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Notice of Privacy Practices

This Notice of Privacy Practices (“Notice”) describes how your protected health information may be used and disclosed and how you can obtain access to your protected health information. Please review it carefully.


This Notice describes the privacy practices of Public Health Management Corporation and its subsidiaries (collectively referenced herein as “PHMC”). PHMC is required by law to maintain the privacy of your protected health information and to provide you with this Notice describing our privacy practices. Protecting the privacy and confidentiality of information about our clients is very important to PHMC. Accordingly, PHMC strives to comply with all confidentiality requirements applicable to the care and services PHMC provides.

Protected Health Information (“PHI”) means individually identifiable health information (for example – Social Security Numbers, your addresses, medical record numbers, driver’s licenses, etc.), as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) that is created or received by PHMC and that relates to the past, present, or future physical or mental health condition of an individual; the provision of health care services to an individual; or the past, present, or future payment for the provision of health care services to an individual; and that identifies the individual or for which there is a reasonable basis to believe the information can be used to identify the individual. PHI may be subject to other confidentiality laws under Federal law, such as the provisions of the Federal Confidentiality of Substance Use Disorder Records regulations, and under Pennsylvania law, through the Mental Health Procedures Act.

As used in this Notice, “you” or “your” generally means the legally recognized personal representative of a person or the parent or foster parent of a minor under 18 years old. There are certain situations when minor patients may make decisions about their own care. In these situations, the minor patient controls the release of their medical information and has the rights described in this Notice. For example, minors age 14 years or older can consent to treatment for mental health disorders, sexually transmitted diseases, substance use disorders, HIV and pregnancy.

PHMC may change this Notice as required by law or in response to internal operational or other issues that require PHMC to do so. The revised Notice will be provided to you through the notices prominently posted in PHMC premises and on the PHMC website.


PHMC is permitted or required to use and/or disclose your health information for various purposes. PHMC may use and/or disclose your PHI for the purposes described below:

A. Treatment: PHMC may use and/or disclose your PHI in order to ensure that you receive proper and needed health care services without your written consent, except for highly confidential information. For example, PHMC may disclose your health information to other health care providers (e.g. social workers, therapists, nurses, and related professionals, etc.) for treatment or to arrange health care, social services or other related services to PHMC programs involved in your care. In addition, PHMC may contact you to schedule appointments or provide you with information about additional treatment alternatives.

B. Payment: PHMC may use and/or disclose your PHI in order to obtain payment for the treatment and/or services we provided to you. For example, PHMC may use and/or disclose your PHI to request payment from your health insurer or to receive funding for the treatment and/or services provided to you by PHMC.

C. Operations: PHMC may use and/or disclose your PHI for our internal operations. Operations are defined as those activities that are necessary to run our programs, maintain licensure and accreditation, obtain funding and to make sure that our patients receive quality care and/or services. For example, PHMC may use your PHI to review the quality of treatment/services provided to you, and/or treatment and services coordinated for you.

1. Health Information Exchange:

  • PHMC participates with one or more secure health information organization networks (each, an “HIO”), including an HIO called “HealthShare Exchange of Southeastern Pennsylvania, Inc., (“HSX”), which makes it possible for PHMC to share your PHI electronically through a secure connected network.
  • PHMC may share or disclose your PHI to HSX and other secure HIOs, including HIOs contracted with the Commonwealth of Pennsylvania, and even HIOs in other states.
  • Other health care providers, including physicians, hospitals and other health care facilities, that are also connected to the same HIO network as PHMC can access your PHI for treatment, payment and other authorized purposes, to the extent permitted by law.
  • You have the right to “opt-out” or decline to participate in having PHMC share your PHI through networked HIOs.
  • If you choose to opt-out of data-sharing through HIOs, PHMC will no longer share your PHI through an HIO network. However, it will not prevent your PHI, which has already been shared through an HIO network, from otherwise being accessed and released to authorized individuals in accordance with the law, including being transmitted through other secure mechanisms (i.e., by fax or an equivalent technology).

