Privacy Practices Notice

This notice describes how your client information may be used and disclosed and how you can get access to this information. Please review it carefully.

Organizational Effectiveness (OE) is comprised of two integrated functions – Health and Productivity (H&P) and Organizational Development (OD) – that serve individuals and groups to improve their health, performance, and engagement at The University of Iowa. Organizational Effectiveness works to empower individuals to fulfill their potential by partnering to build a healthy, productive, and engaged UI community that supports a culture of excellence.

Legal Responsibility

UI Wellness and Faculty and Staff Services /EAP (FSS/EAP) are units with OE. UI Wellness provides comprehensive health management services for faculty and staff.  The EAP provides confidential counseling for faculty and staff. This counseling service will be referred to as the Employee Assistance Program (EAP) hereafter.

UI Wellness and EAP are legally required to protect the privacy of your health information, and to provide you with this notice about our legal duties and privacy practices. UI Wellness and EAP are legally required to follow the privacy practices described in this notice. If you have any questions or want more information about this notice, please contact our Privacy Officer at the contact information listed at the end of this notice. 

Your Protected Health Information (PHI)

Throughout this notice we will refer to your protected health information as PHI. Your PHI includes data that identifies you and reports about the care and services you receive at UI Wellness and EAP.

This notice applies to all of the records, both electronic and paper, about your care.  It includes all information created by UI Wellness and EAP staff. 

This notice about our privacy practices explains how, when, and why we use and share your PHI.  We may not use or disclose any more of your PHI than is necessary for the purpose of the use or disclosure, with some exceptions. 

Changes to This Notice

We reserve the right to change the terms of this notice and our privacy policies.  Any changes will apply to your past, current, or future PHI.  When we make an important change to our policies, we will change the Privacy Notice and post a new notice on our website (http://hr.uiowa.edu/livewell and http://hr.uiowa.edu/fsseap/). We will have available a copy of the revised Privacy Notice in the place where we provide services.  The Privacy Notice will contain the effective date on the last page.  You may also request a copy of our current Privacy Notice at any time from the reception desk at UI Human Resources, 121 University Services Building, Iowa City, IA, 52242-1911.  The telephone number is 319-335-2085.

Your Rights Regarding PHI

Right to request restrictions

For UI Wellness clients: You have the right to ask that we limit how we use and disclose your PHI. For example, when you have paid for your services out-of-pocket in full, at your request we will not share information about those services with your health plan (the organization that pays for your medical care.)  For all other requests we will consider your request, but are not legally required to accept it. If we accept your request, we will put any limits in writing and abide by them except in emergency situations. Remember that you may not limit the uses and disclosures that we are legally required or allowed to make. To request a restriction, contact the Privacy Officer listed below.

For EAP clients: We are legally obligated to not disclose your PHI without your written permission except in situations involving child or dependent adult abuse or neglect, imminent danger to self or others or due to a court subpoena. You may not request a restriction of the use of PHI in these situations we are legally bound to report.

Right to request confidential communications

You have the right to ask that we send PHI to you at an alternate address. For example, you may wish to have your PHI, such as appointment reminders, sent to a P.O. Box or an address different than your home address. We must agree to your request so long as we can easily provide it in the format requested. To make that request let your UI Wellness or EAP provider know of the alternate address. The EAP intake information has a place to indicate where and how you would prefer to receive messages.  You will not need to provide a reason for your request.

Right to inspect and copy

For UI Wellness and EAP:  You may request a copy of your client record.  You have the right to receive this copy in electronic format. To request a copy, please send a written request to the Director, Organizational Effectiveness, University of Iowa, 121 University Services Building, Iowa City, IA, 52242.

Right to an accounting of disclosures

For UI Wellness, you have a right to get a list of instances in which we have disclosed your PHI. Your request must state a time period that may not be longer than six years and may not include dates before April 14, 2003. The list will not include uses or disclosures made for treatment, payment, or program operations. In addition, it will not include uses or disclosures that you have specifically authorized. You must submit your request in writing to the Privacy Officer listed below.  If you request an accounting more than once during a 12-month period, you may be charged for costs.

For EAP, your PHI will not be released without your consent.  This includes disclosures related to referral or treatment services, disclosures for which you have signed a release and/or emergency disclosures for which you did not consent (see instances of mandatory reporting listed above). You may submit your request to your counselor or to the Clinical Administrator of FSS/EAP. You may be asked to sign a release of information to yourself.  If you request an accounting more than once during a 12-month period, you may be charged for costs.

Right to amend

You have the right to request an amendment of PHI maintained about you in the client record if you think that information is inaccurate or incomplete. To request an amendment to your PHI, you should contact the following individuals in the order identified. Your request must be in writing:

  • Your service provider in the respective area (UI Wellness or FSS/EAP)
  • The Manager of the respective area (UI Wellness or FSS/EAP)
  • Organizational Effectiveness, University of Iowa, 121 University Services Building, Iowa City, IA, 52242. Phone number is 319‐353‐2085.

