Privacy Practices
“Confidential Information” means information that is exempt from disclosure to the public or other unauthorized persons under Chapter 42.56 RCW or other federal or state laws. Confidential Information includes, but is not limited to, protected health information as defined by the federal rules adopted to implement the Health Insurance Portability and
Accountability Act of 1996, 42 USC §1320d (HIPAA), and Personal Information.
“Personal Information” means information identifiable to any person, including, but not limited to, information that relates to a person’s name, health, finances, education, business, use or receipt of governmental services or other activities, addresses, telephone numbers, social security numbers, driver license numbers, other identifying numbers, and any financial identifiers or as otherwise identified in RCW 42.56.230.
Mobile Information and SMS Consent
2 Nurses Contracting, LLC does not sell, rent, or share mobile information with third parties or affiliates for marketing or promotional purposes. Mobile information includes mobile telephone numbers, SMS opt-in information, and SMS consent records.
We may disclose mobile information to service providers solely as necessary to operate and support our SMS messaging services. Such service providers are permitted to use the information only to provide services on our behalf.
SMS opt-in data and consent will not be shared with any third parties or affiliates for their own marketing or promotional purposes.
REGULATORY REQUIREMENTS AND PENALTIES
Washington State laws (including RCW 74.04.060and RCW 70.02.020) and federal regulations (including HIPAA Privacy and Security Rules; 42 CFR, Part 2; 42 CFR Part 431) prohibit unauthorized access, use, or disclosure of Confidential Information.
Violation of these laws may result in criminal or civil penalties or fines. You may face civil penalties for violating HIPAA Privacy and Security Rules up to $50,000 per violation and up to $1,500,000 per calendar year as well as criminal penalties up to $250,000 and ten years imprisonment.
ASSURANCE OF CONFIDENTIALITY
Employees of 2 Nurses Contracting having access to Private and Confidential Information:
1. Will not use, publish, transfer, sell or otherwise disclose any Confidential Information gained by reason of this agreement for any purpose that is not directly connected with the performance of the contracted services except as allowed by law.
2. Will protect and maintain all Confidential Information gained by reason this agreement against unauthorized use, access, disclosure, modification or loss.
3. Will employ reasonable security measures, including restricting access to Confidential Information by physically securing any computers, documents, or other media containing Confidential Information.
4. Have an authorized business requirement to access and use 2 Nurses Contracting, LLC systems or property, and view its data and Confidential Information if necessary.
5. Will access, use and/or disclose only the “minimum necessary” Confidential Information
6. Will not share 2 Nurses Contracting, LLC system passwords with anyone or allow others to use the 2 Nurses Contracting, LLC systems logged in as another user.
7. Will not take screen shots, photos, distribute, transfer, or otherwise share any 2 Nurses Contracting, LLC software with anyone.
8. Understand the penalties and sanctions associated with unauthorized access or disclosure of Confidential Information.
Nurse Delegation Notices and Agreements
Policies and Procedures
A qualified caregiver may be delegated to perform nursing care services beyond their usual and customary roles under the direction and supervision of licensed nurses under WAC 246-840-930 and RCW 18.79.260. A caregiver may be a NAC, HCA-C, NAR or Exempt LTCW and must have completed the Nurse Delegation Certification and have current credentials to be eligible to provide delegated care tasks.
Caregivers are prohibited from performing any licensed nurse functions that are specifically defined in the Board of Nursing Rules and those that require nursing assessment or diagnosis, establishment of a plan or care or teaching, that exercises nursing judgement, or procedures requiring specialized nursing knowledge, skills or techniques (eg. Sterile procedures, central line care, or any care for unstable conditions.)
The Registered Nurse Delegator (RND) will be familiar with specific facility policies, procedures and available supplies and staffing as well as rules and regulations governing delegation and nursing care.
RND will assess the nursing care needs and services that may be delegated for the client. If a task cannot be delegated RND will make arrangements for outside services to provide care.
Decisions concerning delegation will be determined in accordance with the provisions outlined in the WAC for Nurse Delegation on ALTSA webpage resources.
RND will monitor the caregiver for competence in the performance of specific task being considered for delegation and provide additional training as needed to safely perform task. Certifications will be completed at a minimum of every 90 days or as needed for changes in client condition or caregiver status.
