You can ask for a printed copy at our front desk or by calling (317) 689-7171

Who we are and what this Notice covers

Key Hearing Aids is a hearing healthcare practice in Carmel, Indiana. Key Hearing Aids is operated by Compass Hearing Aids, Inc., together with Key Hearing Aids, LLC and Key Hearing Aids of Carmel, LLC. "We," "us" and "our" mean all three. We perform Audiometric Hearing Tests to determine amplification needs, and we fit, program and service hearing aids and related devices. We are not a medical facility, and we do not diagnose or treat medical conditions.

To care for you, we keep records about you: your contact details, hearing history, test results, the devices we fit, and billing and hearing benefit plan information. The law protects this information. In this Notice we call it your health information; the law calls it "Protected Health Information."

This Notice applies to everyone who works at Key Hearing Aids and to all of the records we keep about you, on paper or electronically.

Our duties to you

We are required by law to:

• keep your health information private and secure;
• give you this Notice of our legal duties and privacy practices;
• follow the terms of the Notice that is currently in effect; and
• tell you promptly if a breach occurs that may have compromised the privacy or security of your information.

We will not use or share your information other than as described in this Notice unless you tell us we can in writing.

How we use and share your health information

We use your information to provide your hearing care, and we share it with others who help provide that care. For example, we:

• use your audiogram and test results to select, fit and program your hearing aids;
• send ear impressions, test results and fitting details to a hearing aid manufacturer or earmold laboratory to make your devices or custom earmolds;
• send your devices, with the details needed, to a manufacturer or repair facility for service; and
• share results with your physician when your physician referred you to us, when you ask us to, or when we refer you to a physician for a concern outside our scope of practice.

For payment

We use and share your information to be paid for our services. For example, we send orders, authorizations and fitting details to the hearing benefit program or health plan that covers your hearing aids, and we send warranty and loss-and-damage claims to the manufacturer.

For health care operations

We use your information to run our practice, improve our care and keep required records. For example, we review our services for quality, train our staff, and manage our business.

Appointment reminders and follow-up

We may contact you by phone, text message, email or mail to remind you of appointments, to follow up after a fitting or repair, and to tell you about services related to your hearing care, such as cleanings and annual check-ups. Regular email and text messages are not always secure. If you would rather we did not use them, or want us to contact you only in a certain way, tell us (see "Your rights" below).

Business associates

We use outside companies to help us, such as our client records and online forms system, our secure website forms service, and our computer support. They may handle your health information only under a written agreement (a "business associate agreement") that requires them to protect it as we do.

People involved in your care or payment

We may share information with a family member, friend or caregiver who comes to your appointment or who helps with your care or payment for it, unless you tell us not to. If you are not present or cannot agree, we will use our professional judgment and share only what is relevant. We may also share information with a disaster relief organization so your family can be told about your location and condition, unless you object.

Other uses and sharing the law allows or requires

In the situations below, the law allows or requires us to use or share your health information without your written permission. We share only what the law allows and only what is needed.

• When required by law, including federal, state or local law.
• Public health and product safety, such as reporting problems with hearing aids and other devices to the U.S. Food and Drug Administration or the manufacturer, and helping with product recalls.
• Abuse, neglect or exploitation. Indiana law requires reporting when we believe an endangered adult is being abused, neglected or exploited. We report to Adult Protective Services or law enforcement as the law requires.
• A serious threat to health or safety, to help prevent or lessen a serious and imminent threat to you, another person or the public.
• Health oversight, such as audits, inspections, investigations and licensing by government agencies, including the state boards that license hearing aid dealers.
• Lawsuits and legal proceedings, in response to a court or administrative order, or to a subpoena or other lawful request when the law's conditions are met.
• Law enforcement, for purposes the law allows, such as responding to a court order or warrant, or reporting a crime on our premises.
• Coroners, medical examiners and funeral directors, as needed for them to carry out their duties.
• Workers' compensation, for claims under workers' compensation or similar programs.
• Special government functions, such as military, veterans, national security and protective services, and correctional institutions, as the law allows.

Research and information that does not identify you

We may use information about our clients for research and to improve hearing care, but only after it has been de-identified, meaning it no longer identifies you. We will not use or share information that identifies you for research without your written permission.

