PRIVACY POLICY

This privacy policy sets out how Presbyterian Homes uses and protects any information that you give Presbyterian Homes when you use this website. Presbyterian Homes is committed to ensuring that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, then you can be assured that it will only be used in accordance with this privacy statement. Presbyterian Homes may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. This policy is effective from January 1st, 2018.

What We Collect

We may collect the following information:

  • Name and job title
  • Contact information including email address and phone number
  • Demographic information such as postcode, preferences, and interests
  • Other information relevant to customer surveys and/or offers

What We Do with the Information We Gather

We require this information to understand your needs and provide you with a better service.  By submitting any forms, you agree that your information may be used for the following reasons:

  • Internal record keeping
  • We may use the information to improve our products and services
  • We may periodically send promotional email about new products, special offers, or other information which we think you may find interesting using the email address which you have provided
  • From time to time, we may also use your information to contact you for market research purposes
  • We may use the information to contact you by phone or text message at the telephone number provided, even if you previously registered on a do not call registry to share information about our products and services
  • We may use the information to customize the website according to your interests

Confidentiality

We will never sell or share your information without your consent.

Security

We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure we have put in place suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect online.

How We Use Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyze web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes, and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

Links to Other Websites

Our website may contain links to enable you to visit other websites of interest easily. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

Controlling Your Personal Information

You may choose to restrict the collection or use of your personal information in the following ways:

  • If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us or calling us.

We will not sell, distribute, or lease your personal information to third parties unless we have your permission or are required by law. We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.

You may request details of personal information which we hold about you under the Data Protection Act 1998. A small fee will be payable. If you would like a copy of the information held on you please write to us or call us.

If you believe that any information we are holding on you is incorrect or incomplete, please write to or email us as soon as possible. We will promptly correct any information found to be incorrect.

Presbyterian Homes

8707 Skokie Boulevard, Suite 400

Skokie, IL 60077

651-631-6100

info.corporate@presbyterianhomes.org

NOTICE OF PRIVACY PRACTICES

Notice of Privacy Practices.

Your Information.  Your Rights.  Our Responsibilities.

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.

Presbyterian Homes is required by law to maintain the privacy of Protected Health Information (“PHI”) and to provide you with notice of our legal duties and privacy practices with respect to PHI.  References to “Presbyterian Homes,” “we,” and “our” include Presbyterian Homes and the members of its affiliated covered entity.  An affiliated covered entity is a group of organizations under common ownership or control who designate themselves as a single affiliated covered entity for purposes of compliance with the Health Insurance Portability and Accountability Act (“HIPAA”).  Presbyterian Homes, its employees, workforce members and members of the Presbyterian Homes affiliated covered entity who are involved in providing and coordinating health care are all bound to follow the terms of this Agreement.  The members of the Presbyterian Homes affiliated covered entity may share PHI with each other for the treatment, payment and healthcare operations of the affiliated covered entity and as permitted by HIPAA and this Agreement.  For a complete list of the members of Presbyterian Homes’ affiliated covered entity, please contact Presbyterian Homes’ Privacy Officer at (847) 979-3906.

Your Rights

You have the right to:

  • Get a copy of your paper or electronic medical record
  • Correct your paper or electronic medical record
  • Request confidential communication
  • Ask us to limit the information we share
  • Get a list of those with whom we’ve shared your information
  • Get a copy of this privacy notice
  • Choose someone to act for you
  • File a complaint if you believe your privacy rights have been violated

Your Choices

You have some choices in the way that we use and share information as we:

  • Tell family and friends about your condition
  • Provide disaster relief
  • Include you in a hospital directory
  • Provide mental health care
  • Market our services and sell your information
  • Raise funds

Our Uses and Disclosures

We may use and share your information as we:

•      Treat you

•      Run our organization

•      Bill for your services

•      Help with public health and safety issues

•      Do research

•      Comply with the law

•      Respond to organ and tissue donation requests

•      Work with a medical examiner or funeral director

•      Address workers’ compensation, law enforcement, and other government requests

•      Respond to lawsuits and legal actions

Your Rights

When it comes to your health information, you have certain rights.  This section explains your rights and some of our responsibilities to help you.

