HIPAA Privacy Rule

Please review carefully. Effective April 14th, 2003

Those Who Fulfill the Practices in this Notice.

This notice describes the practices of Metro Pavia Health System and that of:

  • All professionals authorized to enter information into your record in each MPHS affiliated hospital.
  • All the departments and units of MPHS affiliated hospitals.
  • All members of volunteer groups authorized by us to assist you during your stay at an MPHS affiliated hospital.
  • All employees, officials, and personnel working at MPHS affiliated hospitals.
  • All external services authorized by the MPHS affiliated hospital.

All these entities, places, and locations comply with the terms of this notice. Also, these entities, places, and locations can share medical information for the purpose of carrying out treatment, payment, or medical interventions as described in this notice.

Our Pledge to Medical Information

understand that your personal and medical information are private, and are fully committed to protecting them. When you receive care and service from MPHS affiliated hospitals, a record is prepared. This record is necessary so that you may be provided with quality care and meet certain legal requirements. The present notice is a legal requirement and it applies to all the records that MPHS affiliated hospitals create in regard to your care, having been prepared by affiliated hospital personnel or medical personnel. It is possible that your personal physician’s policy or notices may be different in regards to the use or disclosure of your medical information that is prepared in the office or clinic.

By means of this notice, you are notified of the ways in which your medical information may be used and disclosed. Likewise, we include a description of your rights and certain obligations that we and our affiliates have regarding the use and disclosure of medical information.

We are required by law to:

  • Ensure that medical information that identifies you is private (with certain exceptions)
  • Give you this notice regarding our legal rights and practices on confidentiality regarding your medical information
  • Comply with the terms of the current notice


How your Medical Information May be Used and Disclosed

The following categories describe the different ways in which we use and disclose medical information. For each use or disclosure category, there will be an explanation of its meaning and we will provide some examples. Not all of the uses and disclosures for each category will be included here. However, each of the ways in which we are allowed to use and disclose information belongs to one of these categories.

Providing Treatment

We may use your medical information in regards to the administration of treatment or medical services. We may disclose your medical information to doctors, nurses, technicians, medical students, or other hospital employees who are involved in your care at the affiliated hospital. For example, if a doctor treats you for a broken leg, he may need to know if you suffer from diabetes. This is because this illness may extend your healing period. Furthermore, it may be necessary for the doctor to inform the dietician that you suffer diabetes so that they may order appropriate foods. Other departments in the affiliated hospital also share your medical information with the purpose of coordinating your different requirements, such as prescriptions, laboratory analysis, and x-rays. We may also disclose your medical information to people outside the affiliated hospital who participate in your medical care after you are released from the hospital, such as specialized nursing facilities or home health care providers.

Payment Procedures

We may use and disclose your medical information to ease the sending of billing and collection for services offered to your medical insurance or a third party for the treatment and services you receive at an affiliated hospital. For example, it is possible that we may need to submit information to your healthcare plan regarding a surgery that was carried out in the hospital so that your health insurance pays us or reimburses you for the surgery. We may also inform your health insurance about a treatment you will receive in order to acquire prior approval or determine if your plan will cover the treatment.

Healthcare Related Activities

We may use and disclose your medical information to carry out medical care activities. It is necessary to use and disclose certain information so that the affiliated hospital works and to ensure that our patients are receiving quality care. For example, we may use your medical information to study the treatment and services we offer and to evaluate our personnel’s performance when treating you. We can also combine many patients’ medical information to decide which services the hospital should offer, which are unnecessary, and if new treatments are being effective. We may also disclose your information to doctors, nurses, technicians, medical students, and other hospital employees for reviewing and learning purposes. We may also combine our medical information with that of other hospitals to compare how we are performing and to evaluate which aspects of our attention and service offerings we can improve. The information that identifies you may be eliminated so that other people can use these to study our care and medical services without disclosing the identity of specific patients.

Appointment Reminders

We may use and disclose your medical information to communicate with and remind you of an upcoming appointment to receive treatment or medical attention at the hospital.

Treatment Alternatives

We may use and disclose your medical information to inform or recommend possible alternatives to treatment options that may interest you.

Health Products and Services

We may use and disclose your medical information to inform you about health products or services that may interest you.


We may use and disclose your medical information to communicate with you to raise funds for the hospital and its operation. We may reveal your medical information to a foundation affiliated with the hospital so that it may communicate with you to raise funds for the hospital. We will only disclose the information necessary to communicate with you, such as your name, address, phone number, and the dates during which you received treatment or services at the hospital. If you do not wish to receive fundraising communications by the hospital, you must notify the Information Management Department of the MPHS affiliated hospital.

We may include certain limited information about you in the affiliated hospital directory while you are a patient there. This information may include your name, placement in the hospital, your general health status (for example, regular, stable, etc.), and your religion. Unless you request the opposite in writing, the directory information, except your religion, could be handed over to people who ask about you by name. Your religion may be revealed to a member of the clergy, such as a priest or rabbi, even if they don’t ask for your name. This information is disclosed so that relatives, friends, and members of the clergy may visit you at the hospital and that they know your overall health progress.