D. Business Associates/Qualified Services Organizations: Certain aspects and components of the services PHMC offers are provided through contracts with external providers and/or organizations known as Business Associates (“BAs”) or Qualified Service Organizations (“QSOs”). An example of a BA/QSO is an entity that has been contracted by PHMC to perform certain functions and/or services on PHMC’s behalf. These services include data processing, billing, legal, accounting, or other professional services. The BA/QSO can only use your PHI to perform these functions and a QSO may not redisclose your PHI.


PHMC may use and/or disclose your PHI for any purpose allowed or required by law. For example, PHMC may be required by Federal, State or local law to use or disclose your PHI to respond to a court order or disclose PHI to the proper authorities for law enforcement purposes. We will not sell your PHI.

  1. Government Oversight Agencies: PHMC may use and/or disclose your PHI if authorized by law to a government oversight agency conducting audits, investigations, or civil or criminal proceedings. For example, we may use and/or disclose your PHI to Federal, State, or City regulatory agencies that conduct audits of medical assistance payments for services provided by PHMC.
  2. Prevention of Violence: If PHMC believes that you are a victim or perpetrator of abuse, neglect or domestic violence, PHMC may disclose your PHI to a governmental authority, including a social service or protective services agency, authorized to receive reports of abuse, neglect, domestic violence or other similar actions.
  3. Public Health Activities: PHMC may use and/or disclose certain PHI for public health initiatives, such as reporting of disease, injury, and death, and for public health investigations. PHMC may use and/or disclose your PHI to coroners, medical examiners, funeral directors or other related professionals consistent with legal regulations.
  4. Aversion of a Serious Threat to Public Health or Safety: PHMC may use and/or disclose PHI about you when necessary to prevent or reduce a serious threat to your health and safety, or that of the public or another person. Any disclosure, however, would only be made to an agency or person able to help prevent the threatened or impending harm.
  5. Military Purposes: PHMC may use and/or disclose your PHI if you are a member of the military as required by armed forces services, and may also disclose your PHI for other specialized government functions, such as national security or intelligence activities.
  6. Worker’s Compensation: PHMC may use and/or disclose your PHI to workers’ compensation agencies or similar programs that provide benefits for work-related injuries or illnesses sustained at work as required and permitted by law.
  7. Law Enforcement: PHMC may share your PHI, with some limitations, with police or other law enforcement officials when sharing is allowed or required by law. For example, PHMC may report an incident of a crime on our premises, respond to a warrant, summons or similar legal process.
  8. Secretary of the Department of Health and Human Services: PHMC will, if required by law, release your PHI to the Secretary of the U.S. Department of Health and Human Services for HIPAA enforcement.


A. Highly Confidential Information: The Federal provisions of the Confidentiality of Substance Use Disorder Records, Pennsylvania’s Mental Health Procedures Act, and certain laws related to sexually transmitted diseases are among those special laws where PHI is granted enhanced privacy protections. This includes PHI:

  1. Maintained in psychotherapy notes;
  2. Documenting mental health and developmental disabilities services;
  3. Referring to drug and alcohol abuse, prevention, treatment and referral; and
  4. Relating to HIV/AIDS testing, diagnosis or treatment and other sexually transmitted diseases.

Generally, PHMC must obtain your written authorization or have a court order to release this type of information.


Public Health Management Corporation is part of an organized health care arrangement, including participants in OCHIN. A current list of OCHIN participants is available at www.ochin.org. As a business associate of Public Health Management Corporation, OCHIN supplies information technology and related services to Public Health Management Corporation and other OCHIN participants. OCHIN also engages in quality assessment and improvement activities on behalf of its participants. For example, OCHIN coordinates clinical review activities on behalf of participating organizations to establish best practice standards and assess clinical benefits that may be derived from the use of electronic health record systems. OCHIN also helps participants work collaboratively to improve the management of internal and external patient referrals. Your personal health information may be shared by Public Health Management Corporation with other OCHIN participants or a health information exchange only when necessary for medical treatment or for the health care operations purposes of the organized health care arrangement. Health care operations can include, among other things, geocoding your residence location to improve the clinical benefits you receive.

