Our Policies

Your Rights and Protections Against Surprise Medical Bills

When you get emergency care or get treated by an out-of-network provider at an in-network hospital or ambulatory surgical center, you are protected from surprise billing or balance billing.

What is “balance billing” (sometimes called “surprise billing”)?

When you see a doctor or other health care provider, you may owe certain out-of-pocket costs, such as a copayment, coinsurance, and/or a deductible. You may have other costs or have to pay the entire bill if you see a provider or visit a health care facility that isn’t in your health plan’s network.

“Out-of-network” describes providers and facilities that haven’t signed a contract with your health plan. Out-of-network providers may be permitted to bill you for the difference between what your plan agreed to pay and the full amount charged for a service. This is called “balance billing.” This amount is likely more than in-network costs for the same service and might not count toward your annual out-of-pocket limit.

“Surprise billing” is an unexpected balance bill. This can happen when you can’t control who is involved in your care—like when you have an emergency or when you schedule a visit at an in-network facility but are unexpectedly treated by an out-of-network provider.

You are protected from balance billing for:

Emergency services

If you have an emergency medical condition and get emergency services from an out-of-network provider or facility, the most the provider or facility may bill you is your plan’s in-network cost-sharing amount (such as copayments and coinsurance). You can’t be balance billed for these emergency services. This includes services you may get after you’re in stable condition, unless you give written consent and give up your protections not to be balanced billed for these post-stabilization services.

Visit www.commonwealthfund.org/publications/maps-and-interactives/2021/feb/state-balance-billing-protections for more information about your rights under your state law.

Certain services at an in-network hospital or ambulatory surgical center

When you get services from an in-network hospital or ambulatory surgical center, certain providers there may be out-of-network. In these cases, the most those providers may bill you is your plan’s in-network cost-sharing amount. This applies to emergency medicine, anesthesia, pathology, radiology, laboratory, neonatology, assistant surgeon, hospitalist, or intensivist services. These providers can’t balance bill you and may not ask you to give up your protections not to be balance billed.

If you get other services at these in-network facilities, out-of-network providers can’t balance bill you, unless you give written consent and give up your protections.

You’re never required to give up your protections from balance billing. You also aren’t required to get care out-of-network. You can choose a provider or facility in your plan’s network.

Visit www.commonwealthfund.org/publications/maps-and-interactives/2021/feb/state-balance-billing-protections for more information about your rights under your state law.

When balance billing isn’t allowed, you also have the following protections:

·       You are only responsible for paying your share of the cost (like the copayments, coinsurance, and deductibles that you would pay if the provider or facility was in-network). Your health plan will pay out-of-network providers and facilities directly.

·       Your health plan generally must:

o   Cover emergency services without requiring you to get approval for services in advance (prior authorization).

o   Cover emergency services by out-of-network providers.

o   Base what you owe the provider or facility (cost-sharing) on what it would pay an in‑network provider or facility and show that amount in your explanation of benefits.

o   Count any amount you pay for emergency services or out-of-network services toward your deductible and out-of-pocket limit.

If you believe you’ve been wrongly billed, you may contact 1-800-985-3059.

Visit www.cms.gov/nosurprises for more information about your rights under federal law.

Visit www.commonwealthfund.org/publications/maps-and-interactives/2021/feb/state-balance-billing-protections for more information about your rights under your state law.

Approved by: People's Center Board of Directors
It is the policy of People’s Center Health Services (People's Center) to (1) Ensure the confidentiality, integrity, and availability of all protected health information it creates, receives, maintains, or transmits. (2) Protect against any reasonably anticipated threats or hazards to the security or integrity of such information. (3) Protect against any reasonably anticipated uses or disclosures of such information that are not permitted or required, and (4) ensure compliance by its workforce.
Procedures to support the policy and to be modified, as needed, and at the discretion of management include:

• Maintaining the designated records set which includes electronic and physical medical records, billing records, and patient logs & reports 

• Providing the Notice of Privacy Practices, which includes a hard copy to be delivered upon a patient’s first visit to the clinic; or if upon return, reception notices the acknowledgment form hasn’t been signed, will provide another copy and an electronic copy which is available on our website 

• Maintaining administrative, physical, and technical safeguards for the protection of patient health information (PHI) 

• Providing training for new and existing staff on a recurring basis 

• Requiring Business Associate Agreements of any partner that may view, collect, use, distribute, or otherwise come in contact with a People's Center patient’s PHI 

• Levying sanctions against non-compliance 

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

We have summarized our responsibilities and your rights on the first page. For a complete description of our privacy practices, please review this entire notice.

