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Policies
How
are Appointments Scheduled?
The office attempts to schedule appointments at your
convenience and when time is available. Preschool children should be seen in the
morning because they are fresher and we can work more slowly with the child for
their comfort. School children with a lot of work to be done should be seen in
the morning for the same reason. Dental appointments are an excused absence.
Missing school can be kept to a minimum when regular dental care is continued.
Since appointed times are reserved exclusively for each patient we ask that you
please notify our office 24 hours in advance of your scheduled appointment time
if you are unable to keep your appointment. Another patient who needs our care
could be scheduled if we have sufficient time to notify them. We realize that
unexpected things can happen, but we ask for your assistance in this regard.
Do I
Stay with My Child During the Visit?
We ask that you allow your child to accompany our staff through the dental
experience. We are all highly experienced in helping children overcome anxiety.
Separation anxiety is not uncommon in children, so please try not to be
concerned if your child exhibits some negative behavior. This is normal and
will soon diminish. Studies and experience have shown that most children over
the age of 3 react more positively when permitted to experience the dental visit
on their own and in an environment designed for children.
What
About Finances?
Payment for professional services is due at the time dental treatment is
provided. Every effort will be made to provide a treatment plan which fits your
timetable and budget, and gives your child the best possible care. We accept
cash, personal checks, debit cards and most major credit cards.
Our
Office Policy Regarding Dental Insurance
If we have received all of your insurance information on
the day of the appointment, we will be happy to file your claim for you. You
must be familiar with your insurance benefits, as we will collect from you the
estimated amount insurance is not expected to pay. By law your insurance company
is required to pay each claim within 30 days of receipt. We file claims for most
insurance companies so your insurance company will receive each claim within
days of the treatment. You are responsible for any balance on your account after
30 days, whether insurance has paid or not. If you have not paid your balance
within 60 days a finance charge of 1.5% or $5, whichever is greater, will be
added to your account each month until paid. We will be glad to send a refund to
you once insurance has paid us.
PLEASE UNDERSTAND that we file dental insurance as a
courtesy to our patients. We do not have a contract with your insurance company,
only you do. We are not responsible for how your insurance company handles its
claims or for what benefits they pay on a claim. We can only assist you in
estimating your portion of the cost of treatment, we at no time guarantee what
your insurance will or will not do with each claim. We also can not be
responsible for any errors in filing your insurance, once again we file claims
as a courtesy to you.
Fact 1 - NO INSURANCE PAYS 100% OF ALL PROCEDURES
Dental insurance is meant to be an aid in receiving dental care. Many patients
think that their insurance pays 90%-100% of all dental fees. This is not true!
Most plans only pay between 50%-80% of the average total fee. Some pay more,
some pay less. The percentage paid is usually determined by how much you or your
employer has paid for coverage or the type of contract your employer has set up
with the insurance company.
Fact 2 - BENEFITS ARE NOT DETERMINED BY OUR OFFICE
You may have noticed that sometimes your dental insurer reimburses you or the
dentist at a lower rate than the dentist's actual fee. Frequently, insurance
companies state that the reimbursement was reduced because your dentist's fee
has exceeded the usual, customary, or reasonable fee ("UCR") used by the
company.
A statement such as this gives the impression that any fee greater than the
amount paid by the insurance company is unreasonable or well above what most
dentists in the area charge for a certain service. This can be very misleading
and simply is not accurate.
Insurance companies set their own schedules and each company uses a different
set of fees they consider allowable. These allowable fees may vary widely
because each company collects fee information from claims it processes. The
insurance company then takes this data and arbitrarily chooses a level they call
the "allowable" UCR Fee. Frequently this data can be three to five years old and
these "allowable" fees are set by the insurance company so they can make a net
20%-30% profit.
Unfortunately, insurance companies imply that your dentist is "overcharging"
rather than say that they are "underpaying" or that their benefits are low. In
general, the less expensive insurance policy will use a lower usual, customary,
or reasonable (UCR) figure.