The personal health information may include past, present and future medical information, as well as information outlined in the Privacy Rules. The information, to the extent disclosed, will be disclosed consistent with the Privacy Rules or any other applicable law as amended from time to time. You have the right to change your mind and withdraw this consent. However, the information may have already been provided as allowed by you. This consent will remain in effect until revoked by you in writing. If requested, you will be provided a list of entities to which your information has been disclosed.


  1. Right to Inspect and Copy Your Protected Health Information: You may request to see and receive copies of your medical/treatment/service and billing records. To do so, please submit a written request to the appropriate PHMC program or subsidiary’s records department.
  2. Right to Request Amendment: You have the right to request that PHMC amend the PHI maintained about you. To request an amendment, your request must be made in writing and submitted to the PHMC Privacy Officer. You must state in your request why you believe that the PHI is incorrect or incomplete. PHMC is not obligated to make requested amendments but will give each request careful consideration. If PHMC denies your request, you have the right to provide a short statement to be placed with your PHI or to have your request for amendment attached to your PHI.
  3. Right to an Accounting of Disclosures: You have the right to request a record of certain disclosures of your PHI. Your request may cover any disclosure made in the six years prior to the date of your request. However, PHMC is not required to give you a record of disclosure that occurred prior to April 14, 2003.
  4. Right to Request Restrictions: You have a right to request additional restrictions on PHMC’s use and disclosure of your PHI. For example, you may request that PHMC not disclose your PHI to your spouse. Your request must describe in detail the restriction you are requesting. HIPAA does not require PHMC to agree to your request, but PHMC will accommodate reasonable requests when appropriate.
  5. Right to Request Confidential Communications: You have the right to request that PHMC communicate with you about PHI in a certain way or at a certain location. For example, you can ask that PHMC only contact you at work or by mail. Your request must specify how or where you wish to be contacted. To request confidential communications, you must make your request in writing to our office. PHMC will not ask you the reason for your request and will accommodate all reasonable requests.
  6. Right to Revoke an Authorization: You have the right to change your mind after you sign an Authorization for Release of Information (“ROI”) that allows PHMC to release your PHI. ROI forms are available upon request from a PHMC program. You may cancel your authorization at any time by submitting a written request. Your request will be effective when PHMC receives it, and PHMC will not release any more information based upon that authorization. PHMC cannot take back information it has already released.
  7. Right to Paper Copy of this Notice: You have the right to get a paper copy of the current version of this Notice. A copy of this Notice is on the PHMC Health Network website at: www.phmchealthnetwork.org.
  8. Right to Receive Notification of a Breach of Your Information: You have the right to and will receive written notification if, after evaluation under standards established by law, it is determined that your PHI has been breached.

If you desire further information about your privacy rights, are concerned that your privacy rights have been violated or disagree with a decision made about access to your PHI, you may contact our Privacy Officer at:

Privacy Officer
Public Health Management Corporation
Division of Total Quality Management
Center Square East, LM 15
1500 Market Street
Philadelphia, PA 19102

Additionally, you may also file a written complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/hipaa/filing-a-complaint/index.html. PHMC will not retaliate against you for filing a complaint.


  1. Effective Date: This Notice is effective as of April 14, 2003; revised on November 8, 2022.
  2. The Right to Change this Notice: PHMC may change the terms of this Notice at any time. If PHMC revises this Notice, the revised Notice will be posted online at: www.phmchealthnetwork.org. You may also obtain a revised Notice by contacting the PHMC Privacy Officer.