People Who Intervene in your Care or in the Payment of your Care

We may disclose your medical information to a friend or relative who is involved in your medical care. We may also disclose information to people who contribute to your payment for medical care.

Unless a written request specifically stating otherwise is received, we can also inform your family or friends in regards to your health status and let them know that you have been admitted to the hospital. Also, it is possible that we provide medical information about you to an entity assisting in case of disaster so that your family is notified regarding your health and whereabouts.


Under certain circumstances, your medical information may be used and disclosed for research purposes. For example, a research project that may consist of comparing the health and recovery of all patients that receive a medication with those who receive another medication for the same disorder. However, all research projects are subject to a special approval process. This process evaluates the proposed research project and the way in which medical information would be used, seeing to it that the research needs and the confidentiality requirements of your medical information are balanced. Before using or disclosing medical information for research purposes, previous process must approve the project. However, we may provide your medical information to the people preparing to carry out a research project, for example, to help them find patients with special medical needs, with the condition that the information that they study does not leave the hospital. In most cases, we will ask for your specific authorization in order to allow the researcher access to your name, address, or any other information that may reveal who you are, or who will be involved in your care at the hospital.

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As Required by Law

We shall disclose your medical information when federal, state, or local law requires it.

To Avoid a Serious Health or Security Threat

We may use and disclose your medical information when necessary in order to avoid a serious health and public security, or that of another person’s, threat. Nonetheless, the information will only be handed over to who is capable of stopping the threat.


Special Circumstances

Organ and Tissue Donation

We may provide information to organizations that are in charge of obtaining organs or carrying out organ, eye, or tissue transplants, or to a donated organ bank, as needed, with the means of facilitating organ donation and transplant.

Military and Veteran Personnel

If you are a member of the armed forces, we can disclose your medical information as required by military command. We can also provide foreign military personnel’s medical information to corresponding foreign military command.

Workers’ Compensation Insurance

We can disclose your medical information to a workers’ compensation insurance program or similar programs. These programs offer benefits for work related injuries or illnesses.

Public Health Risks

We can disclose your medical information for activities related to public health. Generally, these activities include the following:

  • Disease, injury, or disability prevention
  • Information on births and deaths
  • Information about child, geriatric, or dependent adult abuse or abandonment
  • Notification regarding medical reactions or problems with a product
  • Informing the population about recalls of products they may be using
  • Notifying a person that may have been exposed to a disease or who may be at     risk of contracting or spreading a disease or disorder
  • Notifying the pertinent governmental authorities if we believe that a patient     has been a victim of abuse, neglect, or domestic violence.

Monitoring Health Services

We may disclose your medical information to health service monitoring bodies to carry out activities authorized by law. For example, these monitoring activities include audits, investigations, inspections, and license grants. These activities are necessary so that the government can supervise the healthcare system and government programs, and to keep in with laws regarding civil rights.

Lawsuits and Disputes

If you are involved in a lawsuit or dispute, we may provide your medical information in response to a court or administrative order. We may also provide your medical information in response to a subpoena, discovery request, or other lawful process carried out by someone else involved in a dispute, but only if they have informed you about the orders in question (which may include a written notification sent to you) or to obtain an order protecting the requested information.

Law Enforcement

We may provide medical information if required by police or judicial authority:

  • As a response to an order, subpoena, warrant, or similar process.
  • To identify or find a suspect, fugitive, key witness, or missing person.
  • About a crime victim if, under certain limited circumstances, we cannot obtain the consent of the person concerned.
  • About a death we believe could be the result of criminal behavior.
  • About criminal behavior in the hospital.
  • In emergency circumstances, to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime.

Coroners, Medical Examiners, and Funeral Directors

We may provide medical information to a coroner or medical researcher. For example, this may be necessary to identify a deceased person or to determine the cause of death. We may also provide medical information regarding hospital patients to funeral directors when necessary so they may carry out their duties.

National Security and Intelligence Service Activities

We may provide your medical information to authorized federal officials for intelligence, counterintelligence, and other national security related activities authorized by law.

Presidential Protection and Other Services

We may provide your medical information to authorize federal officials so that they may protect the president, other authorized people, or foreign heads of state, or to carry out special investigations.


If you are confined in a correctional facility or under the custody of a police or judicial official, we may disclose your medical information to the correctional facility or police official. Providing this information will be necessary (1) so that the facility can provide you with medical care; (2) to protect your health and safety or the health and safety of others; or (3) for the protection and security of the correctional facility.


Your Rights to Your Medical Information

You have the following rights in regards to the medical information that we hold about you:

Right to Inspect and Copy

You have the right to inspect and copy medical information that may be used to make decisions regarding your health care. Generally, this includes clinical history and billing records, but it may not include certain information regarding mental health.

To inspect and copy the medical information that may be used to make decisions, you must present a written request to the Information Management Department of the MPHS affiliated hospital. You must fill out an authorization form. If you are requesting a copy of the information, it is possible that we may charge copy, shipping, and other supply costs associated with your request.

