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Joint Notice of Privacy Practices
THIS JOINT NOTICE OF PRIVACY PRACTICES (THE “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.
This Notice applies to the following organizations (collectively, “Village Medical”):
• Village Medical and its medical staff
• Village Medical Physical Therapy and Rehabilitation and its medical staff
• Village Medical at Home and its medical staff
• Village Medical Pharmacy and its medical staff
• Starling Physicians PLLC
This Notice identifies the general ways your protected health information can be used or disclosed.
Protected health information refers to your personal health information found in your medical and
billing records. This includes information, whether oral, written or recorded in electronic form, that is
created or received by us and relates to your past, present or future physical or mental health
conditions or the payment for healthcare services. This information can be transmitted or maintained
in any form by Village Medical.
This Notice describes your legal rights regarding your health information. It also informs you of our
legal duties and privacy practices. If you receive services by a physician or a healthcare provider not
at a Village Medical clinic, there may be different health information privacy policies or notices, and
there will be different contact information.
Village Medical organizations and their medical staffs participate in an Organized Health Care
Arrangement under HIPAA for the purpose of sharing protected health information for treatment,
payment and healthcare operations. Village Medical and its respective medical staff members are
independently responsible for complying with this Notice.
Our legal duties
We are required by law to keep your protected health information private, to provide you with this
Notice of our legal duties and privacy practices with respect to your health information, to provide
you with notice in the event of a breach of your unsecured protected health information, and to follow
the terms of the Notice as long as it is in effect. If we revise this Notice, we will follow the terms of the
revised Notice, as long as it is in effect.
How we may use and disclose your health information
The following information describes how we are permitted, orrequired by law, to use and disclose your
health information. Not every use or disclosure in a category will be listed.
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Treatment
We may use or disclose your health information to a physician or other healthcare provider in order to
provide care and treatment to you. For example, a physician treating you for a broken leg may need to
know if you have diabetes, because diabetes may slow the healing process. Different departments at
Village Medical also may share information about you in order to coordinate the different services you
receive, such as lab work, X-rays and prescriptions. We also may disclose health information about you
to those who may be involved in your healthcare outside Village Medical,such as physicians and others
who provide you with follow-up care, and medical equipment or product suppliers. We may contact
you to coordinate care after discharge; to provide appointment reminders; and to provide you with
information about health-related benefits and services at Village Medical, or treatment alternatives
that may be of interest to you.
Payment
We may use or disclose your health information to obtain payment for services we provide to you. We
may disclose your health information to another healthcare provider or entity. For example, Village
Medical may need to provide your health plan with information about surgery you received so your
health plan will pay Village Medical or reimburse you for the surgery. Village Medical may also tell your
health plan about a treatment you are going to receive, in order to obtain the health plan’s prior
approval for the treatment or to determine whether your plan will cover the treatment.
Healthcare operations
We may use or disclose health information about you to support the programs and activities of Village
Medical, such as quality and service improvement, healthcare delivery review, staff performance
evaluation, competence or qualification review of healthcare professionals, education and training of
physicians and other healthcare providers, business planning and development, business
management and general administrative activities. We use this information to continuously improve
the quality of care for all patients we serve. For example, we may combine health information about
many patients to evaluate the need for new services or treatments. We may disclose information for
educational purposes to doctors, nurses and other students. And we may combine health information
we have with that of other facilities to see where we can make improvements.
Additionally, we may share your health information with other healthcare providers and payors for
certain elements of their business operations if the information is related to a relationship the provider
or payor currently has or previously had with you, and if the provider or payor is required by federal
law to protect the privacy of your health information.
Our ability to use or disclose your protected health information for the above payment, treatment, and
healthcare operation purposes may be further limited by other more stringent applicable laws.
Village Medical Health Information Exchange
We may make your health information available electronically, through an information exchange
network, to other providers such as hospitals, laboratories and physicians involved in your care who
request your electronic health information. The purpose of this information exchange is to support the
delivery of safer and better-coordinated patient care. Participation in the information exchange is
voluntary, and you may opt out by emailing compliance@villagemd.com.
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Electronic disclosures
Village Medical creates, receives, maintains and, in some instances, discloses your health information
in an electronic format. We will obtain your written or electronic authorization prior to electronically
disclosing your protected health information for any reason other than treatment, payment,
healthcare operations or as otherwise authorized or required by law.
Authorization for other disclosures
We will not use or disclose your health information, except as described in this document, unless you
authorize us, in writing, to do so. You may give us written authorization to disclose your medical
information to anyone, for any purpose. Village Medical may use electronic or other means to satisfy
your request for the authorized disclosure. You can revoke an authorization at any time by providing
written notification to Village Medical. If you revoke an authorization, we will no longer use or disclose
your health information for the purpose covered by the authorization. However, we are unable to take
back any uses or disclosures already made with your authorization. Specific examples of uses or
disclosures requiring written authorization include the use of psychotherapy notes, marketing
activities, the sale of your health information and most uses and disclosures for which we are
compensated.