Get an electronic or paper copy of your medical record

  • You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
  • We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your medical record

  • You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
  • We may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communications

  • You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
  • We will say “yes” to all reasonable requests.

Ask us to limit what we use or share

  • You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
  • If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.

Get a list of those with whom we’ve shared information

  • You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
  • We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice

You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically.  We will provide you with a paper copy promptly.

Choose someone to act for you

  • If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
  • We will make sure the person has this authority and can act for you before we take any action

File a complaint if you feel your rights are violated

  • You can complain if you feel we have violated your rights by contacting us using the information on page 6.
  • You can file a 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 hhs.gov/ocr/privacy/hipaa/complaints/.
  • We will not retaliate against you for filing a complaint.
  • Your Choices

For certain health information, you can tell us your choices about what we share.  If you have a clear preference for how we share your information in the situations described below, talk to us.  Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

  • Share information with your family, close friends, or others involved in your care
  • Share information in a disaster relief situation
  • Include your information in a hospital directory

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest.  We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In these cases we never share your information unless you give us written permission:

  • Marketing purposes
  • Sale of your information
  • Most sharing of psychotherapy notes

In the case of fundraising:

  • We may contact you for fundraising efforts, but you can tell us not to contact you again.

Our Uses and Disclosures

How do we typically use or share your health information?

We typically use or share your health information in the following ways.

Treat you

We can use your health information and share it with other professionals who are treating you.

Example: A doctor treating you for an injury asks another doctor about your overall health condition.

Run our organization

We can use and share your health information to run our practice, improve your care, and contact you when necessary.

Example: We use health information about you to manage your treatment and services.

Bill for your services

We can use and share your health information to bill and get payment from health plans or other entities.

Example: We give information about you to your health insurance plan so it will pay for your services.

How else can we use or share your health information?

We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research.  We have to meet many conditions in the law before we can share your information for these purposes.  For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.

 Help with public health and safety issues

We can share health information about you for certain situations such as:

  • Preventing disease
  • Helping with product recalls
  • Reporting adverse reactions to medications
  • Reporting suspected abuse, neglect, or domestic violence
  • Preventing or reducing a serious threat to anyone’s health or safety

 Do research

We can use or share your information for health research.

 Comply with the law

We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.

 Respond to organ and tissue donation requests

We can share health information about you with organ procurement organizations.

 Work with a medical examiner or funeral director

We can share health information with a coroner, medical examiner, or funeral director when an individual dies.

 Address workers’ compensation, law enforcement, and other government requests

We can use or share health information about you:

  • For workers’ compensation claims
  • For law enforcement purposes or with a law enforcement official
  • With health oversight agencies for activities authorized by law
  • For special government functions such as military, national security, and presidential protective services

 Respond to lawsuits and legal actions

We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Our Responsibilities

  • We are required by law to maintain the privacy and security of your protected health information.
  • We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
  • We must follow the duties and privacy practices described in this notice and give you a copy of it.
  • We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time.  Let us know in writing if you change your mind.

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Changes to the Terms of this Notice

We can change the terms of this notice, and the changes will apply to all information we have about you.  The new notice will be available upon request, in our office, and on our web site.

Other Instructions for Notice

  • In addition, federal and state law require special privacy protections for certain highly confidential information about you (“Highly Confidential Information”), including the subset of your Protected Health Information that: (1) is maintained in psychotherapy notes; (2) is about mental illness, mental retardation and developmental disabilities; (3) is about alcohol or drug abuse or addiction; (4) is about HIV/AIDS testing, diagnosis or treatment; (5) is about communicable disease(s), including venereal disease(s); (6) is about genetic testing; (7) is about child abuse and neglect; (8) is about domestic abuse of an adult; or (9) is about sexual assault. In order for your Highly Confidential Information to be disclosed for a purpose other than those permitted by law, your written authorization is required.
  • Cheryl Miller, Director of Risk, Compliance & Legal; HIPAA Privacy Officer

Presbyterian Homes, 8707 Skokie Blvd, Suite 400 Skokie, IL 60077
(847) 979-3906; camiller@presbyterianhomes.org

The Effective Date of this Notice is September 23, 2013.