Fact 3 - DEDUCTIBLES & CO-PAYMENTS MUST BE CONSIDERED
When estimating dental benefits, deductibles and percentages must be considered.
To illustrate, assume the fee for service is $150.00. Assuming that the
insurance company allows $150.00 as its usual and customary (UCR) fee, we can
figure out what benefits will be paid. First a deductible (paid by you), on
average $50, is subtracted, leaving $100.00. The plan then pays 80% for this
particular procedure. The insurance company will then pay 80% of $100.00, or
$80.00. Out of a $150.00 fee they will pay an estimated $80.00 leaving a
remaining portion of $70.00 (to be paid by the patient). Of course, if the UCR
is less than $150.00 or your plan pays only at 50% then the insurance benefits
will also be significantly less.
MOST IMPORTANTLY, please keep us informed of any insurance
changes such as policy name, insurance company address, or a change of
employment.
Dr. Rick Meyers
HEALTH INFORMATION PRIVACY
POLICIES & PROCEDURES
These Health Information Privacy Policies & Procedures implement our obligations
to protect the privacy of individually identifiable health information that we
create, receive, or maintain as a healthcare provider.
We
implement these Health Information Privacy Policies and Procedures as a matter
of sound business practice; to protect the interests of our patients; and to
fulfill our legal obligations under the Health Insurance Portability and
Accountability Act of 1996 ("HIPAA"), its implementing regulations at 45 CFR
Parts 160 and 164 (65 Fed. Reg 82462 (Dec. 28, 2000)) ("Privacy Rules"), as
amended (67 Fed. Reg. 53182 [Aug. 14, 2002]), and state law that provides
greater protection or rights to patients than the Privacy Rules.
As
a member of our workforce or as our Business Associate, you are obligated to
follow these Health Information Privacy Policies & Procedures faithfully.
Failure to do so can result in disciplinary action, including termination of
your employment or affiliation with us.
These Policies & Procedures address the basics of HIPAA and the Privacy Rules
that apply in our dental practice. They do not attempt to cover everything in
the Privacy Rules. The Policies & Procedures sometimes refer to forms we use to
help implement the policies and to the Privacy Rules themselves when added
detail may be needed.
Please note that
while the Privacy Rules speak in terms of "individual" rights and actions, these
Policies & Procedures use the more familiar word "patient" instead; "patient"
should be read broadly to include prospective patients, patients of record,
former patients, their authorized representatives, and any other "individuals"
contemplated in the Privacy Rules.
If you have
questions or doubts about any use or disclosure of individually identifiable
health information or about your other obligations under these Health
Information Privacy Policies & Procedures, the Privacy Rules or other federal or
state law, please contact our office. This policy was adopted effective 4/14/03
1. General Rule: No Use or Disclosure
Our dental office must not use or disclose protected health information (PHI),
except as these Privacy Policies & Procedures permit or require.
2. Acknowledgement and Optional Consent
Our dental office
will make a good faith effort to obtain a written acknowledgement of receipt of
our Notice of Privacy Practices (see Section 9) from a patient before we use or
disclose his or her protected health information (PHI) for treatment, to obtain
payment for that treatment, or for our healthcare operations (TPO).
Our dental office’s use or disclosure of PHI for our payment activities and
healthcare operations may be subject to the minimum necessary requirements (see
Section 7).
Our dental office
will become familiar with our state’s privacy laws. If required by our state
law, or as directed by the dentist, we will also seek Consent from a patient
before we use or disclose PHI for TPO purposes – in addition to obtaining an
Acknowledgement of receipt of our Notice of Privacy Practices.
a) Obtaining
Consent – If
consent is to be obtained, upon the individual’s first visit as a patient (or
next visit if already a patient), our dental office will request and obtain the
patient’s written Consent for our use and disclosure of the patient’s PHI for
treatment, payment, and healthcare operations.