RND will monitor the condition of the client, update the plan of care and modify delegated tasks as needed to meet the needs of the client. Changes in care, to include medication changes and orders, will be communicated to the caregiver and further education and instruction will be provided as necessary. Caregivers will report any changes in client condition or medications to Nurse Delegator within 24 hours, and the RND will respond within a 24 hour business time period.
RND will document the delegation, supervision, corrective action and initiate rescinding of delegation if needed in the Nurse Delegation Binder located in the residence. RND may also provide direct nursing services, assessments and training related to Skin Observation Protocol. All Delegation records are required to remain on site for 7 years.
Notice of Privacy Practices and HIPAA
When it comes to your health information, you have certain rights. This notice describes how medical information about you may be used and disclosed and how you can obtain access to the information. Please review it carefully.
Your Rights:
Get an electronic or paper copy of your medical record
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You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
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We will provide a copy or summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost based fee for this.
Ask us to correct your medical record
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You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
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We may say “no” to your request, but we will tell you why in writing within 60 days.
Request confidential communications
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You can ask us to contact you using a specific method (for example home or office phone) or to send mail to a different address.
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We will say “yes” to all reasonable requests.
Ask us to limit use or share
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You can ask us not to use or share certain health information for treatment, payment, or our operations.
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We are not required to agree to your request, and we may say “no” if it affects your care.
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If you pay for a service or health care item out of pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer.
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We will say “yes” unless a law requires us to share that information.
Get a list of those with whom we’ve shared information
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You can ask for a list accounting of the times we have shared your health information for six years prior to the date you ask, who we shared it with, and why.
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We will include all of the disclosures except for those about treatment, health care operations and certain other disclosures (such as any you asked us to make). We will provide one accounting a year free of charge, but will charge a reasonable, cost based fee if you request another within a 12 month period.
Get a copy of this privacy notice
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You can ask for a paper copy of this notice at any time, even if you have agreed to receive this notice electronically. We will provide you with a paper copy promptly.
Choose someone to act for you
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If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
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We will make sure the person has this authority and can act for you before we take any action.
File a complaint if you feel your rights are violated
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You can contact us to file a complaint if you feel we have violated rights by contacting us.
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You can file a complaint with the U.S. Department of Health and Human Services Office using one of the following methods. We will not retaliate against you for filing a complaint.
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Sending a letter to: 200 Independence Avenue SW Washington, D.C. 20201
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Calling: 1-877-696-6775
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Visiting: www.hhs.gov/ocr/privacy/hipaa.complaints
We are required by law to maintain the privacy and security of your protected health information.
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We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
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We must follow the duties and privacy practices described in this notice and provide a copy to you.
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We will not use or share your information other than as described in this notice unless you give us permission in writing. If you give us permission to, you may change your mind at any time. Let us know in writing if you change your mind. For additional information please visit:
Changes to the Terms of This Notice
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We can change the terms of this notice, and the changes will apply to all of the information we have about you. The new notice will be available upon request, in our office, and on our website.
This Notice of Privacy Practices applies to the following organizations.
2 Nurses Contracting, LLC
Anita Brighton RN, COS-C, RND
Warren Brighton RN
Revised 07/22/2022
Digital Photo Consent
Origination Date: 04/11/2023
Revision Date:
Medical Staff Approval Date: 04/11/2023
Purpose:
2 Nurses Contracting is committed to providing high-quality healthcare to its clients. As such, the use of clinical photography is limited to the purposes of diagnosis, documentation, treatment, and professional education. This policy establishes guidelines for managing multimedia imaging of patients. For the purpose of this policy, multimedia imaging includes photography, videotaping, audiotaping and drawings.
Policy:
Clinical photography of patients may be appropriate for the diagnosis and treatment of medical conditions as well as professional education. Clinical photography can be accomplished through a variety of multimedia technology to collect, analyze, and store client protected health information. Use of these medias will be carefully controlled and executed in compliance with all state and federal regulations as well as other organizational policies and procedures.
All photographs must be appropriately identified with patient name and a second identifier.
Any disclosure of clinical photography is considered the release of protected health information and must follow all applicable organizational policies.
Clinical photography is considered a routine practice of the care and treatment of patients and is covered within the general admission consent to treat.