COMPLIANCE

Non-Discrimination Policy

As a recipient of Federal financial assistance, Presbyterian Homes does not exclude, deny benefits to, or otherwise discriminate against any person on the basis of race, color, national origin, disability, or age in admission to, participation in, or receipt of the services and benefits under any of its programs and activities, whether carried out by Presbyterian Homes directly or through a contractor or any other entity with which Presbyterian Homes arranges to carry out its programs and activities.

This statement is in accordance with the provisions of Title VI of the Civil Rights Act of 1964, Section 504 of the Rehabilitation Act of 1973, the Age Discrimination Act of 1975, and Regulations of the U.S. Department of Health and Human Services issued pursuant to these statutes at Title 45 Code of Federal Regulations Parts 80, 84, and 91.

In case of questions, please contact the Section 504 Coordinator at your campus, or the Chief Compliance Officer, who can be reached at:

Lake Forest Place                                        (847) 604-6701

Westminster Place                                       (847) 866-1650

The Moorings of Arlington Heights              (847) 956-4500

Corporate                                                    (847) 979-3906

TDD or State Relay Number:                      (800) 526-0844 (TTY only)

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Language Assistance Services for Limited English Proficiency

Presbyterian Homes adheres to Illinois Administrative Code for Long Term Care Facilities.  Per IL Administrative Code Title 77: Public Health Part 940 Language Assistance Services Code, a health facility shall ensure access to health care information and services for limited-English-speaking or non-English speaking residents or patients or deaf residents or patients.

For the purposes of this policy, a limited English speaking person is one who is unable to speak, read, write or understand the English language at a level that permits effective interaction with health center staff. All interpreters, translators and other aids needed to comply with this policy shall be provided without cost to the person being served, and patients/clients and their families will be informed of the availability of such assistance free of charge.

 

PROCEDURE

Facility:

  1. Posts at the entrance to the facility a notice to advise patients or residents and families of the availability of interpreters, procedure for obtaining an interpreter, and telephone number to call to file a complaint about interpreter service problems. (See Attachment ).

Director of Admissions:

  1. Prior to admission, asks the hospital referral source if the patient will require language assistance services.
  1. Verifies whether those services are available to the patient through family/friends/ or an established interpreter or if the facility needs to provide services.
  1. Notifies staff that a limited- or non-English speaking resident or severely hearing impaired resident will be admitted to the Health Center.

Some limited or non-English speaking persons may prefer or request to use a family member or friend as an interpreter.  However, family members or friends of the limited or non-English speaking person will not be used as interpreters unless specifically requested by that individual and after the limited or non-English speaking person has understood that an offer of an interpreter at no charge to the person has been made by the facility.  Such an offer and the response will be documented in the person’s file.  If the limited or non-English speaking person chooses to use a family member or friend as an interpreter, issues of competency of interpretation, confidentiality, privacy, and conflict of interest will be considered.  If the family member or friend is not competent or appropriate for any of these reasons, competent interpreter services will be provided to the limited or non-English speaking person.

 

Children and other clients/patients/residents will not be used to interpret, in order to ensure confidentiality of information and accurate communication.

Nursing:

  1. If possible, assigns caregiver(s) to limited or non- English speaking resident who speaks the resident’s dominant language.
  1. If an interpreter is not immediately available and/or until services are available, utilizes one of the following on- line products to interpret immediate questions or needs:
  • Google WordMonkey Translator (translates words or phrases from English into one of 43 different languages)
  • apples4the teacher.com/translate.html (accepts 30 characters & translates into ASL hand signs)
  • widgetbox.com/widget/asl-fingerspelling- translator
  1. Provides TDD/TTY telephone for hearing impaired resident if requested.

 

Social Worker :

  1. Identifies and records the resident’s primary language and dialect in the medical record.
  1. Arranges for interpreter services for the resident as needed.
  1. Prepares and maintains a list of interpreters who have been identified as proficient in sign language according to the Interpreter for the Deaf Licensure Act of 2007.
  1. Maintains a list of languages of the population of the geographical area served by the facility.

