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OUR COMMITMENT TO PROTECT YOUR HEALTH INFORMATION

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW YOUR PROTECTED HEALTH INFORMATION (PHI) MAY BE USED AND DISCLOSED. IT ALSO DESCRIBES HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Alivia Health Network is required by law to protect the confidentiality, privacy, and security of your health information, including prescription and medication-related data. In accordance with legal requirements, we are providing this notice about our privacy practices and your rights regarding your Protected Health Information (PHI). We will follow the privacy practices described in this notice while it remains in effect.

 

This Notice of Privacy Practices describes how Alivia Health Network and its affiliated companies (“we”, “us”, “our”) collect, use, and disclose your health information such as your prescription history and medical information, and details the ways we may use or disclose this information to provide you with pharmacy services, such as medication management, prescription refills, and billing. It also explains your rights regarding your health information.

While this notice includes descriptive examples, it is not a comprehensive list of all the ways we handle and protect your health information.

Alivia Health Network must comply with the terms of this notice. However, we reserve the right to change our privacy practices and the terms of this notice. If we make any significant changes to our privacy practices, we will update this notice and provide it to all active patients and/or clients. This notice will also be available upon request. This notice will become effective on January 01, 2025.

How We Safeguard and Protect Your Protected Health Information (PHI):

  • We have implemented administrative, physical, and technical safeguards to ensure the integrity, confidentiality, privacy, and security of your PHI. 

  • We have developed and implemented specific policies and procedures that limit access to your PHI by our employees and business associates to only those required to access it, and only for purposes of treatment, payment, or to carry out certain healthcare operations. 

  • Our employees receive training on our policies and procedures related to privacy and data protection.  

  • Additionally, we have established oversight activities to monitor and ensure compliance with our privacy and security policies regarding PHI.

Notice Summary:

We are committed to using, disclosing, handling, transferring, and storing only the information necessary to manage your pharmacy benefits and services. As part of our administrative processes, we gather personal information from various sources, including:

  • Information you provide directly or through our electronic resources to obtain our products or services. 

  • Information from transactions with our business associates. 

  • Information from healthcare providers. 

  • Government or other health programs.

Protected Health Information (PHI) refers to past, present, or future health information that identifies you (e.g., name) including demographic details (e.g., address), obtained directly from you or through the information requested in our applications or documents for services. It also includes information created or received by healthcare providers, health plans, billing intermediaries, or business associates, related to: (1) your physical or mental health condition; (2) healthcare services provided to you; (3) payments for healthcare services. This information is referred to as PHI for the purposes of this Notice.

This Notice is in compliance with the HIPAA Privacy Rule. Any terms not defined here have the same meaning as in the HIPAA Privacy Rule. We have established policies and procedures to safeguard your PHI, which you may review upon request. You can contact us at privacidad@aliviahealth.com or write to the address provided below:

Quality and Compliance Department 

Alivia Health Network 

P.O. BOX 246 

Bayamón, Puerto Rico, 00960

 

Compliance with Laws and Regulations:

We follow the laws that require us to keep your health information private and secure, including HIPAA (a federal law), Puerto Rican law, and other applicable rules. Such as:

  • HIPAA: The Health Insurance Portability and Accountability Act (HIPAA) of 1996 sets rules for handling, storing, transmitting, and disclosing Protected Health Information (PHI) to ensure privacy and security of personal and health data.

  • HITECH: The Health Information Technology for Economic and Clinical Health Act (HITECH) of 2009 encourages the adoption of health information technology and strengthens privacy and security measures for electronic health data, enhancing enforcement of HIPAA rules.

  • Patient Bill of Rights: The Puerto Rico Patient Bill of Rights outlines the fundamental rights of patients in the healthcare system, ensuring their access to high-quality care, protection of privacy, and participation in decisions regarding their health treatment. These rights include the right to confidentiality, informed consent, and respectful treatment, as well as access to medical records and healthcare services.

Alivia Health Subsidiaries Covered Under This Notice:

This notice applies to all Alivia Health Network subsidiaries:

  • Alivia Health Management (AHM) 

  • Alivia Home Delivery (AHD) 

  • Alivia Infusion Services (AIS) 

  • Alivia Pharmaceutical Services (HUB) 

  • Alivia Specialty Pharmacy (ASP) 

  • Farmacias Plaza (AFP)

Uses and Disclosures of Protected Health Information:

Alivia Health Network will not use or disclose your PHI for any other purpose that is not covered in this notice without obtaining written authorization from you. You shall have the right to revoke the authorization in writing and it is not effective until we receive it. However, your revocation shall not affect the uses and disclosures permitted by law or the uses and disclosures permitted during the validity of the granted authorization effectiveness.