We may deny your request of inspecting and copying your record in certain limited circumstances. If you are denied access to your medical information, you may request the denial’s revision. Another authorized medical professional will see your request and the denial. The person who carries out the review will not be the person who denied the request. We will comply with the review’s decision.

Right to Amend

If you consider that the medical information we have about you is incorrect or incomplete, you may request an amendment. You have the right to request an amendment provided that the information remains in the hospital and is maintained by the same.

To request an amendment, you must do so in writing and present it to the Information Management Department of the MPHS affiliated hospital. Also, you must provide a reason to support your request.

We may deny an amendment request if it is not done in writing or does not have a reason to support it. Also, we may deny your amendment request regarding information that:

  • Was not created by us, unless the person or entity that created the information is no longer available to make the amendment.
  • It is not part of the medical information that is maintained by or for the hospital.
  • It is not part of the information that you are allowed to inspect and copy.
  • It is exact and complete

Even if we deny your amendment request, you have the right to present a written supplement, fewer than 250 words, in regards to whatever concept or declaration on your record you consider to be incomplete or incorrect. If you clearly indicate through writing that you wish for the written supplement to be part of your medical record, we will attach it to the same and we will always include the supplement when we disclose the concept or declaration that you consider to be incomplete or incorrect.

Right to Disclosure Accounting

You have the right to request a disclosure accounting. This is a list of instances in which your medical information was revealed, except for our own instances of use regarding treatment, payment, and medical care activities (as they have been previously described) with other motives as allowed by law. The list will not include information that was disclosed as a result of other uses or allowed disclosures by our confidentiality policies or by law, disclosures authorized by you, disclosures that were done to our, your family or your friends, or through our facility’s directory, or for aid in case of disaster. Also, the list will not include information disclosed due to national security or police reasons or disclosures done before April 14, 2003.

To request this list or accounting of instances during which your information was revealed, you must do so in writing to the Information Management Department at the hospital you are treated. You must indicate a specific period, which cannot be over six years and cannot include dates before April 14, 2003. You must indicate how you want to receive the list (for example, a printed or electronic version, subject to the availability of the medium). The first list that you request in a 12-month period is free. If you request additional lists, we will charge you for the cost of providing them. We will notify you of the cost and you may decide to retire or modify your request before incurring expenses.

Right to Request Restrictions

You have the right to request a restriction or limitation regarding your medical information that we use or disclose, your treatment, payment, or medical care activities. You also have the right to request the limitation of the medical information we reveal about you to a person involved in your medical care or the payment of it, such as a relative or friend. For example, you may request that we do not use or disclose information regarding your surgery.

We are not required to agree to your request. If we are in agreement, we will comply with your request unless the information is necessary to provide you with emergency treatment.

To request restrictions, you must do so in writing to the Information Management Department of the hospital you received medical care. In your request, you must tell us (1) the information you wish to restrict; (2) if you wish to restrict our use, disclosure, or both; (3) who you want to apply these limits to, for example, disclosure to your husband.

Right to Request Confidential Communications

You have the right to request that we communicate with you regarding medical matters in a certain way or in a certain place. For example, you may request that we communicate with you solely by calling you at work or via mail.

To request confidential communications, you must do so in writing to the Information Management Department of the hospital you were treated at.

We will not ask the reason for your request. We will comply with all reasonable requests. Your request must specify how or where you wish to have us communicate with you.

Right to Receive a Hard Copy of this Notice

You have a right to receive a hard copy of this notice. You may ask us to provide a copy of this notice at any time. Even if you have agreed to receive this information via electronic means, you are equally entitled to a hard copy of the same.

To receive a hard copy of this notice, contact the Information Management Department at the hospital you were treated at.

Changes to this Notice

We reserve the right to change this notice. We reserve the right that the reviewed or modified notice be effective regarding your pre-existent medical information with us along with any information we may receive in the future. A copy of the notice in effect will be placed in the hospital. The notice has the effect date in the upper right corner of the first page. Also, each time that you register or are an inpatient at a hospital to receive treatment or health services as an inpatient or outpatient, we will offer a copy of the currently effective notice.


If you believe that we may have violated your privacy rights, you can submit a complaint to the hospital or to Corporate Compliance free hotline at 1-888-882-0882 FREE or via email at cumplimiento@metropaviahealth.com

You will not be penalized for filing a complaint.

Other Uses of Medical Information

The uses or disclosure of medical information that are not covered by this notice or the laws that govern us will only be carried out with your written authorization. If you authorize us to use or release your medical information, you can revoke said authorization, in writing, at any time. If you revoke your authorization, we will no longer use or release your medical information for the reasons outlined in your written authorization, unless we have already acted based on your permission. You must understand that we cannot take back any disclosures that have been made with your authorization, and that we are required to retain our records of the care we have provided you.

Contact Information

You may write to: Metro Pavia Health System Maramar Plaza Building 101 San Patricio Ave Suite 950-960 Guaynabo, PR 00968 or call to 787-620-9770