Policies

Notice of Privacy Practices

NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN
GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. CHANGES ON THIS NOTICE WILL NOT BE HONORED.
YOU WILL BE ASKED TO ACKNOWLEDGE THAT YOU HAVE RECEIVED OUR NOTICE OF PRIVACY PRACTICES.

We understand that information about you and your health is very personal. Therefore, we strive to protect your privacy
as required by law. We will only use and disclose your protected health information (“PHI”) as allowed by law.
This Notice describes the privacy practices of Moravian Manor Communities. In addition to applying to the organization,
generally, this Notice applies to the physicians, therapists, and any other healthcare professionals who are involved in
your care and/or are authorized to enter information into your medical records, and all of our employees, staff,
volunteers, trainees, and other personnel who have access to your health information. These persons and programs
within Moravian Manor Communities may share your health information with each other for purposes of your
treatment, payment for your care or general healthcare operations as described in this Notice.
We are required by law to maintain the privacy of our patient and resident PHI and to provide you with notice of our
legal duties and privacy practices with respect to your PHI. We are required to abide by the terms of this Notice so long
as it remains in effect. We reserve the right to change the terms of this Notice as necessary and to make the new Notice
effective for all PHI maintained by us. The terms of this Notice apply to Moravian Manor Communities, if you have questions regarding the coverage of this Notice, or if you would like to obtain a copy of this Notice, please contact the Privacy Official as described below.

USES AND DISCLOSURES OF YOUR PHI
The following categories describe the ways we may use or disclose your PHI without your consent or authorization. For
each category, we will give you illustrative examples.

Uses and Disclosures for Treatment, Payment and Health Care Operations.
Treatment: We use and disclose your PHI as necessary for your treatment. For instance, doctors, nurses, and other
professionals involved in your care – within and outside of Moravian Manor Communities – will use information in your
medical record that may include procedures, medications, tests, etc. to plan a course of treatment for you.

Payment: We will make uses and disclosures of your PHI as necessary for payment purposes. For instance, we may
forward information regarding your medical procedures and treatment to your insurance company to arrange payment
for the services provided to you. Also, we may use your information to prepare a bill to send to you or to the person
responsible for your payment.

Health Care Operations: We will use and disclose your PHI for health care operations. This is necessary to operate
Moravian Manor Communities, including by ensuring that our patients and residents receive high-quality care. This
includes, but is not necessarily limited to quality assessment and improvement activities, auditing functions, cost
management analysis, and customer service. For example, we may use your PHI in order to conduct an evaluation of the
treatment and services we provide, or to review the performance of our staff. Your health information may also be
disclosed to doctors, nurses, staff, medical students, residents, fellows and others for education and training purposes.
The sharing of your PHI for treatment, payment, and healthcare operations may happen electronically. Electronic
communications enable fast, secure access to your information for those participating in and coordinating your care to
improve the overall quality of your health and prevent delays in treatment.

Health Information Exchanges: Moravian Manor Communities participates in initiatives to facilitate this electronic
sharing, including but not limited to Health Information Exchanges (HIEs) which involve coordinated information sharing
among HIE members for purposes of treatment, payment, and healthcare operations. Patients may opt-out of some of
these electronic sharing initiatives, such as HIEs. Moravian Manor Communities will use reasonable efforts to limit the sharing of PHI in such electronic sharing initiatives for patients who have opted-out. If you wish to opt-out, please contact the Privacy Official as described below.

Our Facility Directory. We use the information to maintain a directory listing your name, room number, and general
condition. Your religious affiliation may be given to a member of the clergy, such as a pastor, priest or rabbi, even if they
don’t ask for you by name. This information is provided so that your family, friends and clergy can visit you. Unless you
choose to have your information excluded from this directory, the information will be disclosed to anyone who requests
it by asking for you by name. If you wish to have your information excluded from this directory, please contact the
Admissions Office at Moravian Manor Communities.
Persons Involved In Your Care. Unless you object, we may, in our professional judgment, disclose to a member of your
family, a close friend, or any other person you identify, your PHI, to facilitate that person’s involvement in caring for you
or in payment for your care. We may use or disclose your PHI to assist in notifying a family member, personal
representative or any other person that is responsible for your care of your location and general condition. We may also
disclose limited PHI to a public or private entity that is authorized to assist in disaster relief efforts in order for that
entity to locate a family member or other persons that may be involved in some aspect of caring for you.