We may use or disclose you’re PHI for the following purposes:

Uses and Disclosures with You

We may use your PHI as part of the provision of our services such as prescription order processing, assistance, and processing your requests. For example, contacting you to complete the health record, and providing assistance and services such as prescription pick-up.

Treatment. We may use or disclose your PHI to provide the pharmacy services you need, such as filling prescriptions, providing medication counseling, and working with other providers as part of the rendition of healthcare services. For example, we may check your medication history to ensure the prescription is safe for you, contact your doctor if you have questions about your prescription, or share medical information for treatment coordination.

Payment. We may use or share your PHI to bill and get payment from health plans and other entities for the services provided. For example, we may send information to your insurance company, pharmacy benefit manager (PBM), or other payor entity to determine if they will pay for the services and products needed and to determine the copayment amount, we may also share your information as part of the billing process, the information of the billing transaction and/associated documentation may include information that can identify you and the services provided or may use and share your information with other health care providers, health plans, or any other covered entity covered by HIPAA that may require payment for its activities.  

Healthcare Operations. We may use or share your PHI to improve our services and proper management of our pharmacy network. Such as business planning and development, training purposes, administrative activities, conducting audits, and detection of fraud, waste, and abuse or noncompliance. For example, we may check your medical records to ensure we are filling them in correctly, monitor the quality of our services, and/or manage your treatment and services.  

We may also use or disclose your PHI for the following purposes:  

Affiliated Companies. To fulfill our responsibilities as a pharmacy provider, we may use or disclose your PHI between our subsidiaries for the purposes of prescription fulfillment, medication management, billing, and coordination of care. 

Business Associate. We may engage third-party service providers to assist with certain services, such as prescription delivery, accounting, information technology, and consulting. These third-party providers, known as Business Associates, may need access to your PHI in order to carry out the contracted services. By contract and law, they are obligated to safeguard your PHI and use or disclose it only as necessary to perform the services on our behalf. 

Disclosures to Parents and Legal Guardians. We may disclose a minor’s PHI to their parents or legal guardian in accordance with applicable laws. For instance, a parent or legal guardian may present and collect a prescription on behalf of the minor and access the minor’s prescription medication history. 

Disclosures with Individuals Involved in Your Care. We may disclose your PHI to a family member, other relative, close personal friend, or any person you identify if it is relevant to that person’s involvement in your care or payment for your care unless you have requested a restriction. Prior to the disclosure, we will provide you with the opportunity to refute such disclosure. If you are unable to provide such an objection, we will utilize our professional judgment to determine if the disclosure is in your and your healthcare’s best interests.  

Additionally, we may disclose your PHI to your designated "personal representative." If an individual has the legal authority or is authorized by you to access Protected Health Information (PHI) on your behalf, we will generally treat that person as your "personal representative” and treat them in the same we would treat you with respect to your PHI. If you designate a personal representative to access your PHI, this designation does not extend to making healthcare decisions unless specified. If a healthcare professional determines that you, as a personal representative, are engaging in domestic violence, abuse, or neglect, or are endangering the life of an individual, they may choose to disregard your authority as the individual's personal representative. This decision is based on professional judgment and prioritizes the best interests of the individual. 

When the Law Requires It. We may have to share your PHI as required and permitted by legislation, state, or federal law as applicable.  

Law Enforcement. We may disclose your PHI to law enforcement as required by law or in response to a court order, subpoena, warrant, or similar legal process. If permitted, we will make an effort to notify you prior to disclosing your information to law enforcement. 

Legal Proceedings. We may use or disclose your PHI in the course of judicial or administrative proceedings to comply with a court order (disclosure as expressly permitted), or in response to a citation, subpoena, discovery request, or other legal procedure authorized by law.  

Public Health Activities. We may share your PHI to help public health agencies in certain situations such as tracking diseases, preventing or controlling diseases, aiding with product recalls, reporting medication side effects, reporting suspected abuse, neglect, or domestic violence, and/or preventing or reducing a serious threat to health and safety.  

For Research Purposes. We may use or disclose your PHI for research purposes when authorized by law. This may include sharing your PHI with researchers, provided access is limited to a designated data set to the information, and prior to the disclosure the research has been evaluated and approved by the Board Compliance, and safeguards are in place to protect the confidentiality of your information. 