UI Wellness providers, EAP providers and/or Organizational Effectiveness may deny your request for an amendment if:

  • It is not in writing
  • It is not part of information that you would be permitted to inspect or copy.
  • It is related to information that was not created or produced by staff within UI Wellness or FSS/EAP.

Breach Notification

In the unlikely event there is a breach of your PHI, you have the right to be notified.  We will notify you at the last address we have on record.  We will inform you of the nature of the breach and corrective action taken to prevent a recurrence.

Right to paper copy of this Privacy Notice

Even if you have received a copy of this notice via e‐mail, you have the right to request a paper copy also. You may pick up a copy at the reception desk in Human Resources at 121 University Services Building.

Revocation of Permission

If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. To revoke your permission to disclose information, contact the following individuals in the order provided:

  • Your service provider in the respective area (UI Wellness or FSS/EAP)
  • The Manager in the respective area (UI Wellness or FSS/EAP)
  • Organizational Effectiveness , University of Iowa, 121 University Services Building, Suite 50, Iowa City, IA, 52242‐1911. Phone number is 319‐353‐2314.

If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written revocation. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the services that we provided to you.

Complaints

If you believe your privacy rights have been violated, you may file a complaint. You may file your complaint with your service provider or the Manager of the respective service (UI Wellness or FSS/EAP) If you are not satisfied with the resolution offered, you may file a complaint with Organizational Effectiveness, The University of Iowa, 121 University Services Building, Iowa City, IA, 52242. You may also contact the University of Iowa Privacy Officer, listed below. There will be no retaliation or penalty for filing a complaint.

Uses of Protected Health Information

UI Wellness and EAP collect health information about you and store it in a confidential file and on a secure computer. This is your client file. The client file is the property of UI Wellness and EAP, but selected information in the file belongs to you. We use and disclose health information for very few reasons and usually only with your written permission. The following describes the different categories of our uses and disclosures and gives you some examples of each category. Not every use or disclosure will be listed.

Treatment

For UI Wellness and EAP clients: We use PHI in the course of providing services.  Disclosure would only be with your written permission.

Payment

For UI Wellness: We may use and disclose your PHI  to our internal referral sources at UIHC for payment purposes.  Written consent is obtained from you as part of the referral agreement.

For EAP Clients: This does not apply as EAP services are free.

Appointment reminders and health related benefits or services

We may use PHI (e.g. your name) to provide appointment reminders or give you information about other UI Wellness or EAP services.

Law Enforcement

UI Wellness may disclose PHI when a law requires that we report information to government agencies, including federal officials or special investigative officers, and law enforcement personnel about victims of abuse, neglect or domestic violence and when ordered to do so in judicial or administrative proceedings.

EAP will only disclose information related to child or dependent adult abuse or neglect to the Department of Human Services.  In the event there is evidence of clear and eminent danger to self or others, we may contact a family member, law enforcement or give information when ordered to do so in judicial or administrative proceedings. 

Research Studies

Should you participate in a research study a Privacy Board or Institutional Review Board determines that measures are in place to protect your identity from disclosure to organizations outside of the University of Iowa.  You may be asked to participate in a research study and if you agree, you will need to give special authorization to disclose your PHI.

Program Evaluation

UI Wellness or EAP may gather information to determine the effectiveness of an intervention or program. Such information is only disclosed IN AGGREGATE with the goal being to help improve our services. 

Business Associates

We may share your health information with others called “business associates,” who perform services on our behalf.  The Business Associate must agree in writing to protect the confidentiality of the information.  For example, UI Wellness has a Business Associate agreement with Quality Health Solutions, Inc., the third party vendor that provides the on-line Personal Health Assessment and on-line lifestyle management programs for eligible University of Iowa faculty and staff. 

Uses and Disclosures for Which You Have the Opportunity to Object

For UI Wellness: We may provide your PHI to an individual that you indicate is involved in your care or the payment of your care with your written consent, unless you object in whole or in part. Except as described above, all other uses and disclosures of your PHI will require your authorization.

For EAP clients, disclosure would only be with your written permission.

Uses and Disclosures for Which Your Written Permission is Required

For UI Wellness and EAP clients, disclosure would only be with your written permission or when required by law as noted above.

Federal and state law requires special privacy protections for certain confidential information about you.  We must obtain your written permission to share highly sensitive medical information, including the following:

  • Psychotherapy notes written by your therapist;
  • Other mental health information;
  • Substance (drug and alcohol) abuse treatment information;
  • HIV/AIDS testing, diagnosis, and treatment information.

Other examples of uses and disclosures of your PHI that require your written permission are:

  • For UI Wellness clients, a summary report of your completion of the Health Coach service or behavior change program.

Marketing – We must obtain your written permission prior to using your PHI to send marketing materials.  UI Wellness and EAP do not participate in any arrangements for the sale of your PHI.  Such arrangements would require your prior written authorization.

Questions

If you have questions about this Privacy Notice, please contact:

Deborah Thoman
UI Privacy Officer
University of Iowa
C‐429‐1 General Hospital UIHC
319‐384‐5897

This notice is in effect on July 21, 2014.