SourcePoint
CONFIDENTIALITY POLICY

SourcePoint staff will protect the clients/members Right to Privacy by holding in confidence all information obtained in the course of providing information, assistance, service and case management. Exception: Disclosure that is required by a court order law, such as adult or child abuse, neglect, exploitation and dependency. SourcePoint implements policies and procedures to accommodate client/member privacy rights as required by and specified in the Privacy Rule of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1996.

PURPOSE

1. Confidentiality protects the clients Right to Privacy.

2. To ensure the protection of confidentiality of information about persons referred to and enrolled in the SourcePoint Program or any program of SourcePoint.

3. To educate staff, clients, caregivers, volunteers and significant others regarding confidentiality, the release of information, and the limits of confidentiality.

PROCEDURE

1. SourcePoint staff will protect the clients Right to Privacy (see Attachment A) and maintain client confidentiality by:

a. Obtaining written permission/informed consent from the client or legal
representative for disclosure of information to other professional and agencies outside the SENIOR CHOICES network, or as permitted by the Privacy Rule of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act (see Attachments B & C and the Notice of Privacy Practice).

b. Exercising professional discretion in releasing only the information about the
client that is relevant to the problem at hand both within and outside the network.

c. Informing the client fully about the limits of confidentiality in a given situation,
the purpose for which information is obtained, and how it may be used.

d. Asking the client what they would like shared with significant others.

e. Educating the client, legal representative, caregivers, staff, public, and significant others regarding confidentiality, the release of information, and the limits of confidentiality.

f. Holding interviews in private. The client should have the opportunity to be interviewed alone.
g. Affording clients reasonable access to records concerning them and protecting the confidences of others in the record.


h. Obtaining informed consent of clients before taping, recording or permitting a
third party observation of their activities.

2. COA shall maintain a record system which includes, but is not limited to:

a. Policies and procedures to govern the record system and procedures for all
agency staff and volunteer or contracting case management agency.

b. Maintaining records on the agency?s or contracting agency?s premise in
locked storage areas.

c. Provision for the retention and storage of client records for at least six (6)
years from the date of the last service to the client, in the locked storage area.

d. Provision for the retention and storage of all client records in the event the
agency discontinues operation.

e. All staff and volunteers shall sign a confidentiality statement.

f. Any written document that has client information on it shall be shred, before it is discarded.

3. No information is to be disclosed to any other individual, group or organization that is not included within this policy without a signed release of information on file specifying that the requestor is designated on a signed release of information form as having permission to receive such. This includes, but is not limited to law enforcement, family members, neighbors, friends or other service providers.

4. Any request for information made by an individual, group or organization about an alleged or actual client, shall be advised that we are unable to divulge any information either confirming or denying that an individual is a client, without written consent by that person.

5. All media representatives are to be referred to the Executive Director and a ?No Comment? response is to be given, regardless of whether the individual is a client or not.

6. As stated in the Client Privacy Rights Policy of the HIPAA Personnel Policies and Procedures, Clients served by the SourcePoint have the following rights with respect to the privacy of their health information.

- to receive a paper copy of the Councils Notice of Privacy Practices;
- to lodge complaints about the Councils privacy practices;
- to request restrictions on the uses and disclosures of health information;
- to request to receive confidential communication;

- to access their protected health information for inspection and/or copying;
- to amend their health care information; and
- to request an accounting of disclosures of health information.


I have read the SourcePoint Confidentiality Policy and agree to follow the procedures outlined. I understand that should I fail to comply with this policy, disciplinary action may be taken, including termination of employment