Oversight Activities. We may share your PHI with regulatory or accreditation agencies, for audits, compliance monitoring, investigations, inspections, or licensing. These disclosures help ensure oversight of the healthcare system and compliance with state and federal laws, including civil rights regulations. 

Food and Drug Administration (FDA). We may disclose your PHI to the FDA or its agents to address imminent threats to public health or safety, including adverse events related to food, drugs, supplements, products, or product defects. This may also include sharing information for product recalls, repairs, or replacements. 

Manufacturers and Aggregators. We may use your PHI to create de-identified data, which could be shared with manufacturers and aggregators for product improvement services or data programs. This data may be used to analyze prescription and usage patterns, program management, patient profiles, treatment duration, product inventory, and other related aspects. 

Medical Examiners, Funeral Directors, Organ Donation Organizations. We may use or disclose your PHI to forensic pathologists or medical examiners to assist them in performing their duties, such as determining the cause of death or carrying out other legally authorized functions. Additionally, we may share your information with funeral directors or organ donation organizations to support their responsibilities related to the deceased, as well as with organizations involved in the procurement, banking, or transplantation of organs, eyes, or tissues. 

Workers' Compensation. We may use or disclose your PHI as necessary to comply with laws related to workers' compensation or other similar programs that provide benefits for work-related injuries or illnesses. 

Disaster Relief and Emergency Situations. We may disclose your PHI to authorized public or private entities involved in disaster relief efforts. Additionally, we may share your information to help notify your family members, personal representatives, or caregivers about your general health condition and location during a disaster or emergency. 

Military, Veterans, and National Security. We may disclose your PHI to military authorities if you are a member of the Armed Forces or a veteran. We may also share your PHI with federal officials for national security or intelligence activities, including protection of the President and government officials. PHI about foreign military personnel may be shared with the appropriate foreign military authorities. 

To Avert a Serious Threat to Health and Safety. We may disclose your PHI to prevent a serious threat to your health or safety or that of others. 

Correctional Institutions. If you are or become an inmate of a correctional facility, we may disclose your PHI to the institution or its agents as necessary for the provision and continuity of healthcare services, as well as for the health and safety of others. 

Uses and Disclosures that Require Your Authorization: 

Any other uses or disclosures of your PHI will require your prior written authorization, including those involving psychotherapy notes, the sale of PHI, or the marketing of PHI (except for face-to-face marketing activities with you that involve only nominal value). Your access to pharmacy services will not be affected if you deny the authorization. You may also provide authorization to disclose and permit access to your PHI to anyone for any purpose. You may also revoke the authorization in writing at any time, however, this will not affect any use or disclosure made by your authorization while it was in effect. A copy of the authorizations and revocations submitted shall be kept in our organization's records.  Information used or disclosed may be further disclosed by the person or class of persons or entity receiving it, and thus it would no longer be protected under privacy regulations. 

Access to Your Electronic Health Information (Information Blocking): 

Information blocking occurs when an entity prevents or delays, without a valid reason, your ability to view, use, or share your Electronic Health Information (EHI). This practice is not allowed under the federal 21st Century Cures Act. EHI may include, but is not limited to, details about your prescriptions, treatments, or medical visits. This law requires us to give you access to your information, and to allow you to use or share it with whomever you choose, when requested by you or someone authorized by you. There are certain limited exceptions permitted by law. If you wish to access your electronic health information, you may contact the Quality and Compliance Department. 

Special Protections for Certain Types of PHI: 

Substance Use Disorder Treatment Information. If we maintain your substance use disorder treatment records, those records are protected by additional privacy and confidentiality regulations. We won’t share them without your written consent, except as required by law. 

Reproductive Health Information. We understand that information about reproductive health (like birth control, pregnancy, and fertility) is sensitive. We will protect this information and only share it with your written consent, unless the law requires otherwise. It is prohibited to use or disclose protected health information when requested to investigate or impose liability on anyone for obtaining, providing, or facilitating lawful reproductive healthcare, including requests by law enforcement agencies.

 

HIV/AIDS Information. HIV/AIDS-related health information is protected under both federal and state law. We won’t share this information without your consent unless it is needed for medical treatment, public health, or legal reasons. 

Mental Health and Genetic Information. Your mental health and genetic information (like psychotherapy notes and test results related to your DNA) is protected by law. We will only use and disclose this information as permitted and required by law.