Any consent we
obtain must be on our Consent form, which we may not alter in any way. Our
dental office will include the signed Consent form in the patient’s chart.
b) Exceptions
– Our dental
office does not have to obtain the patient’s Consent in emergency treatment
situations; when treatment is required by law; or when communications barriers
prevent consent.
c) Consent
Revocation – A
patient from whom we obtain consent may revoke it at any time by written notice.
Our dental office will include the revocation in the patient’s chart. There is
space at the bottom of our Consent form where the patient can revoke the
consent.
e) Applicability –
Consent for use or disclosure of PHI should not be confused with informed
consent for dental treatment. This section applies to our practice.
3. Authorization
In some cases we
must have proper, written Authorization from the patient (or the patient’s
personal representative) before we use or disclose a patient’s PHI for any
purpose (except for TPO purposes) or as permitted or required without consent or
authorization (see Sections 3, 4, or 5).
Our dental office will use the Authorization form. We will always act in strict
accordance with an Authorization.
a)
Authorization Revocation – A patient may revoke an authorization at any time by
written notice. Our dental office will not rely on an Authorization we know has
been revoked.
b)
Authorization from Another
Provider – Our dental office will use or disclose PHI as permitted by a valid
Authorization we receive from another healthcare provider.
Our dental office may rely on that covered entity to have requested only the
minimum necessary protected PHI. Therefore, our dental office will not make our
own "minimum necessary" determination, unless we know that the Authorization is
incomplete, contains false information, has been revoked, or has expired.
c)
Authorization Expiration – Our dental office will not rely on an Authorization
we know has expired.
4. Oral Agreement
Our dental office may use or disclose a patient’s PHI with the patient’s Oral
Agreement or if the patient is unavailable subject to all applicable
requirements.
Our dental office
may use professional judgment and our experience with common practice to make
reasonable inferences of the patient’s best interest in allowing a person to act
on behalf of the patient to pick up dental/medical supplies, X-rays, or other
similar forms of PHI.
5. Permitted Without Acknowledgement, Consent Authorization or Oral Agreement
Our dental office
may use or disclose a patient’s PHI in certain situations, without Authorization
or Oral Agreement. In our dental office, these disclosures are not likely to be
frequent.
a) Verification of
Identity
– Our dental office will always verify the identity of any patient, and the
identity and authority of any patient’s personal representative, government or
law enforcement official, or other person, unknown to us, who requests PHI
before we will disclose the PHI to that person.
Our dental office will obtain appropriate identification and, if the person is
not the patient, evidence of authority. Examples of appropriate identification
include photographic identification card, government identification card or
badge, and appropriate document on government letterhead. Our dental office will
document the incident and how we responded.
b) Uses or
Disclosures Permitted under this Section 5
– The situations in which our dental office is permitted to use or disclose PHI
in accordance with the procedures set out in this Section 5 are listed below.
·
Our dental
office may disclose a patient’s PHI to that patient on request.
·
Our dental
office may disclose to a patient’s personal representative PHI relevant to the
representative capacity. We will not disclose to a personal representative we
reasonably believe may be abusive to a patient any PHI we reasonably believe may
promote or further such abuse.
·
Our dental
office will not use or disclose a patient’s PHI for fundraising purposes without
the patient’s Authorization.
·
Our dental
office will not use or disclose PHI for marketing without a patient’s
Authorization unless the marketing is in the form of a promotional gift of
nominal value that we provide, or face-to-face communications between us and the
patient.
·
Our dental
office may use or disclose PHI in the following types of situations, provided
procedures specified in the Privacy Rules are followed:
1.
For public
health activities;
2.
To health
oversight agencies;
3.
To
coroners, medical examiners, and funeral directors;
4.
To
employers regarding work-related illness or injury;
5.
To the
military;
6.
To federal
officials for lawful intelligence, counterintelligence, and national security
activities;
7.
To
correctional institutions regarding inmates;
8.
