Privacy Policy

This notice describes how your medical information may be used or disclosed and how you can gain access to it. Please read this notice carefully.

The Health Insurance Portability and Accountability Act (HIPAA) of 1996 is a federal program that requires strict confidentiality for all your personal health information. That includes all your medical and dental information used or disclosed by us in any form, whether electronic, written or verbal. The Act gives you significant rights to understand and control how your health information is used. The Act also provides penalties for the misuse of Protected Health Information (PHI).

PHI is any information about you, including demographic data that identifies you and your past, present or future physical or mental health condition, as well as related healthcare services. This Privacy Policy describes how we may use or disclose your PHI to provide treatment, payment or healthcare operations or other purposes that are permitted or required by law. This policy also describes your rights to access and control your PHI.

USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION

Your PHI may be used or disclosed by our physician, office staff or others involved in your care and treatment, whether providing healthcare services to you, paying your healthcare bills, supporting the operation of our practice or any other lawful use.

Treatment: We will use and disclose your PHI to provide, coordinate or manage your healthcare and related services. This includes the coordination or management of your healthcare by a third party. For example, your PHI may be given to a physician you have been referred to in order to ensure that he or she has the necessary information to diagnose or treat you.

Healthcare Operations: We may use or disclose your PHI to support our business activities. These activities may include quality assessment, employee review and conducting or arranging other business activities. We may also use a sign-in sheet at the registration desk where you will be asked to sign your name and indicate your physician. We may call you by name in our reception area when your physician is ready to see you. We may use or disclose your PHI, as necessary, to contact you to remind you of your appointment. We may phone your home and leave a message (on an answering machine or with the person answering the phone) to remind you of an upcoming appointment, the need to schedule a new appointment or to call our office. We may also mail a postcard reminder or letter to your home address. Please tell us if you prefer that we call or contact you at another phone number or location.

We may use or disclose your PHI under the following circumstances without your authorization. These include, as required by law:

  • Public health issues

  • Communicable diseases

  • Health oversight

  • Abuse or neglect

  • Food and Drug Administration requirements

  • Legal proceedings

  • Law enforcement

  • Coroners, funeral directors and organ donation

  • Medical research

  • Criminal activity; prison inmates

  • Military activity and national security

  • Workers’ Compensation

Required Uses and Disclosures: The law requires us to disclose to you when we are investigated by the Secretary of the Department of Health and Human Services to determine our compliance with HIPAA. Other permitted and required uses and disclosures will be made only with your consent, authorization or opportunity to object unless required by law. You may revoke this authorization in writing at any time except to the extent that your physician or the physician’s practice has taken action in reliance on the use or disclosure indicated in your authorization.

Payment: Your PHI will be used, as needed, to obtain payment for healthcare services. For example, obtaining approval for a hospital stay may require that your relevant PHI be disclosed to your health insurance plan to obtain approval for a hospital admission or a health-related procedure.

YOUR RIGHTS

You have the right to inspect and copy your PHI. Under federal law, however, you may not inspect or copy the following records:

  • Psychotherapy notes

  • Information compiled in reasonable anticipation of, or use in civil, criminal or administrative actions or proceedings

  • PHI that is subject to law prohibiting access to said PHI

You have the right to request a restriction of your health information. This means you may ask us not to use or disclose any part of your PHI for the purposes of treatment, payment or healthcare operations. You may also request nondisclosure of any part of your PHI to family members or friends who may be involved in your care or for notification purposes described in these Privacy Practices. Your request must state the specific restriction and to whom you want the restriction to apply.

Your physician is not required to agree to your requested restriction. If your physician believes it is in your best interests to permit use and disclosure of your PHI, your PHI will not be restricted. You then have the right to use another healthcare professional.

You have the right to request to receive confidential communications from us by alternative means or at an alternative location. You have the right to obtain a paper copy of this Notice from us, upon request, even if you have agreed to accept this Notice alternatively (e.g., electronically).

