TITLE:

FUNDRAISING

POLICY:
Columbia University Medical Center will conduct fundraising activities in accordance with city, state, and federal laws and regulations, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

PURPOSE :
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) limits the use and disclosure of a patient's Protected Health Information (PHI) for fundraising purposes. Columbia University Medical Center is committed to protecting the privacy of its patients and the confidentiality of their PHI as mandated by city, state, and federal laws and regulations, including HIPAA.

This Policy describes when and how Columbia University Medical Center will use or disclose patients' PHI for fundraising purposes and the procedures a patient must execute if he/she wants to opt out of being contacted for fundraising efforts.

PROCEDURES:

1. Permitted uses and disclosures of PHI for fundraising purposes..
1. Columbia University Medical Center will disclose PHI only:
1. the Office of Development, which conducts fundraising efforts on behalf of Columbia University Medical Center; or



2. to business associates who are conducting fundraising activities for Columbia University Medical Center.


2. PHI that is disclosed by Columbia University Medical Center for fundraising purposes will be used to benefit Columbia University Medical Center.



3. Unless otherwise authorized by the patient, the patient's PHI that will be used or disclosed for fundraising purposes will be limited to:
1. the patient's demographic information; and



2. the dates on which health care services were provided to the patient.


2. Notifying the patient.
1. The Columbia University Medical Center Notice of Privacy Practices (NOPP) will include a statement that the patient may be contacted to raise funds for Columbia University Medical Center.



2. The Columbia University Medical Center NOPP will also include a statement that the patient may elect to opt out of being contacted in future fundraising efforts.



3. All fundraising materials sent to the patient will include instructions for how the patient may opt out of receiving further fundraising communications from Columbia University Medical Center.
1. The opt-out language in the materials will include the contact person at Columbia University Medical Center to whom the patient's request to opt-out should be directed.



2. All fundraising opt-out requests received by Columbia University Medical Center will be forwarded to Britton Ward in the Office of Development (bw2159@columbia.edu).


3. Reasonable efforts to comply with opt-out requests. Columbia University Medical Center will make reasonable efforts to ensure compliance with a patient's opt-out request.



4. Definitions
Protected Health Information is information about a patient, including demographic information that may identify a patient, that relates to the patient's past, present or future physical or mental health or condition, related health care services or payment for health care services.

RESPONSIBILITY:         Departments, HIPAA Privacy Officer