In
response to subpoenas and other lawful judicial processes;
9.
To law
enforcement officials;
10.
To report
abuse, neglect, or domestic violence;
11.
As
required by law;
12.
As part of
research projects; and
13.
As
authorized by state worker’s compensation laws.
6. Required Disclosures
Our dental office will disclose protected health information (PHI) to a patient
(or to the patient’s personal representative) to the extent that the patient has
a right of access to the PHI (see Section 10); and to the U.S. Department of
Health and Human Services (HHS) on request for complaint investigation or
compliance review.
Our dental office will use the disclosure log to document each disclosure we
make to HHS.
7. Minimum Necessary
Our dental office
will make reasonable efforts to disclose, or request of another covered entity,
only the minimum necessary protected health information (PHI) to accomplish the
intended purpose.
There is no minimum
necessary requirement for disclosures to or requests by one another in our
dental office or by a healthcare provider for treatment; permitted or required
disclosures to, or for disclosure requested and authorized by, a patient;
disclosures to HHS for compliance reviews or complaint investigations;
disclosures required by law; or uses or disclosures required for compliance with
the HIPAA Administrative Simplification Rules.
a) Routine or
Recurring Requests or Disclosures
– Our dental office will follow the policies and procedures that we adopt to
limit our routine or recurring requests for our disclosures of PHI to the
minimum reasonably necessary for the purpose.
b) Non-Routine or
Non-Recurring Requests or Disclosures
– No non-routine or non-recurring request for or disclosure of PHI will be made
until it has been reviewed on a patient-by-patient basis against our criteria to
ensure that only the minimum necessary PHI for the purpose is requested or
disclosed.
c) Other’s Requests
– Our dental office will rely, if reasonable for the situation, on a request to
disclose PHI being for the minimum necessary, if the requester is: (a) a covered
entity; (b) a professional (including an attorney or accountant) who provides
professional services to our practice, either as a member of our workforce or as
our Business Associate, and who represents that the requested information is the
minimum necessary; (c) a public official who represents that the information
requested is the minimum necessary; or (d) a researcher presenting appropriate
documentation or making appropriate representations that the research satisfies
the applicable requirements of the Privacy Rules.
d) Entire Record
– Our dental office will not use, disclose, or request an entire record, except
as permitted in these Policies & Procedures or standard protocols that we adopt
reflecting situations when it is necessary.
e) Minimum Necessary
Workforce Use
– Our dental office will use only the minimum necessary PHI needed to perform
our duties.
8. Business Associates
Our dental office
will obtain satisfactory assurance in the form of a written contract that our
Business Associates will appropriately safeguard and limit their use and
disclosure of the protected health information (PHI) we disclose to them.
These Business
Associate requirements are not applicable to our disclosures to a healthcare
provider for treatment purposes. The Business Associate Contract Terms document
contains the terms that federal law requires be included in each Business
Associate Contract.
a.) Breach by
Business Associate
– If our dental office learns that a Business Associate has materially breached
or violated its Business Associate Contract with us, we will take prompt,
reasonable steps to see that the breach or violation is cured.
If the Business
Associate does not promptly and effectively cure the breach or violation, we
will terminate our contract with the Business Associate, or if contract
termination is not feasible, report the Business Associate’s breach or violation
to the U.S. Department of Health and Human Services (HHS).
9. Notice of Privacy Practices
Our dental office
will maintain a Notice of Privacy Practices as required by the Privacy Rules.
a) Our Notice
– Our dental office will use and disclose PHI only in conformance with the
contents of our Notice of Privacy Practices. We will promptly revise a Notice of
Privacy Practices whenever there is a material change to our uses or disclosures
of PHI to legal duties, to the patients’ rights or to other privacy practices
that render the statements in that Notice no longer accurate.
