Barron Pharmacy

Accommodating Patient Rights
Patients possess a variety of rights related to their PHI at Barron Pharmacy. The rights, in addition to the right to receive a written Notice of Privacy Practices, include the following:

1. A request for access to pharmacy records;
2. A request to amend pharmacy records;
3. A request for an accounting;
4. A request for confidential communication; and
5. A request to file a complaint.

Any employee receiving a request from a patient related to any of the above-listed patient rights shall immediately refer the request to the Pharmacy Privacy Officer, and if the Pharmacy Privacy Officer is not available, the request shall be referred to the pharmacist on duty.

Any patient requesting the exercising of any of the above-listed rights shall be requested to complete the form that relates to the patient right. However, if a patient refuses to complete the form, and instead wants to exercise the right based only upon an oral request, the Pharmacy
Privacy Officer or pharmacist on duty shall make a good faith effort to accommodate the patient request.

Every effort shall be made to accommodate a request of a patient to exercise a right granted to the patient by HIPAA. All requests to exercise a patient right shall be promptly reviewed and acted upon by the Pharmacy Privacy Officer. Where a patient is entitled to a written response to a request to exercise a patient right, the written response shall be provided promptly to the patient. Documentation of resolution and response of a request to exercise a patient right shall be placed upon the appropriate Barron Pharmacy form as necessary or required by the form.

The Pharmacy Privacy Officer shall consult with the pharmacist on duty as necessary with regard to any request related to a patient right.

Uses and Disclosures of PHI
Use and disclosure of PHI shall occur only in accordance with the written Notice of Privacy Practices of Barron Pharmacy.

With respect to any use and disclosure of PHI, only the minimum necessary PHI shall be used and disclosed, unless otherwise permitted by the Pharmacy Privacy Officer or pharmacist on duty who is familiar with the rules concerning the minimum necessary standard.

Only the Pharmacy Privacy Officer and pharmacist on duty shall be allowed to request a written authorization for a use and disclosure of PHI that is not described in the Notice of
Privacy Practices, or otherwise requires a written authorization pursuant to HIPAA.

Use and disclosure of PHI shall occur only with respect to the employees of Barron Pharmacy who have an essential need for the PHI in order to carry out their job tasks and responsibilities. Such employees shall not use or disclose PHI to other employees.

Any use and disclosure of PHI for purposes of marketing must be approved in advance by the Pharmacy Privacy Officer.

Record Keeping Requirements
The initial written Notice of Privacy Practices and any revised written Notices of Privacy Practices that may be prepared shall be maintained at Barron Pharmacy for at least six years from the effective date stated on the written Notice of Privacy Practices.

The document used to record patients' signatures acknowledging receipt of the written Notice of Privacy Practices shall be maintained at Barron Pharmacy for at least six years from the date of the last patient signature contained on the document.

Any use and disclosure of PHI that is subject to the HIPAA accounting requirement shall be maintained in an appropriate database, electronic or written, with performance of routine backing up, and shall be maintained for at least six years from the date of the use and disclosure.

All contracts with business associates shall include the HIPAA required "satisfactory assurances" and shall be maintained in a readily retrievable manner.

Staff Training
Although not all employees will have access to PHI, it is the policy of Barron Pharmacy that all employees will undergo staff training.

Staff training programs and materials shall be modified as needed to remain current, and all employees shall be retrained as necessary.

Cooperation with Investigations and Compliance Reviews
It is the policy of Barron Pharmacy to fully cooperate with any investigation or compliance review concerning the compliance of Barron Pharmacy with the HIPAA privacy standards.