Family and friends
We may use or disclose information to notify or assist in notifying a family member, personal
representative or other person responsible for your care, of your location and general condition. We
will also disclose health information to a family member, other relative, close personal friend or any
other person you identify and authorize, if the information is relevant to that person’s involvement
with your care or payment for your care.
Future communications
We may use or disclose your information to communicate with you via newsletters, mailings or other
means regarding treatment options, health-related information, disease-management programs,
wellness programs or other community-based initiatives or activities in which Village Medical
participates. If we receive any financial compensation for such communications (with limited
permitted exceptions), we will obtain your authorization prior to sending the communication, and your
authorization can be revoked at any time by providing us written notification of the revocation.
Public health and safety
We may use or disclose health information, as authorized or required by local, state or federal law, for
the following purposes, which are deemed to be in the public interest or benefit:
• To report certain diseases and wounds, births and deaths, and suspected cases of abuse,
neglect or domestic violence
• To help identify, locate or report criminal suspects, crime victims, missing persons, suspicious
deaths or criminal conduct on Village Medical premises
• To respond to a court order, subpoena or other judicial process
• To assist federal disaster-relief efforts
• To enable product recalls, repairs or replacements
• To respond to an audit, inspection or investigation by a health-related government agency
• To assist in federal intelligence, counterintelligence and national security issues
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• To facilitate organ and tissue donations
• To assist coroners, medical examiners and funeral directors
• To respond to a request from a jail or prison regarding an inmate’s health or medical
treatment
• To respond to a request from your military command authority (if you are a member or veteran
of the armed forces)
• To provide information to a workers’ compensation program
Prohibited Uses and Disclosures Related to Reproductive Health Care
We are prohibited from using or disclosing your protected health information where the information is
sought to investigate or impose liability on individuals, health care providers, or others who seek, obtain,
provide, or facilitate reproductive health care that is lawful under the circumstances in which such
health care is provided, or to identify persons for such activities. This prohibition applies in situations
where we receive a request for information connected to reproductive health care and we reasonably
determine that one of the following circumstances applies:
• The reproductive health care is lawful under the law of the state in which such health care
is provided under the circumstances in which it is provided.
• The reproductive health care is protected, required, or authorized by federal law, including
the U.S. Constitution, under the circumstances in which such health care is provided,
regardless of the state in which it is provided.
For example, if law enforcement from another state requests records related to an abortion you
obtained legally in this state, we would be prohibited from disclosing that information.
Attestation Required for Certain Disclosures
In some cases, we may be required to obtain a signed attestation that a request for your information
potentially related to reproductive health care is not for a prohibited purpose as described above before
disclosing that information. This applies to requests for protected health information related to:
• Health oversight activities
• Judicial and administrative proceedings
• Law enforcement purposes
• Disclosures to coroners and medical examiners
For example, if we receive a request from law enforcement for records that may be related to
reproductive health services you received, we would need to obtain a signed attestation from the
requestor that the information is not being sought to investigate or impose liability related to lawful
reproductive health care before releasing those records.
Part 2 Program Information
If you receive services from our Part 2 program for substance, use disorder, your information is
protected by additional federal law (42 CFR Part 2). Records from our Part 2 program, or testimony
relaying the content of those records, may not be used, or disclosed in a civil, criminal, administrative,
or legislative proceeding against you without either your written consent or a court order. A court order
authorizing this use or disclosure must be accompanied by a subpoena or other legal requirement
compelling disclosure. You also have the right to elect not to receive fundraising communications from
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us if we intend to use Part 2 records for fundraising purposes. You will be provided a clear and
conspicuous opportunity to make this election.
Business associates
There are some services provided at Village Medical through contracts with business associates. When
these services are contracted, we will disclose your health information to the business associate so
they can perform the job we have asked them to do. However, business associates, such as Village
Medical, are required by federal law to appropriately safeguard your information.
Research
We will disclose information to researchers after approval by an Institutional Review Board (IRB) in
preparation for a research study, to recruit research subjects, or for a research study. The IRB reviews
research proposals and establishes protocols to protect your safety and the privacy of your health
information.
Special privacy protections for alcohol and drug-abuse information
Alcohol and drug-abuse information has special privacy protections. We will not disclose any
information identifying an individual as being a patient or provide any health information relating to
the patient’s substance-abuse treatment unless the patient consents in writing; a court order requires
disclosure of the information; medical personnel need the information to meet a medical emergency;
qualified personnel use the information forthe purpose of conducting scientific research, management
audits, financial audits or program evaluation; or it is necessary to report a crime or a threat to commit
a crime, or to report abuse or neglect as required by law.