You have the right to have your physician amend your PHI. If we deny your request for amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your statement and provide you with a copy of any such rebuttal. You have the right to receive an accounting of certain disclosures we have made, if any, of your PHI.

We reserve the right to change the terms of this Notice and will inform you of any changes. You then have the right to object or withdraw as provided in this Notice.

COMPLAINTS

You may complain to us or to the Secretary of Health and Human Services if you believe your privacy rights have been violated by us. You may file a complaint by notifying our privacy officer at our office and main telephone number. We will not retaliate against you for exercising your right to file a complaint.

This Notice was published and is effective on or before 6/1/2010. 

 
 

Anti-Discrimination Policy

Jay Grossman D.D.S INC. (dba Concierge Dentistry) is committed to a work environment in which all individuals are treated with respect and dignity. Everyone has the right to work in a professional atmosphere that promotes equal employment opportunities and prohibits unlawful discriminatory practices, including harassment. Therefore, Jay Grossman D.D.S INC. (dba Concierge Dentistry) expects that all relationships among persons in the office will be business-like and free of explicit bias, prejudice, and harassment.

Jay Grossman D.D.S INC. (dba Concierge Dentistry) has developed this policy to ensure that all its employees can work in an environment free from unlawful harassment, discrimination, and retaliation. Jay Grossman D.D.S INC. (dba Concierge Dentistry) will make every reasonable effort to ensure that all concerned are familiar with these policies and are aware that any complaint in violation of such policies will be investigated and resolved appropriately.

Any employee who has questions or concerns about these policies should talk with Sara Lopez or Dr. Jay Grossman.

These policies should not, and may not, be used as a basis for excluding or separating individuals of a particular gender, or any other protected characteristic, from participating in business or work-related social activities or discussions. In other words, no one should make the mistake of engaging in discrimination or exclusion to avoid allegations of harassment. The law and the policies of Jay Grossman D.D.S INC. (dba Concierge Dentistry) prohibit disparate treatment on the basis of sex or any other protected characteristic, with regard to terms, conditions, privileges and perquisites of employment. The prohibitions against harassment, discrimination and retaliation are intended to complement and further those policies, not to form the basis of an exception to them.

Equal employment opportunity

It is the policy of Jay Grossman D.D.S INC. (dba Concierge Dentistry) to ensure equal employment opportunity without discrimination or harassment on the basis of race, color, religion, sex, sexual orientation, gender identity or expression, age, disability, marital status, citizenship, national origin, genetic information, or any other characteristic protected by law. Jay Grossman D.D.S INC. (dba Concierge Dentistry) prohibits any such discrimination or harassment.

Retaliation

Jay Grossman D.D.S INC. (dba Concierge Dentistry) encourages reporting of all perceived incidents of discrimination or harassment. It is the policy of Jay Grossman D.D.S INC. (dba Concierge Dentistry) to investigate such reports promptly and thoroughly. Jay Grossman D.D.S INC. (dba Concierge Dentistry) prohibits retaliation against any individual who reports discrimination or harassment or participates in an investigation of such reports.

Sexual harassment

Sexual harassment constitutes discrimination and is illegal under federal, state, and local laws. For the purposes of this policy, “sexual harassment” is defined, as in the Equal Employment Opportunity Commission Guidelines, as unwelcome sexual advances, requests for sexual favors and other verbal or physical conduct of a sexual nature when, for example:

a) submission to such conduct is made either explicitly or implicitly a term or condition of an individual’s employment,

b) submission to or rejection of such conduct by an individual is used as the basis for employment decisions affecting such individual, or

c) such conduct has the purpose or effect of unreasonably interfering with an individual’s work performance or creating an intimidating, hostile or offensive working environment.

Title VII of the Civil Rights Act of 1964 recognizes two types of sexual harassment:

a) quid pro quo and

b) hostile work environment.