Substance use disorder records

Key Hearing Aids is not a substance use disorder treatment program. If we ever receive records protected by the federal rule on substance use disorder records (42 CFR Part 2), we will follow that rule's added limits. In particular, those records, and testimony about them, will not be used or shared in any civil, criminal, administrative or legislative proceeding against you unless you give written consent or a court orders it after you have been given notice and a chance to be heard.

When Indiana law gives you more protection

If Indiana law or another law gives more protection to some of your information than this Notice describes, we follow the stricter law.

Uses that need your written permission

• Marketing. We will not use or share your health information for marketing that a third party pays us for without your written permission.
• Sale of information. We do not sell your health information, and we never would without your written permission.
• Psychotherapy notes. We do not keep psychotherapy notes.
• Fundraising. We do not use your health information for fundraising.
• Anything else not described in this Notice.

If you give us written permission, you can take it back (revoke it) in writing at any time. That will not undo anything we already did in reliance on your permission.

Information shared with others may be shared again

When we share your information as this Notice describes, the person or organization that receives it may share it again, and it may no longer be protected by federal privacy law.

Your rights

To use any of these rights, contact our Privacy Officer (details at the end of this Notice). We may ask you to make your request in writing, and we have forms to help. You can send written requests by mail, by fax, in person, or through the secure form on our website.

1. Get a copy of your records. You can see or get a paper or electronic copy of the health information we keep about you. We will respond within 30 days of your request (we may extend this once by up to 30 days and will tell you why). We may charge a reasonable, cost-based fee. In limited cases we may deny your request; if we do, we will explain why in writing and tell you how to ask for a review.
2. Ask us to correct your records. If you believe information we keep about you is wrong or incomplete, you can ask us in writing to correct it and tell us why. We will respond within 60 days. If we say no, we will explain why in writing, and you can send us a statement of disagreement to keep with your records.
3. Ask us to contact you privately. You can ask us to contact you in a certain way (for example, only on your cell phone) or at a certain address. We will not ask why, and we will say yes to all reasonable requests.
4. Ask us to limit what we use or share. You can ask us not to use or share certain information for treatment, payment or our operations, or not to share it with someone involved in your care. We are not required to agree, and we may say no if it would affect your care. If you pay for a service or item out of pocket in full, you can ask us not to share that information with your health plan for payment or operations; we will say yes unless the law requires us to share it.
5. Get a list of who we shared your information with. You can ask for a list (an "accounting") of the times we shared your health information in the six years before your request, who we shared it with, and why. The list will not include sharing for treatment, payment or operations, sharing you asked for, and certain other sharing. We will provide one list a year free; we may charge a reasonable, cost-based fee for another within 12 months, and we will tell you the fee first.
6. Get a copy of this Notice. You can ask for a paper copy at any time, even if you agreed to receive it electronically. It is also on our website and posted in our office.
7. Choose someone to act for you. If someone has your health care power of attorney or is your legal guardian, that person can use your rights and make choices about your health information. We will check that the person has this authority before we act.
8. File a complaint if you believe your privacy rights have been violated (see below).

Make a privacy request

To use any of these rights, call us at (317) 689-7171, write to our Privacy Officer (see “Contact us” below), or email compliance@keyhearingaids.com.

How long we keep your records

We keep client records for at least seven years after your last visit. We may choose to keep them longer, even indefinitely, and they stay securely protected for as long as we keep them. When we no longer keep them, we destroy them securely.

Complaints

If you believe your privacy rights have been violated, you can complain to us by contacting our Privacy Officer. You can also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights:

• online at www.hhs.gov/ocr/complaints;
• by mail to 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;
• by phone at 1-800-368-1019 (TDD 1-800-537-7697).

A complaint to the Office for Civil Rights must generally be filed within 180 days of when you knew, or should have known, of the problem; the Office can extend this for good cause. We will not retaliate against you for filing a complaint.

Changes to this Notice

We reserve the right to change this Notice at any time. Changes will apply to all of the health information we have about you, including information we had before the change. When we make an important change, we will post the new Notice in our office and on our website, and you can ask us for a copy at any time.

Contact us

For questions about this Notice, to use your rights, or to make a complaint, contact: