It is the intent of Daughters of Israel to uphold the business integrity and ethical conduct as a participant in governmentally funded healthcare programs and other contractual arrangements. Delivery of care must be in compliance with all laws and regulations applicable to such programs as well as all Federal, State and local laws and regulations which govern Daughters of Israel's operations. It is the responsibility of every Daughters of Israel employee, including affiliated providers operating at Daughters of Israel, Daughters of Israel physicians and other health care professionals, to proactively identify issues relating to potential fraud and abuse exposure, and to comply with the policies and procedures designed to minimize such exposure.

Compliance in this area is challenging because the regulatory requirements governing reimbursement are complex and changing. To underscore and enhance its continued pledge of compliance and to better assist all employees, including physicians and allied health professionals, in this area, Daughters of Israel is committed to this comprehensive Compliance Program.

Daughters of Israel has adopted the directives set forth in the Office of Inspector General's Compliance Program Guidance for skilled nursing facilities to prevent and detect potential violations of law. The adoption and implementation of our voluntary Compliance Program will significantly advance the prevention of potential fraud, abuse and waste and compliance with all governing State, Federal and local laws and regulations, while at the same time furthering the fundamental mission of Daughters of Israel.

Any questions as to the propriety of a particular situation should be reported anonymously to the Daughters of Israel toll-free hotline at 866-225-9900.

Excluded Individuals/Entities Policy

Policy

It is the policy of Daughters of Israel to ensure that any payments received for Federal and State funded health care programs are not for items or services that are directly or indirectly furnished, ordered, directed, managed or prescribed in whole or in part by an excluded, unlicensed or uncertified individual or entity. Excluded individuals or entities are those identified by the State or Federal government as not being allowed to participate in State of Federally funded health benefits programs, such as Medicaid, NJ Family Care or Pharmaceutical Assistant to the Aged or Disabled (PAAD).

Procedures

Daughters of Israel is responsible for verifying that current and prospective employees (regular or temporary)., contractors or subcontractors who directly or indirectly will be furnishing, ordering, directing, managing or prescribing items or services in whole or in part are not excluded, unlicensed or uncertified by searching the following databases:

• Federal Exclusions Database (OIG) – monthly;
• N. J. Treasurer's Exclusions Database – Vendors; - monthly
• Division of Consumer Affairs Licensure Databases: Nurses, Social Workers; - monthly
• N. J. Department of Health and Senior Services Licensure Database – Health Care Vendors; - monthly
• Certified Nurse Aide Registry (PSI) – CNA's. - monthly

An employee whose licensure has expired or has been revoked, will be removed from work schedules until such time that the license is renewed or reinstated in good standing. Daughters of Israel will cease to do business with Health Care vendors or entities that are listed on the above databases as being excluded, until such time that the exclusion is removed and the entity is reinstated in good standing.

THIS 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.

 

We respect the privacy of your personal health information and are committed to maintaining our Residents' confidentiality. This Notice applies to all information and records related to your care that our facility has received or created. It extends to information received or created by our employees, staff, physicians and volunteers. This notice informs you about the possible uses and disclosures of your personal information. It also describes your rights and our obligations regarding your personal health information.

We are required by law to:

• maintain the privacy of your protected health information;
• provide to you this Notice of our legal duties and privacy practices relating to your personal health information; and,
• abide by the terms of the Notice that are currently in effect.

 

I. WITH YOUR CONSENT WE MAY USE AND DISCLOSE YOUR PERSONAL HEALTH INFORMATION FOR TREATMENT, PAYMENT AND HEALTH CARE OPERATIONS

 

You will be asked to sign a Consent allowing us to use and disclose your personal health information for purposes of treatment, payment and health care operations. We have described these uses and disclosures below and provide examples of the types of uses and disclosures we may make in each of these categories.

 

For Treatment. We will use and disclose your personal health information in providing you with treatment and services. We may disclose your personal health information to facility and non-facility personnel who may be involved in your care, such as physicians, nurses, nurses' aides, and physical therapists. For example, a nurse caring for you will report any change in your condition to your physician. We also may disclose personal health information to individuals who will be involved in your care after you leave the facility.