Sexual harassment may include a range of subtle and not-sosubtle behaviors and may involve individuals of the same or different gender. Depending on the circumstances, these behaviors may include unwanted sexual advances or requests for sexual favors; sexual jokes and innuendo; verbal abuse of a sexual nature; commentary about an individual’s body, sexual prowess, or sexual deficiencies; leering, whistling or touching; insulting or obscene comments or gestures; display in the workplace of sexually suggestive objects or pictures; and other physical, verbal or visual conduct of a sexual nature.

Harassment

Harassment on the basis of any other protected characteristic is also strictly prohibited. Under this policy, harassment is verbal, written or physical conduct that denigrates or shows hostility or aversion toward an individual because of his or her race, color, religion, sex, sexual orientation, gender identity or expression, national origin, age, disability, marital status, citizenship, genetic information, or any other characteristic protected by law, or that of his or her relatives, friends or associates, and that:

a) has the purpose or effect of creating an intimidating, hostile or offensive work environment,

b) has the purpose or effect of unreasonably interfering with an individual’s work performance, or

c) otherwise adversely affects an individual’s employment opportunities.

Harassing conduct includes epithets, slurs or negative stereotyping; threatening, intimidating or hostile acts; denigrating jokes; and written or graphic material that denigrates or shows hostility or aversion toward an individual or group that is placed on walls or elsewhere on the employer’s premises or circulated in the workplace, on company time or using company equipment by e-mail, phone (including voice messages), text messages, social networking sites or other means.

Individuals and Conduct Covered

These policies apply to all applicants and employees, whether related to conduct engaged in by fellow employees or by someone not directly connected to Jay Grossman D.D.S INC. (dba Concierge Dentistry) (e.g., an outside vendor, consultant, or customer).

Conduct prohibited by these policies is unacceptable in the workplace and in any work-related setting outside the workplace, such as during business trips, business meetings and business-related social events.

Reporting an Incident of Harassment, Discrimination or Retaliation

Jay Grossman D.D.S INC. (dba Concierge Dentistry) encourages reporting of all perceived incidents of discrimination, harassment, or retaliation, regardless of the offender’s identity or position. Individuals who believe that they have been the victim of such conduct should discuss their concerns with their immediate supervisor, any member of the personnel practices committee, human resources, or any ombudsman. See the complaint procedure described below.

In addition, Jay Grossman D.D.S INC. (dba Concierge Dentistry) encourages individuals who believe they are being subjected to such conduct to promptly advise the offender that his or her behavior is unwelcome and to request that it be discontinued. Often this action alone will resolve the problem. Jay Grossman D.D.S INC. (dba Concierge Dentistry) recognizes, however, that an individual may prefer to pursue the matter through complaint procedures.

Complaint Procedure

Individuals who believe they have been the victims of conduct prohibited by this policy or believe they have witnessed such conduct should discuss their concerns with their immediate supervisor, human resources, any member of the personnel practices committee (Sara Lopez or Dr. Jay Grossman).

Jay Grossman D.D.S INC. (dba Concierge Dentistry) encourages the prompt reporting of complaints or concerns so that rapid and constructive action can be taken before relationships become irreparably strained. Therefore, while no fixed reporting period has been established, early reporting and intervention have proven to be the most effective method of resolving actual or perceived incidents of harassment.

Any reported allegations of harassment, discrimination or retaliation will be investigated promptly. The investigation may include individual interviews with the parties involved and, where necessary, with individuals who may have observed the alleged conduct or may have other relevant knowledge.

Jay Grossman D.D.S INC. (dba Concierge Dentistry) will maintain confidentiality throughout the investigatory process to the extent consistent with adequate investigation and appropriate corrective action.

Retaliation against an individual for reporting harassment or discrimination or for participating in an investigation of a claim of harassment or discrimination is a serious violation of this policy and, like harassment or discrimination itself, will be subject to disciplinary action. Acts of retaliation should be reported immediately and will be promptly investigated and addressed.