 

Know your rights associated with PHI: 

You have the following rights under both HIPAA and the Patient Bill of Rights: 

Right to Request a Copy of Your Health Information.  You have the right to inspect and receive a copy of your personal, financial, health, or prescription information related to your pharmacy records or medication claims, subject to legal limitations and exceptions. To request access, submit a written request. Within 5 days, we will either provide the information, allow you to review it during business hours, inform you if we do not have the information, direct you to the source, or deny the request due to confidentiality, legal proceedings, or other protected sources. We will notify you in writing if the request is denied, except in the case of ongoing investigations. The first request is free; subsequent requests may incur a charge.  

Right to an Accounting of Disclosures. You have the right to receive a list of times we’ve shared your protected health information for reasons other than treatment, payment, healthcare operations, or your permission. The list will cover the last six years. It will include the name of the entity, the date, the reason for sharing, and a brief description of the information shared. If you request this more than once a year, we may charge a fee for the extra requests.  

Right to Amendments. You have the right to request corrections to your health information. Your request must be in writing and include a reason or evidence to support the change. We will respond within 60 days and notify you if more time is needed. We may deny your request if we didn’t create the information, or for other reasons. If denied, we will provide a written explanation, and you can submit a statement of disagreement for future disclosures. If we approve your request, we will inform others, including business associates, and update future disclosures accordingly. 

Right to Request a Restriction or Limitation on How We Use or Share Your PHI. You have the right to request a restriction or limitation on how we use or disclose health information. We are not obligated to agree to your request. If we do agree, we will follow the terms of the agreement, except in a medical emergency or as required or permitted by law. Your request and our agreement to apply additional restrictions must be submitted in writing.  If a service is paid for entirely out of pocket by you, HIPAA regulations allow you to request that the service not be disclosed to your health plan, relating solely to that service for purposes of payment or health care operations, unless the disclosure is required by law. 

Right to Ask for Alternate or Confidential Communication. You have the right to request that we communicate with your PHI at an alternative location or address. Such as sending correspondence to a specific address or being contacted at an alternate phone number. To request an alternate or confidential communication please submit the request in writing and indicate the specific address where you would like to receive your information. We reserve the right to accommodate such requests as practical and reasonably possible. 

Right to Receive a Notice in the Event of Breach. We are required by law to protect the privacy and security of your PHI. If a breach occurs that may compromise the confidentiality, privacy, or security of your Protected Health Information (PHI), we will notify you. 

Right to Non-Discrimination. You have the right to be treated fairly, regardless of race, color, national origin, socio-economic status, sex, age, disability, or any other protected characteristic under the law. 

 

Right to a Copy of This Notice. You have the right to request and receive a copy of this notice in either electronic or paper format. If you would like to request a copy of this Notice of Privacy Practices, please contact the Quality and Compliance Office (Q&C) at the contact information provided below.  

Questions or Filling a Request: 

If you would like to exercise your rights, please submit a written request utilizing our organization's formulary as applicable to each request type. If have any questions or need more information, please contact our Quality and Compliance Department at the contact details below: 

Phone: 787-709-4208 

Email: privacidad@aliviahealth.com  

Postal Address: 

Quality and Compliance Department 

Alivia Health Network 

P.O. BOX 246 

Bayamón, Puerto Rico, 00960 

 

Complaints 

If you think your privacy rights have been violated or if you have concerns about how we’ve used or shared your health information, you can file a complaint with us or with the Puerto Rico Department of Health or the U.S. Department of Health and Human Services (HHS). We won’t take any action against you for filing a complaint. 

  • Quality and Compliance Department 
     

Website: https://www.aliviahealth.com/compliance  

Phone: 787-709-4208 
Email:
privacidad@aliviahealth.com  

Postal Address: 

Quality and Compliance Department 

Alivia Health Network 

P.O. BOX 246 

Bayamón, Puerto Rico, 00960 

Phone: 787-765-2929 

Email: contactus@salud.pr.gov  

Postal Address:  

Departamento de Salud de Puerto Rico 

P.O. Box 70184 

San Juan, P.R. 00936-8184 

  • U.S. Department of Health and Human Services (HHS) 
    Website:
    www.hhs.gov/ocr 

Phone: 1-800-368-1019 
Email:
OCRComplaint@hhs.gov   

Fax: 202-619-3818 

Postal Address:  

Centralized Case Management Operations 

U.S. Department of Health and Human Services 

200 Independence Avenue, S.W. 

Room 509F HHH Bldg. 

Washington, D.C. 20201 
 

We support the exercise of your rights associated with your Protected Health Information (PHI). We shall not discriminate or discriminate against you in any way if you choose to file a complaint with us with the OCR.  

 

Notice of Privacy Practices Revision Date: January 2025

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