Form 1, Notice of Privacy Practices, found in this Privacy Kit, contains the
terms that federal law requires.
b) Distribution of
Our Notice – Our
dental office will provide our Notice of Privacy Practices to any person who
requests it, and to each patient no later than the date of our first service
delivery after April 14, 2003.
Our dental office
will have our Notice of Privacy Practices available for patients to take with
them. We will also post our Notice of Privacy Practices in a clear and prominent
location where it is reasonable to expect patients seeking services from us will
be able to read the Notice.
c) Acknowledgement
of Notice – Our
dental office will make a good faith effort to obtain from the patient a written
Acknowledgement of receipt of our Notice of Privacy Practices.
Our dental office
shall use Form 2, Acknowledgement of Receipt of Notice of Privacy Practices,
found in this Privacy Kit, to obtain the Acknowledgement. If we cannot obtain
written Acknowledgement from the patient, we will use the form to document our
attempt and the reason why written Acknowledgement was not signed by the
patient.
10. Patients’ Rights
Our dental office will honor the rights of patients regarding their PHI.
a) Access
– With rare exceptions, our dental office must permit patients to request access
to the PHI we or our Business Associates hold.
No PHI will be
withheld from a patient seeking access unless we confirm that the information
may be withheld according to the Privacy Rules. We may offer to provide a
summary of the information in the chart. The patient must agree in advance to
receive a summary and to any fee we will charge for providing the summary. Our
dental office will contact our Business Associates to retrieve any PHI they may
have on the patient.
b) Amendment
– Patients have the right to request to amend their PHI and other records for as
long as our dental office maintains them.
Our dental office may deny a request to amend PHI or records if: (a) we did not
create the information (unless the patient provides us a reasonable basis to
believe that the originator is not available to act on a request to amend); (b)
we believe the information is accurate and complete; or (c) we do not have the
information.
Our dental office
will follow all procedures required by the Privacy Rules for denial or approval
of amendment requests. We will not, however, physically alter or delete existing
notes in a patient’s chart. We will inform the patient when we agree to make an
amendment, and we will contact our Business Associates to help assure that any
PHI they have on the patient is appropriately amended. We will contact any
individuals whom the patient requests we alert to any amendment to the patient’s
PHI. We will also contact any individuals or entities of which we are aware that
we have sent erroneous or incomplete information and who may have acted on the
erroneous or incomplete information to the detriment of the patient.
When we deny a request for an amendment, we will mark any future disclosures of
the contested information in a way acknowledging the contest.
c) Disclosure
Accounting – Patients have the right to an accounting of certain disclosures our
dental office made of their PHI within the 6 years prior to their request. Each
disclosure we make, that is not for treatment payment or healthcare operations,
must be documented showing the date of the disclosure, what was disclosed, the
purpose of the disclosure, and the name and (if known) address of each person or
entity to whom the disclosure was made. The Authorization or other documentation
must be included in the patient’s record. We use the patient’s chart to track
each disclosure of PHI as needed to enable us to fulfill our obligation to
account for these disclosures.
We
are not required to account for disclosures we made: (a) before April 14, 2003;
(b) to the patient (or the patient’s personal representative); (c) to or for
notification of persons involved in a patient’s healthcare or payment for
healthcare; (d) for treatment, payment, or healthcare operations; (e) for
national security or intelligence purposes; (f) to correctional institutions or
law enforcement officials regarding inmates; or (g) according to an
Authorization signed by the patient or the patient’s representative; (h)
incident to another permitted or required use disclosure.
We will temporarily
suspend the accounting of any disclosure when requested to do so pursuant
according to the Privacy Rules by health oversight agencies or law enforcement
officials. We may charge for any accounting that is more frequent than every 12
months, provided the patient is informed of the fee before the accounting is
provided. We will contact our Business Associates to assure we include in the
accounting any disclosures made by them for which we must account.
d) Restriction on
Use or Disclosure
– Patients have the right to request our dental office to restrict use or
disclosure of their PHI, including for treatment, payment, or healthcare
operations. We have no obligation to agree to the request, but if we do, we will
comply with our agreement (except in an appropriate dental/medical emergency).