People's Center Responsibilities

We are required to:

• Maintain the privacy of your health information

• Provide you with this notice of our legal duties and privacy practices with respect to information we collect and maintain about you

• Abide by the terms of this notice

Your Rights

As a patient of People’s Center you have several rights with regard to your health information, including the following:

• The right to request that we not use or disclose your health information in certain ways.

• The right to request to receive communications in an alternative manner or location.

• The right to access and obtain a copy of your health information.

• The right to request an amendment to your health information.

• The right to an accounting of disclosures of your health information.

• The right to receive a notice of breach of unsecured health information.

We reserve the right to change our privacy practices and to make the new provisions effective for all health information we maintain. Our privacy practices change, we will post the changes on the bulletin board in our clinics are on our web site. A copy of the revised notice will be available after the effective date of the changes upon request.

We will not use or disclose your health information without your authorization, except as described in this notice.

If you have questions and would like additional information, you may contact Ann C. Rogers, Chief Executive Officer (CEO).

Understanding Your Health Record/Information

If medical, dental or behavioral services are provided to you at People’s Center a record of your care/treatment is made. Typically, this record contains your symptoms, examination, test results, diagnoses, treatment, and a plan for future care or treatment. This information often referred to as your health, medical or dental record, serves as a:

• basis for planning your care and treatment

• means of communication among the many health professionals who contribute to your care

• legal document describing the care you received

• means by which you or a third-party payer can verify that services billed were actually provided

• a tool in educating health professionals

• a source of data for clinic planning and marketing

• a tool with which we can assess and continually work to improve the care we render and the outcomes we achieve

Understanding what is in your record and how your health information is used helps you to: ensure its accuracy, better understand who, what, when, where, and why others may access your health information, and make more informed decisions when authorizing disclosure to others.

How We Will Use or Disclose Your Health Information

(1) Treatment. We will use or disclose your health information for treatment purposes, including for the treatment activities of other health care providers. For example, information obtained by a nurse, physician, dentist, or other member of your healthcare team will be recorded in your record and used to determine the course of treatment that should work best for you. Your provider will document in your record his or her expectations of the members of your healthcare team. Members of your healthcare team will then record the actions they took and their observations. In that way, your provider will know how you are responding to treatment. We will also provide your physician or a subsequent healthcare provider with copies of various reports that should assist him or her in treating you.If state law requires your written consent for us to disclose your personal information for treatment, we’ll ask you for that consent. But that consent will not generally be required in a medical emergency (if you are unable to give us your permission due to your condition), or for us to exchange information with affiliates.

(2) Payment. We will use or disclose your health information for payment, including for the payment activities of other health care providers or payers. For example, a bill may be sent to you or a third-party payer, including Medicare or Medicaid. The information on or accompanying the bill may include information that identifies you, as well as your diagnosis, procedures and supplies used.

(3) Health care operations. We will use or disclose your health information for our regular health operations. For example, members of the medical staff, the risk or quality improvement manager, or members of the quality improvement team may use information in your health record to assess the care and outcomes in your case and others like it. This information will then be used in an effort to continually improve the quality and effectiveness of the health care and service we provide.

(4) Business associates. There are some services provided in our organization through the use of outside people and entities. Examples of these “business associates” include our accountants, consultants and attorneys. We may disclose your health information to our business associates so that they can perform the job we’ve asked them to do. To protect your health information, however, we require the business associates to appropriately safeguard the privacy and security of your information.

