All fundraising activities within Covenant Health will be conducted in accordance with the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
The dignity and privacy of each patient and/or resident is incredibly important and must be preserved. The use of patient/resident data for fundraising purposes, while permissible under HIPAA assuming certain safeguards are in place, may only occur for fundraising purposes if the dignity and privacy of the patient/resident is respected. Fundamental to that is giving the patient/resident the opportunity to control when his/her information is shared with the foundation staff.
Reason(s) for the Policy
To provide guidance regarding the use of Protected Health Information (PHI) for fundraising purposes, including the required disclosure statement for fundraising communications and the procedure to follow when a patient requests to opt-out of receiving fundraising communications.
Primary Guidance To Which This Policy Responds
HIPAA Administrative Simplification and Final Omnibus Rule of 2013 45 CFR § 164.514(f)
Who is Governed by This Policy
Covenant Health workforce members.
Exclusions and Special Situations
This policy applies to fundraising activities associated with patient/resident information within Covenant Health
Covenant Health may use certain protected health information (“PHI”) for fundraising purposes but, must allow patients to opt-out of receiving future fundraising communications.
- The following protected health information may be used by Covenant Health for fundraising purposes
- demographic information (e.g., name, suffix, title, address, date of birth/age, gender, language, race, ethnicity, marital status, email addresses, telephone numbers, minors’ guarantor information)
- health insurance
- department of service, and location of service
- provider name and specialty
- date(s) of service (excluding future appointments)
- treatment outcome (deceased only)
- Patient ID/EPIC MRN – used to suppress patients who opt-out of fundraising, data management and included in gift officer reports for meetings with faculty
- Patients have the right to opt-out of receiving fundraising communications. The foundation office maintains a list of individuals who have requested not to be contacted for fundraising purposes.
- Any Covenant Health workforce member that is informed of a request to opt-out of receiving fundraising communications by a patient or his/her designated representative should direct that person to contact the foundation office to process the request. The individual may email Development at foundation@covh.org.
- Before contacting a patient for fundraising purposes:
- The sender of the communication must contact the foundation office at foundation@covh.org or 212-305-9526 to verify that an opt-out request is not on file for that individual.
- All written, electronic, or verbal communications for a fundraising purpose must clearly inform the patient that they have the right to opt-out of receiving future communications and how to exercise this right.
- Information mailed or emailed to patients for the purpose of soliciting a donation must include the following required opt-out language:
- Please contact the foundation office at foundation@covh.org if you wish to opt-out of receiving development communications.
- Questions about this policy may be directed to the foundation office.
To opt out of fundraising communications or for questions, please contact the foundation office at foundation@covh.org or 212-305-9526.