circumstances.
Workers’ Compensation. We may disclose your PHI as authorized by and to the extent necessary to comply with state law relating to workers compensation or other similar programs.
As required by law. We may use and disclose your PHI when required to do so by any other law not already referred to in the preceding categories.
Uses and Disclosures Requiring Your Written Authorization
Use or Disclosure with Your Authorization. For any purpose other than the ones described above, we only may use or disclose your PHI when you grant us Your Authorization. For instance, you will need to execute an authorization form before we can send your PHI to your life insurance company, your attorney, or to an attorney representing another party in litigation in which you are involved.
Uses and Disclosures of Your Highly Confidential Information. In addition, federal and Illinois law requires special privacy protections for certain highly confidential information about you (“Highly Confidential Information”), including, without limitation: (1) psychotherapy notes; (2) mental health services and developmental disabilities services; (3) HIV/AIDS testing, diagnosis or treatment; (4) venereal disease(s); (5) genetic testing; (6) child abuse and neglect; (7) domestic abuse of an adult with a disability; or (8) sexual assault. In order for us to disclose your Highly Confidential Information for a purpose other than those permitted by law, we must obtain Your Authorization.
Sale of Protected Health Information. We will not sell your PHI without Your Authorization.
Marketing. We must obtain Your Authorization prior to using your PHI for marketing purposes, unless an exception applies. For example, we will not accept any payments from other organizations or individuals in exchange for making communications to you about treatments, therapies, health care providers, settings of care, case management or care coordination, and products or services unless you have given us Your Authorization to do so, or the communication is permitted by law. We can provide refill reminders or communicate with you about a drug or biologic that is currently being prescribed to you so long as payment we receive for making the communication is reasonably related to our cost of making the communication. We may market to you in a face-to-face encounter and give you a promotional gift of nominal value without obtaining Your Authorization.
Your Rights Regarding Your Protected Health Information
For Further Information; Complaints. If you desire further information about your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to your PHI, you may contact our Privacy Office at 312.238.0766 or privacyofficer@sralab.org, or the Shirley Ryan AbilityLab Customer Care telephone line at 312.238.4410. 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 Shirley Ryan AbilityLab Privacy Office 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 Office for Civil Rights.
Right to Request Additional Restrictions. You may request restrictions on our use or disclosure of your PHI: (1) for treatment, payment and health care operations; (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care; or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for restrictions carefully, we are not required to agree to a requested restriction unless the disclosure is to a health plan for purposes of carrying out payment or health care operations and the information pertains solely to a health care item or service for which you have paid us out of pocket in full. If you wish to request additional restrictions, please obtain a request form from our Privacy Office and submit the completed form to the Privacy Office. We will send you a written response.
Right to Receive Confidential Communications. You may request, and we will accommodate, any reasonable written request for you to receive your PHI by alternative means of communication or at alternative locations.
Right to Revoke Your Authorization. You may revoke Your Authorization, or any written authorization obtained in connection with your PHI, except to the extent that we have taken action in reliance upon it, by delivering a written revocation statement to the Shirley Ryan AbilityLab Privacy Office. If Your Authorization was obtained as a condition of obtaining insurance coverage, other laws provide your insurer with the right to contest a claim, and you may be responsible for any charges the insurer does not pay. A form of Written Revocation is available upon request from the Privacy Office.
Right to Inspect and Copy Your Health Information Timely. You may request timely access to your medical record file 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 desire access to your records, please obtain a record request form from the Shirley Ryan AbilityLab Privacy Office and submit the completed form to the Privacy Office. If you request paper copies, we may charge you for each page. We may also charge you for our postage costs, if you request that the copies be mailed.
Right to Amend Your Records. You have the right to request that we amend PHI maintained in your medical record file or billing records. If you desire to amend your records, please obtain an amendment request form from the Shirley Ryan AbilityLab Privacy Office and submit the completed form to the Privacy Office. We will comply with your request unless we believe that the information you wish to have amended is accurate and complete or other circumstances apply.
Right to Receive an Accounting of Disclosures. Upon request, you may obtain an accounting of certain disclosures of your PHI made by us during any period of time prior to the date of your request provided such period does not exceed six (6) years and does not apply to disclosures that occurred prior to April 14, 2003. If you request an accounting more than once during a twelve (12) month period, we may charge you for the accounting statement.
Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice, even if you have agreed to receive such notice electronically.
To request a copy of your medical records, please download the Authorization to Release Protected Health Information on the Medical Records page and e-mail the completed release to *medical_records@sralab.org or fax it to 312.238.2900.
Effective Date and Duration of This Notice
Effective Date This Notice is effective on April 14, 2003, and was revised April 1, 2007, September 22, 2013, January 30, 2015, March 25, 2017, May 30, 2019, and September 20, 2021.
Right to Change Terms of this Notice We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all PHI that we maintain, including any information created or received prior to issuing the new notice. If we change this Notice, we will post the new notice in Shirley Ryan AbilityLab waiting areas and on our Internet site at www.sralab.org. You also may obtain any new notice by contacting the Shirley Ryan AbilityLab Privacy Office.
Privacy Office
Shirley Ryan AbilityLab
355 East Erie Street
Chicago, Illinois 60611
Telephone Number: 312.238.0766
Email: privacyofficer@sralab.org