 

For Payment. We may use and disclose your personal health information so that we can bill and receive payment for the treatment and services you receive at the facility. For billing and payment policies, we may disclose your personal health information to your representative, an insurance or managed care company, Medicare, Medicaid or another third party payor. For example, we may contact Medicare or your health plan to confirm your coverage or to request prior approval for a proposed treatment or service.

 

For Health Care Operations. We may use and disclose your personal health information for facility operations. These uses and disclosures are necessary to manage the facility and to monitor our quality of care. For example, we may use personal health information to evaluate our facility's services, including the performance of our staff.

 

We may require that you sign a Consent as described above as a condition of our providing treatment to you because the uses and disclosures of your personal health information are essential to our ability to care for you.

 

II. WE MAY USE AND DISCLOSE PERSONAL HEALTH INFORMATION ABOUT YOU FOR OTHER SPECIFIC PURPOSES.

 

Facility Directory. Unless you object, we will include certain limited information about you in our facility directory. This information may include your name, your location in the facility, your general condition and your religious affiliation. Our directory does not include specific medical information about you. We may release information in our directory, except for your religious affiliation, to people who ask for you by name. We may provide the directory information, including your religious affiliation, to any member of the clergy.

 

Individuals Involved in Your Care or Payment for Your Care. Unless you object, we may disclose your personal health information to a family member or close personal friend, including clergy, who is involved in your care.

 

Disaster Relief. We may disclose your personal health information to an organization assisting in a disaster relief effort.

 

As Required By Law. We will disclose your personal health information when required by law to do so.

 

Public Health Activities. We may disclose your personal health information for public health activities. These activities may include, for example:

• reporting to a public health or other government authority for preventing or controlling disease, injury or disability, or reporting child abuse or neglect;
• reporting to the federal Food and Drug Administration (FDA) concerning adverse events or problems with products for tracking products in certain circumstances, to facilitate product recalls or to comply with other FDA requirements;
• to notify a person who may have been exposed to a communicable disease or may otherwise be at risk contracting or spreading a disease or condition or
• for certain purposes involving workplace illness or injuries.

 

Reporting Victims of Abuse, Neglect or Domestic Violence. If we believe that you have been a victim of abuse, neglect or domestic violence, we may use and disclose your personal health information to notify a government authority if required or authorized by law, or if you agree to the report.

 

Health Oversight Activities. We may disclose your personal health information to a health oversight agency for oversight activities authorized by law. These may include, for example, audits, investigations, inspections and licensure actions or other legal proceedings. These activities are necessary for government oversight of the health care system, government payment or regulatory programs, and compliance with civil rights laws.

 

Judicial and Administrative Proceedings. We may disclose your personal health information in response to a court or administrative order.

 

Law Enforcement. We may disclose your personal health information for certain law enforcement purposes, including:

• as required by law to comply with reporting requirements;
• to comply with a court order;
• to identify or locate a suspect, fugitive, material witness, or missing person;
• when information is requested about the victim of a crime if the individual agrees or under other limited circumstances;
• to report information about a suspicious death;
• to provide information about criminal conduct occurring at the facility;
• to report information in emergency circumstances about a crime; or
• where necessary to identify or apprehend an individual in relation to a violent crime or an escape from lawful custody.

 

Research. We may allow personal health information of residents from our facility to be used or disclosed for research purposes provided that the researcher adheres to certain privacy protections. Your personal health information may be used for research purposes only if the privacy aspects of the research have been reviewed and approved by a special Privacy Board or Institutional Review Board, if the research occurs after your death, or if you authorize the use or disclosure.

 

Coroners, Medical Examiners, Funeral Directors, Organ Procurement Organizations. We may release your personal health information to a coroner, medical examiner, funeral director or, if you are an organ donor, to an organization involved in the donation of organs and tissues.

 

To Avert a Serious Threat to Health or Safety. We may use ad disclose your personal health information when necessary to prevent a serious threat to your health or safety or the health or safety of the public or another person. However, any disclosure would be made only to someone with the ability to help prevent the threat.

 

Military and Veterans. If you are a member of the armed services, we may use and disclose your personal health information as required by military command authorities. We may also use and disclose personal health information about foreign military personnel as required by the appropriate foreign military authority.

