PHI Usage Policy

How We May Use and Disclose PHI About You

The following paragraphs describe different ways that we use and disclose PHI.

Use for Treatment, Payment, or Health Care Operations

We are permitted to use and disclose your PHI (1) to provide treatment to you, (2) to be paid or request payment for our services, and (3) to conduct health care operations. This section of this Notice discusses each of these types of uses and disclosures of PHI

For Treatment

We may use PHI about you to provide you with health care treatment or services. For example, we may use you PHI when conducting plan operations procedures. We may disclose PHI about you to CWRU personnel, as well as to doctors, nurses, hospitals, clinics, or other health care providers who are involved in your care. For example, a doctor treating you for a medical condition may need to know the medications which have been prescribed for you, or the services and items that have been provided to you. CWRU may also share PHI about you in order to coordinate health care services and items that you may need.

For Payment

We may use and disclose PHI about you so that the services and items that you receive from CWRU may be billed to and payment may be collected from you, an insurance company, or a third party payor. For example, we may need to give information about the services or items that you received so that the plan can pay your providers or reimburse you for the services or items.

Health Care Operations

We may use and disclose PHI about you for health care operations. These uses and disclosures are necessary to make sure you receive quality care. For example, we may use PHI to review treatment and services and to evaluate the performance of staff in providing services to you. We may also disclose information to doctors, nurses, hospitals, clinics, and other health care providers, for review and learning purposes. We may remove information that identifies you from this set of PHI so others may use it to study health care and health care delivery without learning the names of the specific individuals.

Other Uses and Disclosures of PHI

Listed below are a number of other ways that CWRU is permitted or required to use or disclose PHI. This list is not exhaustive. Therefore, not every use or disclosure in a category is listed.

Appointment Reminders

We may use and disclose protected health information to contact you as a reminder that you have an appointment with us.

Individuals Involved in Your Care or Payment for Your Care

We may release PHI about you to a friend or family member who is involved in your medical care. We may also give information to someone who helps pay for your care. In addition, we may disclose PHI about you to a person or entity assisting in an emergency so that your family can be notified about your condition, status and location.

As Required By Law

We will disclose PHI about you when required to do so by federal, state, or local law.

Public Health Risks

We may disclose PHI about you for public health activities, including to prevent or control disease or, when required by law, to notify public authorities concerning cases of abuse or neglect.

Health Oversight Activities

We may disclose PHI to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure.

Lawsuits and Disputes

If you are involved in a lawsuit or dispute, we may disclose PHI about you in response to a court or administrative order. We may also disclose PHI about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

Law Enforcement

We may release PHI if asked to do so by a law enforcement official as permitted by law.

Coroners and Medical Examiners

We may release PHI to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death.


Under certain circumstances, we may use and disclose PHI about you for research purposes. For example, we might disclose PHI to be used in a research project involving the effectiveness of certain procedures. In some cases, we might disclose PHI for research purposes without your knowledge or approval. However, such disclosures will be made only if approved through a special process. This process evaluates a proposed research project and its use of PHI, trying to balance the research needs with an individual's need for privacy of their PHI.

To Avert a Serious Threat to Health or Safety

We may use and disclose PHI about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.

Military and Veterans

If you are a member of the armed forces, we may release PHI about you as required by military command authorities.

Health-Related Benefits and Services

We may use and disclose PHI to tell you about health-related benefits or services that may be of interest to you.

Workers' Compensation

We may release PHI about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.


We may disclose PHI about you for fundraising purposes. Any such disclosure of PHI will be limited in scope and disclosed only to CWRU personnel or agents, to our business associates or to a charitable organization which is obligated to act for the benefit of CWRU. If you do not want CWRU to contact you about fundraising, you may opt out by notifying the CWRU Privacy Officer. Further information about disclosures for fundraising purposes may be found in CWRU’s HIPAA Policies and Procedures, under “Fundraising.”

Other uses and disclosures will be made only upon your written authorization. Specifically, use or disclosures of PHI will be made only upon your written authorization for the following:

  • for marketing purposes;
  • for the disclosure of psychotherapy notes;
  • for the sale of your PHI.

CWRU will not use PHI that is genetic information for underwriting purposes.

You also have the right to revoke such authorization, in writing, except where we have previously taken action in reliance on your prior authorization or if the authorization was a condition to obtaining insurance or health plan coverage and applicable law provides the insurer or health plan with the right to contest a claim under the policy.

Certain provisions of Ohio law may now, or in the future, impose greater restrictions on uses and/or disclosures of PHI or otherwise be more stringent than federal rules protecting the privacy of PHI. If such provisions of Ohio law apply to a use or disclosure of PHI or under other circumstances described in this Notice, CWRU must comply with those provisions.

When required to do, the Plan will disclose only the minimum amount of PHI necessary to accomplish the intended purpose of a use, disclosure or request for PHI.