Genetics & IVF Institute
Notice of Privacy Practices for Patients
Effective September 15, 2013
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.
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal program that requires that all medical records and other individually identifiable health information used or disclosed by Genetics & IVF Institute (GIVF) in any form, whether electronically, on paper, or orally be kept confidential to maintain the privacy of your protected health information. This Act gives you, the patient, significant new rights to understand and control how your health information is used. HIPAA provides penalties for covered entities that misuse personal health information.
We respect your right to privacy and understand that your medical information is personal to you. In order to provide medical services to you, we create paper and electronic records about your health and the care we provide. Your personal health information is confidential and this Notice of Privacy Practices (NPP) is intended to help you understand how GIVF uses and discloses your personal health information and what rights you have with respect to your medical information.
We may use and disclose your medical records only for each of the following purposes:
Treatment means providing, coordinating, or managing health care and related services by one or more health care providers. Examples of this would include related care and treatment services by health care providers, scheduling surgery, other exams or appointments with other providers, calling in prescriptions and refills, consultation between health care providers relating to a patient for coordination of care and physician to staff discussions for coordination of care, and the referral of a patient for health care from one health care provider to another.
Payment means such activities as obtaining reimbursement for services, confirming coverage, billing or collection activities, related data processing, and utilization review. An example of this would be sending a bill for your visit to your insurance company for payment.
Healthcare operations include the business aspects of running our practice on a daily basis, such as conducting quality assessment and improvement activities, auditing functions, cost-management analysis, and customer service. An example would be an internal quality assessment review.
Any other uses and disclosures will be made only with your written authorization. Specific types of disclosures that require your authorization include: disclosures of psychotherapy notes; disclosures for marketing purposes for which GIVF receives remuneration; and the sale of your protected health information. You may revoke such authorization in writing and we are required to honor and abide by that written request, except to the extent that we have already taken actions relying on your authorization.
We reserve the right to update these practices at any time. The revised notice will be posted in our patient waiting areas and you will have the opportunity to request a paper or electronic copy of the revised notice from our privacy officer, the front desk staff, or by accessing our website.
We may also create and distribute de-identified health information by removing all references to individually identifiable information. We may contact you to confirm your appointments or communicate with you in connection with care management or coordination. You have the following rights with respect to your protected health information, which you can exercise by presenting a written request to the Privacy Officer.
- The right to request restrictions on certain uses and disclosures of protected health information, including those related to disclosures to family members, other relatives, close personal friends, or any other person identified by you. We are, however, not required to agree to a requested restriction unless it is a request to restrict disclosure of your protected health information to your insurance company for services/products for which you have paid out-of-pocket and in full, and that are unrelated to treatment and not required by law. If we do agree to a restriction, we must abide by it except in limited circumstances or unless you agree in writing to revoke it.
- The right to reasonable requests to receive confidential communications of protected health information from us by alternative means or at alternative locations.
- The right to inspect and copy your protected health information.
- The right to amend your protected health information.
- The right to receive an accounting of disclosures of protected health information.
- The right to obtain a paper copy of this notice from us upon request.
We are required by law to maintain the privacy of your protected health information and to provide you with notice of our legal duties and privacy practices with respect to protected health information. We are also required to notify you if there is a breach of your unsecured health information.
This notice is effective as of September 15, 2013 and we are required to abide by the terms of the Notice of Privacy Practices and to make the new notice provisions effective for all protected health information that we maintain. We will post and you may request a written copy of the revised Notice of Privacy Practices from this office.
You have recourse if you feel that your privacy protections have been violated. You have the right to file a formal, written complaint with our office or with the Department of Health & Human Services (HHS), Office of Civil Rights (OCR), about violations of the provisions of this notice or the policies and procedures of our office. We will not retaliate against you for filing a complaint.
For more information or to submit a written inquiry or complaint, please contact our Privacy Officer:
Genetics & IVF Institute
Cheryl Richardson, Privacy Officer
3015 Williams Drive
Fairfax, VA 22031
703-698-3948 - 703-698-3963 (fax)
For HIPAA information or to file a complaint:
US Department of Health and Human Services
Office of Civil Rights
200 Independence Avenue, SW
Washington, DC 20201
202-619-0257 or 1-877-696-6775
Fairfax Cryobank is committed to protecting the identities of our clients and donors. We have and will continue to honor the contracts we have agreed to with our donors. If they are anonymous donors, we will keep their identity private from all parties who wish access to that information. Our ID Options donors have agreed to a limited release of information which will not occur until a child registered with us as his offspring reaches the age of 18.