Fundraising. We may contact you in an effort to raise money for Moravian Manor Communities and its programs and
operations. However, you have the right to opt-out of receiving fundraising communications at any time. We will not
contact you directly to raise money for Moravian Manor Communities if you are a resident of either Personal Care or
Healthcare centers.

Appointments and Services. We may use your PHI to remind you about appointments or to follow up on your visit.

Health Products and Services. We may, from time to time, use your PHI to communicate with you about treatment
alternatives and other health-related benefits and services that may be of interest to you.

Business Associates. We contract with certain outside persons or organizations to perform certain services on our
behalf, such as auditing, billing, legal services, etc. At times it may be necessary for us to provide your PHI to one or
more of these outside persons or organizations. In such cases, we require these business associates, and any of their
subcontractors, to appropriately safeguard the privacy of your information.

Other Uses and Disclosures. We are permitted or required by law to make certain other uses and disclosures of your PHI
without your consent or authorization. Subject to conditions specified by law, we may release your PHI:

  • for any purpose required by law;
  • for public health activities, such as required reporting of disease, injury, and birth and death, and for required
    public health investigations;
  • to certain governmental agencies if we suspect child abuse or neglect; or if we believe you to be a victim of
    abuse, neglect, or domestic violence;
  • to your employer when we have provided health care to you at the request of your employer for purposes
    related to occupational health and safety. In most cases you will receive notice that your PHI is being disclosed
    to your employer;
  • if required by law to a government oversight agency conducting audits, investigations, inspections and related
    oversight functions;
  • in emergency circumstances, such as to prevent a serious and imminent threat to a person or the public;
  • if required to do so by a court or administrative order, subpoena or discovery request. In most cases you will
    have notice of such release;
  • to law enforcement officials, including for purposes of identifying or locating suspects, fugitives, witnesses, or
    victims of crime, or for other allowable law enforcement purposes;
  • to coroners, medical examiners, and/or funeral directors;
  • if necessary, to arrange an organ or tissue donation from you or a transplant for you; ;
    8226114.2 – December 30, 2020
  • if you are a member of the military for activities set out by certain military command authorities as required by
    armed forces services. We may also release your PHI, if necessary, for national security, intelligence, or
    protective services activities; and
  • if necessary, for purposes related to your workers’ compensation benefits.
    Your Authorization. Except as outlined above, we will not use or disclose your PHI for any other purpose unless you
    have signed a form authorizing the use or disclosure. The form will describe what information will be disclosed, to
    whom, for what purpose, and when. You have the right to revoke your authorization in writing, except to the extent we
    have already relied upon it. These situations can include:
  • uses and disclosures of psychotherapy notes;
  • uses and disclosures of PHI for marketing purposes, including marketing communications paid for by third
    parties;
  • uses and disclosures of PHI specially protected by state and/or Federal law and regulations;
  • uses and disclosures for certain research protocols;
  • disclosures that constitute a sale of PHI.

Confidentiality of Alcohol and Drug Abuse Patient Records, HIV-Related Information, and Mental Health Records.

The confidentiality of alcohol and drug abuse treatment records, HIV-related information, and mental health records
maintained by us is specifically protected by state and/or Federal law and regulations. Generally, we may not disclose
such information unless you consent in writing, the disclosure is allowed by a court order, or in limited and regulated
other circumstances.