Your health information rights
Your medical record is the physical property of Village Medical (via the healthcare practitioner or
facility that compiled it). You have the following rights, with certain exceptions, regarding the health
information that is created about you at Village Medical.
Paper copy of Notice
You have the right to a paper copy of this Notice. In addition, a copy of this Notice also may be obtained
at our website, villagemedical.com/forms.
Confidential communications
You have the right to request that we communicate health information to you by an alternate means
or location other than your home address and telephone number. Your request must be made in
writing to the Village Medical contact person listed below. The request must specify how or where you
wish to be contacted. We will try to accommodate your request for alternate communications. If
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you request an alternate means of communication, you should also communicate that request to all
your physicians, including your private physician.
Restrictions
You have the right to request a restriction or limitation on the health information we use or disclose
about you for treatment, payment or healthcare operations. You also have the right to request a limit
on the health information we disclose about you to someone who is involved in your care or the
payment for your care, such as a family member or friend. For example, you could ask that we not use
or disclose information to a family member about a surgery you had. To request a restriction, you must
make your request in writing to the Village Medical contact person listed below. We will agree to
reasonable requests, but note that we are not required to agree to all requests. If we do agree, our
agreement must be in writing, and we will comply with your request unless the information is needed
to provide you emergency treatment.
Additionally, you have the right to request that we not use or disclose information to a health plan for
purposes of payment or healthcare operations (not for treatment) if the health information pertains
solely to a healthcare item or service that has been paid for out of pocket and in full. Your request for
restriction must be submitted in writing. In this case, Village Medical must honor your request.
However, you should be aware that such restrictions may have unintended consequences, particularly
if other providers need to know that information (such as a pharmacy filling a prescription). It will be
your obligation to notify any such other providers of this restriction. Additionally, such a restriction
may impact your health plan’s decision to pay for related care that you may not want to pay for out of
pocket (and which would not be subject to the restriction).
Access
You have the right to review and obtain a copy of your health information, with certain exceptions.
Usually, this includes medical and billing records, but does not include psychotherapy notes or
information compiled in reasonable anticipation of, or for future use in, a civil, criminal, or
administrative action or proceeding. Your requestto review or obtain a copy of your health information
must be in writing. We may deny your request in certain circumstances, but in most instances, you will
be provided with our written explanation and an opportunity to review. You will be charged a
reasonable cost-based fee as authorized by law. To the extent your information is held in an electronic
health record capable of fulfilling your request, you may be able to receive the information in an
electronic format no later than 15 business days after the date your written request is received.
Amendment
If you feel the health information we have about you is incorrect or incomplete, you have the right to
ask for an amendment of that information. You have the right to request an amendment for as long as
the information is kept by or for us. Your request for an amendment must be made in writing, and
include a reason that supports your request. We may deny your request, but we will explain our
decision in writing within 60 days and you would then be given the opportunity to submit a statement
of disagreement.
Accounting of disclosures
You have the right to receive a list of certain disclosures of your health information we have made
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within the last six years, who we shared your health information with, and why. Your request for an
accounting must be in writing to the Village Medical contact person listed below, and must state a time
period for which you want an accounting. You may request one accounting free of charge within any
12-month period. A reasonable cost-based fee will be charged for additional lists within this same time
period.
Breach notification
You have the right to be notified in the event that we, or one of our business associates, discover an
inappropriate use or disclosure of your unsecured protected health information. Notification of any such
use or disclosure will be made in accordance with state and federal requirements.
Revisions of this Notice
We reserve the right to change this Notice, and the right to make the new provisions effective for all
health information we currently maintain, as well as any information we receive in the future. If we
make a major change to this Notice, the revised Notice will be physically posted at Village Medical and
on our website. In addition, a paper copy of the revised Notice will be available upon request.
To report a complaint
If you believe your health information privacy rights have been violated, you can file a complaint with
us at the contact information below or with the Secretary of the United States Department of Health
and Human Services by sending a letter to 200 Independence Avenue S.W., Room 509F HHH Bldg.,
Washington, D.C. 20201, calling 1- 800-368-1019 or visiting https://www.hhs.gov/hipaa/filing-acomplaint/index.html. There will not be any penalty or retaliation against you for making a complaint
to us or to the Department of Health and Human Services.
Village Medical contact person
If you have any questions or need information regarding our legal duties and privacy practices, or how
to exercise any of your health information rights listed in this Notice, please submit any requests in
writing via email to compliance@villagemd.com or mail to Privacy Officer, 150 Floral Avenue, New
Providence, New Jersey 07974. You may contact the Privacy Officer by phone at (908) 277-8686.
Effective: January 2025