Anonymous donors will always remain anonymous. They will never become ID Options donors (see below).
current time is "closed," which dictates that the donor's and recipient's
identities remain anonymous. All donor and recipient records will
be maintained indefinitely and we will not compromise the anonymity
between the donor and the recipient. We do not facilitate contact between anonymous donors and their offspring.
In certain medically necessary circumstances, we will, upon physician
request, attempt to obtain specific additional donor medical or genetic
information and testing. Donor identity in these circumstances will remain anonymous.
Identity (ID) Option Donors
Certain new donors have consented to be ID Option donors. These donors agree
to a limited release of identifying information when registered offspring from
their donated sperm reach 18 years of age. Children must be registered with Fairfax Cryobank by their parents as offspring of an ID Option donor. Parents can also opt not to register at birth and wait to see what their family situtation dictates. Regardless of the intent to register a child or not, the ID Option consent must be signed and returned before units will be released.
ID Option donors can therefore be used as an anonymous donor if the parent has decided not to register their child for the program.
Contact with Donors
Fairfax Cryobank staff is instructed to return calls and emails from all donors. We recognize the importance of our relationships with our donors. If a donor is attempting contact and not receiving a call back or email they should speak to Client Services who will direct them to the correct person.
We encourage all past donors to contact us and update their medical and personal information which will then be shared with clients as appropriate. This will also allow us to confirm their identification, verify that their contact information is up to date, and clarify any medical issues via our Medical Director, a board certified Clinical Geneticist.
Donor Information: Medical and Personal Profiles
The plethora of information that is now available on all donors was not available in the past. Currently there are vast amounts of non-identifying information on all donors including Identity Options (ID) donors. In fact anonymous and ID donors have all of the same medical and personal information available, the only difference is that when an ID Option donor is used there is the option for the offspring to contact the donor when they reach the age of 18.
Annual Updates from Donors
We have a program that reaches out to past donors and allows them to easily update medical and personal information confidentially. Donors who wish to update their information can contact Client Services and they will be directed to the laboratory staff that will assist them in this process. We publish relevant updated information on the donor’s summary profile.
Check Donor Medical Status
We believe that the best way for clients to gather medical and personal information about their donors is at the source, from the Cryobank itself. We have instituted the Check Donor Medical Status as a way for clients to easily verify that there is no medical update that would lead to an increased risk for them or their offspring. This also allows us to give an immediate and accurate notification if any medical issue does arise.
Fairfax Cryobank Family Forums
Fairfax now has the Fairfax Cryobank Family Forums. These wonderful forums are a popular way for clients to connect and share their experiences. The Cryobank has set up the site and works to provide up to date information therefore, we believe this is the best source for clients to connect.
As of January 1 2012, new donors are given the option of knowing their donor number. Clients purchasing donor sperm from donors who entered the program prior to January 1, 2012 purchased with the understanding that donors did not have access to their donor numbers and accordlingly old donor numbers are not released. It is important to consider and respect each donor and all recipients who use donor sperm.
Request to Release Identifying Information
We understand and respect the desire of many women, couples, and donor insemination (DI) offspring to know more about their donor. However, it is important to acknowledge that there are also many women, couples, offspring, and families that do not want identifying information released as originally agreed. It would not be ethical for us to compromise the agreements we made with all of the people involved from the donor to the recipient.
We believe it is the responsibility of the Cryobank to continue to gather updated non identifying medical and personal information from donors for as long as possible and to share that information with our clients. We do this in a way that maintains the integrity of our original agreements and contracts.
We have provided high quality donor sperm for more than 20 years that has led to the creation and growth of happy families. We have continued to expand and update our portfolio of information on donors to address the growing needs of families that have resulted from the use of donor sperm. It is for this reason that we work to update profiles and allow families to connect through forums.
We respect and will uphold the agreements and contracts that were in place when a donor donated at the Cryobank. There is always more than just one way to look at a situation and, we believe, we must respect and uphold the original agreements and contracts. It is important to note that there are donors who chose to donate anonymously and families who chose an anonymous donor because of the anonymity. It would be impossible to have all parties involved reach an unequivocal consensus to release identifying information, and therefore we honor the agreements in place.