Health Information
This section applies to the information and records we have about student's health status as obtained from the release of liability signed by participants on each NAIOMT course. Health information may include information created and received by our office or in the classroom, it may be in the form of written or electronic records or spoken words and it may include information about a student's health history, health status, symptoms, examinations, test results, diagnoses, treatments, procedures, prescriptions, related billing activity and similar types of health-related information.

We will provide a NOTICE OF PRIVACY PRACTICE to each student enrolled in our classes. The notice will tell the student about the ways in which we may use and disclose their health information and describes each student's rights and our obligations regarding the use and disclosure of that information.

How We May Use and Disclose Health Information.
Health information may be disclosed and shared with different NAIOMT personnel, faculty and lab assistants in order to ensure the safety of the individuals on the course since most if not all of the NAIOMT courses have a practical/laboratory manual therapy component which may, in rare instances, cause injury. Health information may also need to be disclosed to other health care providers in case of injury to the student on a NAIOMT course.

Other Circumstances

1. Required by Law - We will disclose health information when required to do so by Federal, State or local law.
2. Research - We may use and disclose health information for research projects that are subject to a special approval process. The patient will be asked for permission if the researcher will have access to the student's name, address or other information that reveals who they are.
3. Worker's Compensation - We may release health information about a student for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.
4. Public Health Risks - We may disclose health information about a student for public health reasons in order to prevent or control disease, injury or disability; or report suspected abuse or neglect, non-accidental physical injuries or problems with products.
5. Lawsuits and Disputes - If a student is involved in a lawsuit or a dispute, we may disclose health information about the student in response to a court or administrative order. Subject to all applicable legal requirements, we may also disclose health information in response to a subpoena.
6. Law Enforcement - We may release information if asked to do so by a law enforcement official in response to a court order, subpoena, warrant, summons or similar process, subject to all applicable legal requirements.
7. Family and Friends - We may disclose health information about a student to the student's family member or friends if we obtain verbal agreement to do so from the student or if we give the student an opportunity to object to such a disclosure and the student does not raise an objection. In situations where a student is not capable of giving consent (due to incapacity or medical emergency), we may, by using our professional judgment, determine that a disclosure to a family member or friend is in the student's best interest. In that situation, we will disclose only health information relevant to the person's involvement in the students care.

HIPPA Compliance Officer
North American Institute of Orthopaedic Manual Therapy (NAIOMT) has assigned the responsibility of Privacy Officer and compliance with HIPPA regulations to William Temes. The Privacy Officer can be contacted at the following address:

NAIOMT
Attn: Privacy Officer
PO BOX 1574
Eugene, OR 97401

Confidentiality of Student Information Stored in Electronic Forms

Student's information maintained in electronic files will be protected through the use of passwords on computer terminals and stations. Computer hardware will be located in secure locations with appropriate security measures in place. Security measures will include firewalls and anti-virus software, and may include auto-logoff activation or other access technologies as they become available.

NAIOMT will maintain backups of all computer systems and data storage units to enable disaster data retrieval. Company data files will have on-site and off-site storage of records.

Additionally, NAIOMT will maintain the confidentiality of protected health information by following each of these additional requirements:

• FAX information   NAIOMT will take reasonable precautions to assure that the recipient of the faxed information can be identified and is authorized to receive such protected health information. Fax machines that receive information will be located in an area where access is limited to the appropriate personnel.
  
• Email   NAIOMT will take reasonable precautions when emailing medical information which may include, but may not be limited to the use of password protection, encryption and authentication.

All student records will be maintained in secure areas with appropriate fire protection and locked doors. Pursuant to the Minimum Necessary Standard, NAIOMT will ensure that only employees that require access to student information will have access to the files stored in paper formats.

Confidentiality of Student Info Transmitted Through Oral Means of Communication

Employees of NAIOMT will not discuss student sensitive information in an unsecured area or within the hearing area of any third parties not covered by applicable Authorizations or otherwise specifically permitted to receive such information under the Regulations. Student information can be collected and transmitted via telephone; however, confidential student information will not be left on an answering machine unless NAIOMT has obtained specific authorization from the student to leave such information on an answering machine. The use of a speaker phone by the employee is prohibited if there is any reasonable chance of an unauthorized third party hearing such information.

Compliance Requirements

NAIOMT is required to establish privacy conscious business practices. These include, but are not limited to:

• Performing initial training of staff and independent contractors, complete with annual training updates concerning privacy issues;
• Designating a "Privacy Officer"; and ensuring that appropriate safeguards are established and maintained in order to protect personally identifiable health information.