Misconduct constituting harassment, discrimination or retaliation will be dealt with appropriately. Responsive action may include, for example, training, referral to counseling or disciplinary action such as a warning, reprimand, withholding of a promotion or pay increase, reassignment, temporary suspension without pay, or termination, as Jay Grossman D.D.S INC. (dba Concierge Dentistry) believes appropriate under the circumstances.

If a party to a complaint does not agree with its resolution, that party may appeal to Jay Grossman D.D.S INC. (dba Concierge Dentistry)’s executive director or the chief operating officer.

False and malicious complaints of harassment, discrimination, or retaliation (as opposed to complaints that, even if erroneous, are made in good faith) may be the subject of appropriate disciplinary action.

 
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Whistleblower Protection Policy

Jay Grossman D.D.S INC. (dba Concierge Dentistry) requires directors, officers and employees to observe high standards of business and personal ethics in the conduct of their duties and responsibilities. As employees and representatives of the Jay Grossman D.D.S INC. (dba Concierge Dentistry), we must practice honesty and integrity in fulfilling our responsibilities and comply with all applicable laws and regulations.

Reporting Responsibility

This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns internally so that Jay Grossman D.D.S INC. (dba Concierge Dentistry) can address and correct inappropriate conduct and actions. It is the responsibility of all board members, officers, employees, and volunteers to report concerns about violations of Homeless Not Toothless’ code of ethics or suspected violations of law or regulations that govern Jay Grossman D.D.S INC. (dba Concierge Dentistry)’s operations.

No Retaliation

It is contrary to the values of Jay Grossman D.D.S INC. (dba Concierge Dentistry) for anyone to retaliate against any board member, officer, employee, or volunteer who in good faith reports an ethics violation, or a suspected violation of law, such as a complaint of discrimination, or suspected fraud, or suspected violation of any regulation governing the operations of Jay Grossman D.D.S INC. (dba Concierge Dentistry). An employee who retaliates against someone who has reported a violation in good faith is subject to discipline up to and including termination of employment.

Reporting Procedure

Jay Grossman D.D.S INC. (dba Concierge Dentistry) has an open door policy and suggests that employees share their questions, concerns, suggestions or complaints with their supervisor. If you are not comfortable speaking with your supervisor or you are not satisfied with your supervisor’s response, you are encouraged to speak with the current CEO. Supervisors and managers are required to report complaints or concerns about suspected ethical and legal violations in writing to the Jay Grossman D.D.S INC. (dba Concierge Dentistry) CEO, who has the responsibility to investigate all reported complaints. Employees with concerns or complaints may also submit their concerns in writing directly to their supervisor or the CEO.

Executive Director

The Jay Grossman D.D.S INC. (dba Concierge Dentistry) CEO is responsible for ensuring that all complaints about unethical or illegal conduct are investigated and resolved. The Compliance Officer will advise the Board of Directors of all complaints and their resolution and will report at least annually to the Treasurer on compliance activity relating to accounting or alleged financial improprieties.

Accounting and Auditing Matters

The Jay Grossman D.D.S INC. (dba Concierge Dentistry) CEO shall immediately notify the Audit Committee/Finance Committee of any concerns or complaint regarding corporate accounting practices, internal controls or auditing and work with the committee until the matter is resolved.

Acting in Good Faith

Anyone filing a written complaint concerning a violation or suspected violation must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation. Any allegations that prove not to be substantiated and which prove to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offense.

Confidentiality

Violations or suspected violations may be submitted on a confidential basis by the complainant. Reports of violations or suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations

The Jay Grossman D.D.S INC. (dba Concierge Dentistry) CEO will notify the person who submitted a complaint and acknowledge receipt of the reported violation or suspected violation. All reports will be promptly investigated and appropriate corrective action will be taken if warranted by the investigation.