RIGHTS THAT YOU HAVE

Access to Your PHI. Generally, you or your personal representative have the right to access, inspect, and/or receive
paper and/or electronic copies of the PHI that we maintain about you. Requests for access must be made in writing and
be signed by you or, when applicable, your personal representative. We may charge you for a copy of your medical
records in accordance with a schedule of fees under federal and state law.

Amendments to Your PHI. You have the right to request that PHI that we maintain about you be amended or corrected.
Requests for amendment must be made in writing and be signed by you or, when applicable, your personal
representative and must state the reasons for the amendment/correction request. We are not obligated to make all
requested amendments but will give each request careful consideration. If we grant your amendment request, we may
also reach out to other prior recipients of your information to inform them of the change. Please note that even if we
accept your request, we may not delete any information already documented in your medical record.

Accounting for Disclosures of Your PHI. You have the right to receive an accounting of certain disclosures made by us of
your PHI except for disclosures made for purposes of treatment, payment, and health care operations or for certain
other limited exceptions. This accounting will include only those disclosures made in the six (6) years prior to the date on
which the accounting is requested. Requests must be made in writing and signed by you or, when applicable, your
personal representative. The first accounting in any 12-month period is free; you will be charged a reasonable, cost-based fee for each subsequent accounting you request within a 12-month period.

Restrictions on Use and Disclosure of Your PHI. You have the right to request restrictions on certain uses and
disclosures of your PHI for treatment, payment, or health care operations. We are not required to agree to your
restriction request unless otherwise described in this notice, but will attempt to accommodate reasonable requests
when appropriate. We retain the right to terminate an agreed-to restriction if we believe such termination is
appropriate. In the event we have terminated an agreed upon restriction, we will notify you of such termination. Such
requests must be made in writing and signed by you and, when applicable, your personal representative.

Restrictions on Disclosures to Health Plans. You have the right to request a restriction on certain disclosures of your PHI
to your health plan. We are only required to honor such requests for restriction when you or someone on your behalf, other than your health plan, pay for the health care item(s) or service(s) in full. Such requests must be made in writing and signed by you and, when applicable, your personal representative.

Confidential Communications. You have the right to request communications regarding your PHI from us by alternative
means or at alternative locations and we will accommodate reasonable requests by you. You, or when applicable, your
personal representative must request such confidential communication in writing to each department to which you
would like the request to apply.

Breach Notification. We are required to notify you in writing of any improper breach of your unsecured PHI without
unreasonable delay, but in any event, no later than 60 days after we discover the breach.

Paper Copy of Notice. As a patient or resident, you have the right to obtain a paper copy of this Notice. You can also find
this Notice on our website at www.moravianmanorcommunities.org.

ADDITIONAL INFORMATION

Complaints. If you believe your privacy rights have been violated, you may file a complaint in writing with the Privacy
Official at the address below. You may also file a complaint with the Secretary of the U.S. Department of Health and
Human Services in Washington, D.C. All complaints must be made in writing and in no way will affect the quality of care
you receive from us.

For further information. If you have questions or wish to exercise any choices described in this Notice, you may contact
us by mail, telephone, or by email:

Moravian Manor Communities
300 West Lemon Street
Lititz PA 17543
Attention: Privacy Official

Compliance Report

If you have any questions or would like information regarding your privacy rights, you may contact our Compliance Official at 717-625-7600. If you believe your privacy rights have been violated, you may file a complaint with Moravian Manor Communities or with the Secretary of the Department of Health and Human Services.

To file a complaint with Moravian Manor Communities, please address your complaint to:

Moravian Manor Communities
Privacy and Compliance Official
300 West Lemon Street
Lititz, PA 17543

You may file a complaint by calling 717-625-7600.  

For a full description of how your protected health information (PHI) may be used and disclosed, and how you can get access to this information, read our Privacy Notice.

You will not be penalized for filing a complaint.

Anti-Discrimination Policy

Moravian Manor Communities complies with applicable Federal civil rights laws and does not discriminate on the basis of race, color, national origin, age, disability, gender, gender-identity, or sexual orientation.