(5) Health Information Exchange. People’s Center participates in an electronic Health Information Exchange(“HIE”). The HIE is managed by Health Information Organization certified by the State of Minnesota. The HIE is a secure network that safely connects participating health care provider electronic health record systems. People’s Center may make your protected health information available electronically through the HIE to other health care providers that request your information for their treatment and payment purposes. Participation in an HIE also lets People’s Center see their information about you for our treatment and payment and health care operation purposes. You are permitted to request and review documentation regarding who has accessed your information through the HIE. Contact Ann C. Rogers, CEO for information on how to make this request.

(6) Health Information Exchange OPT-OUT. If you don’t want to participate in the HIE, you may “opt-out” at any time. If you do opt out other medical professionals may not have timely access to your essential medical information. If you do wish to opt-out of participation in the HIE, please contact People’s Center at (612)332-4973 to obtain the opt-out form.

(7) Notification. Unless you instruct us otherwise, we may use or disclose information to notify or assist in notifying a family member, personal representative, or another person responsible for your care, of your location, and general condition.

(8) Communication with family and friends. We may disclose to a family member, other relative, close personal friend or any other person you identify, your health information to the extent it is relevant to that person’s involvement in your care or payment related to your care. We will provide you with an opportunity to object to such a disclosure whenever we practicably can do so.

(9) Research. We may disclose information to researchers when we have received an authorization from you or when certain conditions have been met.

(10) Transfer of information at death. We may disclose health information to funeral directors, medical examiners, and coroners to carry out their duties consistent with applicable law.

(11) Organ procurement organizations. Consistent with applicable law, we may disclose health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.

(12) Marketing. We will not use or disclose your personal information for marketing purposes without your authorization. However, we may contact you regarding your treatment, to coordinate your care, or to direct or recommend alternative treatments, therapies, health care providers or settings. In addition, we may contact you to describe a health-related product or service that may be of interest to you, and the payment for such product or service.

(13) Fundraising. We may contact you as part of a fundraising effort. You will be provided the right to opt out of receiving any future fundraising communications.(14) Food and Drug Administration (FDA). We may disclose to the FDA, or to a person or entity subject to the jurisdiction of the FDA, health information relative to adverse events with respect to food, supplements, product and product defects, or post marketing surveillance information to enable product recalls, repairs, or replacement.

(15) Workers’ compensation. We may disclose health information to the extent authorized by and to the extent necessary to comply with laws relating to workers’ compensation or other similar programs established by law.

(16) Public health. As required by law, we may disclose your health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability.

(17) Correctional institution. If you are an inmate of a correctional institution, we may disclose to the institution or agents thereof health information necessary for your health and the health and safety of other individuals.

(18) Law enforcement. We may disclose health information for law enforcement purposes as required by law or in response to a valid subpoena.

(19) Reports. Federal law makes provision for your health information to be released to an appropriate health oversight agency, public health authority or attorney, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or have otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public.

(20) Personal Representative, Health Care Agent or Guardian. If you have designated a HIPAA personal representative or have a legal guardian and/or have appointed a health care agent, we will treat that person as if that person is you with respect to disclosures of your health information.

(21) Psychotherapy notes. Under most circumstances, without your written authorization, we may not disclose the notes a mental health professional took during a counseling session that are kept separate from your general medical records.

(22) Sale of Health Information. We will not sell or rent your health information.

Your Health Information Rights

Although your health record is the physical property of People’s Center, the information in your health record belongs to you. You have the following rights:

• Right to Request Restrictions of Your Personal Information. You may request that we not use or disclose your health information for a particular reason related to treatment, payment, People’s Center’s general health care operations, and/or to a particular family member, other relative or close personal friend. Although we will consider your requests with regard to the use of your health information, be aware that we are under no obligation to accept it or to abide by it except with respect to disclosures to health plans as provided below. We will abide by your requests with regard to the disclosure of your clinical and personal records to anyone outside of People’s Center, except in an emergency, if you are being transferred to another health care institution, or the disclosure is required by law.”