__________________________________________________________________

Grievance Procedure

A grievance is a significant complaint or concern arising from a denial of an applicant’s admission to one of Presbyterian Homes’ Health Care Centers. To assure fair treatment for all individuals denied admission to a Health Care Center, a grievance procedure is followed. This is based on the following:

Section 504 of the Rehabilitation Act prohibits discrimination based on handicap. In accordance with Section 504 Regulation, any program participant (patient, resident, etc.), participant representative, prospective participant who has reason to believe that he/she has been mistreated, denied services or discriminated against in any aspect of services or because of handicap may file a grievance. In order to implement this policy, this agency/facility has adopted an internal grievance procedure providing for prompt and equitable resolution of complaints alleging any action prohibited by the U.S. Department of Health and Human Services regulation (45 CFR Part 84) implementing Section 504 of the Rehabilitation Act of 1973 as amended (29 U.S.C. 794) Section 504 states, in part, that “no otherwise qualified handicapped individual…shall, solely by reasons of his handicap, be excluded from the participation in, be denied the benefits of, or be subjected to discrimination under any program or activity receiving Federal financial assistance…” The law and regulations may be examined in the offices of the Administrators of Health Services at Westminster Place, Lake Forest Place, or The Moorings of Arlington Heights, all of whom have been designated to coordinate the efforts of Presbyterian Homes to comply with the regulations.

PROCEDURE

Grievant

  1. Submits a grievance in writing, that contains the name and address of the person filing it, and briefly describes the action alleged to be prohibited by the regulations.
  1. Files a grievance in the office of the Section 504 Coordinator of the Health Care Center within 30 days after the person filing the grievance becomes aware of the action alleged to be prohibited by the regulation. This time frame may be waived by the Coordinator if extenuating circumstances exist that justify an extension.

The Section 504 Coordinator is each campus’ Health Care Administrator, and the corporate office’s Chief Compliance Officer, who can be reached at:

Lake Forest Place                                             (847) 604-6701

Westminster Place                                            (847) 866-1650

The Moorings of Arlington Heights                   (847) 956-4500

Corporate                                                          (847) 979-3906

Coordinator or designee

  1. Conducts such investigation of a grievance as may be appropriate to determine its validity. These rules require thorough investigations, affording all interested persons and their representatives, if any, an opportunity to submit evidence relevant to the grievance. Under section 504 of the Rehabilitation Act, 45 CFR 84.7(b), the agency/ facility need not process complaints from applicants for employment.
  1. Issues a written decision determining the validity of the grievance no later than 10 days after its filing.
  1. If the grievance has not been resolved at this point, forwards it to the Campus Executive Director, who shall have an additional 10 days to resolve the grievance.

Vice President /Campus Executive Director

  1. Notifies the grievant in writing of the decision and lists the evidence on which the decision is based.

Grievant

  1. The availability and use of this grievance procedure does not prevent a person from filing a complaint of discrimination on the basis of disability with the U.S. Department of Health and Human Services, Office for Civil Rights.

_____________________________________________________________________

Section 504 – Notice of Program Accessibility

Presbyterian Homes and all of its programs and activities are accessible to and useable by disabled persons, including persons who are deaf, hard of hearing, or blind, or who have other sensory impairments. Access features include:

  • Accessible parking designated specifically for disabled persons.
  • Access via ramps between parking areas and buildings.
  • Level access into first floor level with elevator access to all other floors.
  • Fully accessible offices, meeting rooms, bathrooms, public waiting areas, cafeteria, patient treatment areas, including examining rooms and resident rooms.
  • A full range of assistive and communication aids is made available to persons who are deaf, hard of hearing, or blind, or with other sensory impairments. There is no additional charge for such aids. Some of these aids include:
    • Qualified sign language interpreters for persons who are deaf or hard of hearing.
    • Readers and taped material for the blind and large print materials for the visually impaired.
    • Flash cards, alphabet boards and other communication boards.
    • Assistive devices for persons with impaired manual skills.

 

If you require any of the aids listed above, please make the admission staff aware of our need for assistance.

The regulation implementing Section 504 requires that an agency/facility “…adopt and implement procedures to ensure that interested persons, including persons with impaired vision or hearing, can obtain information as to the existence and location of services, activities, and facilities that are accessible to and usable by disabled persons.” (45 C.F.R. §84.22(f))