 

Workers Compensation. We may use or disclose your personal health information to comply with laws relating to workers' compensation or similar programs.

 

National Security and Intelligence Activities. We may disclose your personal health information to authorized federal officials conducting national security and intelligence activities or as needed to provide protection to the President of the United States, certain other persons or foreign heads of states or to conduct other special investigations.

 

III. YOUR AUTHORIZATION IS REQUIRED FOR OTHER USES OF PERSONAL HEALTH INFORMATION.

 

We will only use and disclose personal health information (other than as described in this Notice or required by law) only with your written Authorization. You may revoke your authorization to use or disclose personal health information in writing at any time. If you revoke your Authorization, we will no longer use or disclose your personal health information for the purposes covered by the Authorization, except where we have already relied on your Authorization.

 

IV. YOUR RIGHTS REGARDING YOUR PERSONAL HEALTH INFORMATION

 

You have the following rights regarding your personal health information:

 

Right to Request Restrictions. You have the right to request restrictions on our use or disclosure of your personal health information for treatment, payment or health care operations. You also have the right to restrict the personal health information we disclose about you to a family member, friend or other person who is involved in your care or the payment for your care. We are required to agree to your requested restriction unless you are being transferred to another health care institution, the release of records is required by law, or the release of information is needed to provide you emergency treatment.

 

Right of Access to Personal Health Information. You have the right to request, either orally or in writing, your medical or billing records or other written information that may be used to make decisions about your care. We must allow you to inspect your records within 24 hours of your request. If you request copies of the records, we must provide you with copies within 2 days of that request. We may charge a reasonable fee for our costs in copying and mailing your requested information.

 

Right to Request Amendment. You have the right to request the facility to amend any personal health information maintained by the facility for as long as the information is kept by or for the facility. You must make your request in writing ands must state the reason for the requested amendment.

 

We may deny your request for amendment if the information
• was not created by the facility, unless the originator of the information is no longer available to act on your request;
• is not part of the personal health information maintained by or for the facility;
• is not part of the information to which you have a right of access; or
• is already accurate and complete, as determined by the facility.

 

If we deny your request, we will give you a written denial including the reasons for the denial and the right to submit a written statement disagreeing with the denial.

Right to an Accounting of Disclosures. You have the right to request an "accounting" of our disclosures or your personal health information. This is a listing of certain disclosures made by the facility or by others on our behalf, but does not include disclosures for treatment, payment and health care operations or certain other exceptions.
To request an accounting of disclosures, you must submit a request in writing, stating a time period beginning after April 13, 2003 that is within six (6) years from the date of your request. An accounting will include, if requested: the disclosure date; the name of the person or entity that received the information and address; a brief statement of the purpose of the disclosure or a copy of the authorization or request; or certain summary information concerning multiple similar disclosures. The first accounting provided within a 12 month period will be free; for further requests, we may charge you our costs.

Right to a Paper Copy of This Notice. You have a right to obtain a paper copy of this Notice. You may request a copy of this Notice at any time.

Right to Request Confidential Communications. You have the right to request that we communicate with you concerning personal health matters in a certain manner or at a certain location. For example, you can request that we contact you only at a certain phone number. We will accommodate your reasonable requests.

V. COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint in writing with the facility or with the Office of Civil Rights in the U.S. Department of Health and Human Services. To file a complaint with the facility, please call our Human Resources Department at 973-400-3818.

We will not retaliate against you if you file a complaint.

VI. CHANGES TO THIS NOTICE

We will promptly revise and distribute this Notice whenever there is a material change to the uses or disclosures, your individual rights, our legal duties, or other privacy practices stated in this Notice. We reserve the right to change this Notice and to make the revised or new Notice provisions effective for all personal health information already received and maintained by the facility as well as for all personal health information we receive in the future. We will post a copy a copy of the current Notice in the facility. In addition we will provide a copy of any revised Notice to all Residents.

VII. FOR FURTHER INFORMATION

If you have any questions about this Notice or would like further information concerning your privacy rights, please call our Human Resources Department at 973-400-3818.