• Right to Restrict Disclosures to Health Plans. You have the right to prohibit us from disclosing to your health plan personal information related to a particular service, if you pay us for that service up front and in full and if the disclosure is for the purpose of carrying out payment or health care operations and is not otherwise required by law.•Right to Request Confidential Communications. If you are dissatisfied with the manner in which or the location where you are receiving communications from us that are related to your health information, you may request that we provide you with such information by alternative means or at alternative locations. Such a request must be made in writing on People’s Center’s standard form, and submitted to Ann C. Rogers. We will attempt to accommodate all reasonable requests.

• Right to Review and Copy your Personal Information. You may request to inspect and/or obtain copies of health information about you, which will be provided to you in the time frames established by law. You may make such requests orally or in writing; however, in order to better respond to your request we ask that you make such requests in writing on People’s Center’s standard form. If you request to have copies made, we will charge you a reasonable fee.

• Right to Request an Amendment of Your Personal Information. If you believe any health information in your record is incorrect or if you believe that important information is missing, you may request that we correct the existing information or add the missing information. Such requests must be made in writing, and must provide a reason to support the amendment. We ask that you use the form provided by People’s Center to make such requests. For a request form, contact Ann C. Rogers, CEO.

• Right to Receive an Accounting of Disclosures. You may request that we provide you with a written accounting of all disclosures made by us during the time period for which you request (not to exceed 6 years). We ask that such requests be made in writing on a form provided by People’s Center. Note that an accounting will not apply to any of the following types of disclosures: disclosures made for reasons of treatment, payment or health care operations unless such disclosures are part of an electronic medical record system; disclosures made to you or your legal representative, or any other individual involved with your care; disclosures to correctional institutions or law enforcement officials; and disclosures for national security purposes. You will not be charged for your first accounting request in any 12 month period. However, for any requests that you make thereafter, you will be charged a reasonable, cost-based fee.

• Right to Obtain a Copy of this Notice. You have the right to obtain a paper copy of our Notice of Privacy Practices upon request. You may also access and print a copy of our notice from our website: www.peoples-center.org.

• Right to Revoke an Authorization. You may revoke an authorization to use or disclose health information, except to the extent that action has already been taken. Such a request must be made in writing to Ann C. Rogers, CEO.

• Right to Receive Notice of a Breach. We are required to notify you by first class mail or by e-mail (if you have indicated a preference to receive information by e-mail), of any breaches of Unsecured Protected Health Information as soon as possible, but in any event, no later than 60 days following the discovery of the breach.

• Right to File a Complaint. If you believe we have violated your privacy rights, you may complain to us directly (see Contact Information below) or to the Office for Civil Rights of the United States Department of Health and Human Services. You may file a complaint with either us or the Office for Civil Rights without fear of reprisal.

For More Information or to Report a Problem

If you have questions and would like additional information you may contact Ann C. Rogers, CEO.If you believe that your privacy rights have been violated, you may file a complaint with us. These complaints must be filed in writing on a form you may request it from Ann C. Rogers, CEO, and when completed should be returned to Ann C. Rogers, CEO You will not be treated differently if you make a complaint. You may also file a complaint with the regional office of the United States Department of Health and Human Services. You will not be penalized for filing a complaint with the federal government.

Regional Manager

Office for Civil Rights, Region V

U.S. Department of Health and Human Services

233 N. Michigan Ave., Suite 240

Chicago, IL 60601

Voice Phone (800) 368-1019

FAX (312) 886-1807

TDD (800) 537-7697

3. COMPLAINTS

You may complain to us or to the Secretary of Health and Human Services if you believe your privacy rights have been violated by us. You may file a complaint with us by calling our front desk at 612-332-4973. We will not retaliate against you for filing a complaint.
If you prefer to send a communication through the mail system, please use the following address:

People’s Center Clinics & Services
Attn: Privacy Officer – Confidential
425 20th Avenue South
Minneapolis, MN 55454