We may terminate an
agreement restricting use or disclosure of PHI by a written notice of
termination to the patient. We will contact our Business Associates whenever we
agree to such a restriction to inform the Business Associate of the restriction
and its obligations to abide by the restriction. We will document in the
patient’s chart any such agreed to restrictions.
e) Alternative
Communications –
Patients have the right to request us to use alternative means or alternative
locations when communicating PHI to them. Our dental office will accommodate a
patient’s request for such alternative communications if the request is
reasonable and in writing.
Our dental office will inform the patient of our decision to accommodate or deny
such a request. If we agree to such a request, we will inform our Business
Associates of the agreement and provide them with the information necessary to
comply with the agreement.
f) Applicability
– Our dental office will be aware of and respect these patients’ rights
regarding their PHI, even though in most situations patients are unlikely to
exercise them.
11. Staff Training and Management, Complaint Procedures, Data Safeguards,
Administrative Practices
a) Staff Training
and Management
* Training
– Our dental office will train all members of our workforce in these Privacy
Policies & Procedures, as necessary and appropriate for them to carry out their
functions. We will complete the privacy training of our existing workforce by
April 14, 2003.
After April 14, 2003, our dental office will train each new staff member within
a reasonable time after the member starts. We will also retain each staff member
whose functions are affected either by a material change in our Privacy Policies
and Procedures or in the member’s job functions, within a reasonable time after
the change.
Form 7, Staff Review
of Policies and Procedures, can be used to have workforce members acknowledge
they have received and read a copy of these Policies and Procedures.
*Discipline and
Mitigation
– Our dental office will develop, document, disseminate, and implement
appropriate discipline policies for staff members who violate our Privacy
Policies & Procedures, the Privacy Rules, or other applicable federal or state
privacy law.
Staff members who violate our Privacy Policies & Procedures, the Privacy Rules
or other applicable federal or state privacy law will be subject to disciplinary
action, possibly up to and including termination of employment.
b) Complaints
– Our dental office will implement procedures for patients to complain about our
compliance with our Privacy Policies and Procedures or the Privacy Rules. We
will also implement procedures to investigate and resolve such complaints.
The Complaint form
can be used by the patient to lodge the complaint. Each complaint received must
be referred to management immediately for investigation and resolution. We will
not retaliate against any patient or workforce member who files a Complaint in
good faith.
c) Data Safeguards
– Our dental office will "add to" and strengthen these Privacy Policies &
Procedures with such additional data security policies and procedures as are
needed to have reasonable and appropriate administrative, technical, and
physical safeguards in place to ensure the integrity and confidentiality of the
PHI we maintain.
Our dental office will take reasonable steps to limit incidental uses and
disclosures of PHI made according to an otherwise permitted or required use or
disclosure.
d) Documentation and
Record Retention
– Our dental office will maintain in written or electronic form all
documentation required by the Privacy Rules for six years from the date of
creation or when the document was last in effect, whichever is greater.
e) Privacy Policies
& Procedures
– Only {name of Dentist} may change these Privacy Policies & Procedures.
12. State Law Compliance
Our dental office will comply with the privacy laws of each state that has
jurisdiction over our practice, or its actions involving protected health
information (PHI), that provide greater protections or rights to patients than
the Privacy Rules.
13. HHS Enforcement
Our dental office will give the U.S. Department of Health and Human Services (HHS)
access to our facilities, books, records, accounts, and other information
sources (including individually identifiable health information without patient
authorization or notice) during normal business hours (or at other times without
notice if HHS presents appropriate lawful administrative or judicial process).
We
will cooperate with any compliance review or complaint investigation by HHS,
while preserving the rights of our practice.
14. Designated Personnel
Our dental office will designate a Privacy Officer and other responsible persons
as required by the Privacy Rules.
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Dr. Rick!