Clinical photography includes images carried out by patients, family members, and visitors. If at any time it is felt by 2 Nurses Contracting that the imaging process is not in the best interest of the client or organization, the organization may request the individual processing the images to discontinue. Failure to comply with this request may result in the termination of the client care relationship or other relationship with the organization.
Clinical photography does not include photography of patients for the purposes of promotion, artwork, or advertising of 2 Nurses Contracting.
Clinical photography is defined as any videotaping, filming, or still photography of clients and includes, but is not limited to:
Pictures of pressure ulcers or wounds
Videotapes of nursing procedures
Pictures illustrating abuse, neglect, assaults, or accidents
Pictures of clients taken for the purpose of identification
Pictures of Medications, Orders, Documents, Equipment, Signatures, Supplies
Clinical photographs, video, media must be uploaded to the EHR or other and deleted from the device afterward.
Consent:
The use of clinical photography is considered routine to client care and is covered under the general admission consent to treat form.
The patient or responsible party must be informed prior to the photography of the use and purpose of the picture.
The patient or responsible party has the right to refuse.
The patient or responsible party has the right to withdraw consent at any time by contacting the compliance officer nurses@2nursescontracting.com
Releasing Clinical Photographs:
Once taken, clinical photographs become a permanent part of the legal health record and can be released as such according to state and federal regulations.
Clinical photographs must be identified in the record with the appropriate patient-identifiable information including patient name and a second identifier.
Requests for disclosures of clinical photography for the purposes of treatment, payment, or operations do not require client consent.
Requests for external disclosures of clinical photography that are not for treatment, payment, or operations requires the patient’s informed consent prior to the release. Examples or external disclosures requiring authorization include, but are not limited to:
Requests by law enforcement
Requests by social services
Requests by marketing
Newborn photographs available for purchase
Record Retention:
Clinical photographs are considered a part of the legal health record.
Images will be maintained in accordance with all organizational record retention policies and procedures.
Use of Cell Phones as Imaging Devices:
The use of cell phones as imaging devices is allowed by staff. Cell phones are allowed in client care areas, and may be used by staff while on duty.
While it is impossible for 2 Nurses Contracting to control the number and use of cell phones that may enter the hospital by patients and families, the use of cell phones as an imaging device must follow the guidelines as outlined in this policy. If at any time it is felt by 2 Nurses Contracting that the imaging process is not in the best interest of the client or organization, the organization may request the individual processing the images to discontinue. Failure to comply with this request may result in the termination of the patient care relationship or other relationship with the organization.
Corrective Discipline:
Failure to follow the clinical photography policy may result in the corrective disciplinary process up to and including termination.
Examples of inappropriate photographs include a:
Staff using a general authorization as consent for release of a clinical photograph in a nursing publication
Staff using a photograph in a research paper published in a national magazine without authorization
Article citation:
AHIMA. "Sample Consent for Clinical Photography, Videotaping, Audiotaping, and Other Multimedia Imaging of Patients." Journal of AHIMA (April 2010): web extra.
Electronic Signature Consent
Origination Date: 04/11/2023
Revision Date:
Medical Staff Approval Date: 04/11/2023
Electronic Signature Consent
I,_________, agree and understand that by signing the Electronic Signature Acknowledgment and Consent Form, that all electronic signatures are the legal equivalent of my manual/handwritten signature and I consent to be legally bound to this agreement. I further agree my signature on this document is as valid as if I signed the document in writing. This is to be used in conjunction with the use of electronic signatures on all forms regarding any and all future documentation with a signature requirement, should I elect to have signed electronically.
SMS Policy
Revision Date: 10/25/2026
Medical Staff Approval Date: 10/25/2026
SMS/Text Messaging Terms of Service
To opt in to the text messaging service (the“Service”), text JOIN to 253-905-0156. By texting JOIN, you consent to receive recurring text messages from 2 Nurses Contracting, LLC at the mobile telephone number from which you send the JOIN request and agree to these SMS/Text Messaging Terms of Service (the“Terms”).
1. SMS Opt-In
To subscribe to the Service, text JOIN to 253-905-0156.
By texting JOIN, you affirmatively consent to receive recurring text messages from 2 Nurses Contracting, LLC at the mobile telephone number from which you send the JOIN request.
Messages may include communications regarding services, scheduling, reminders, notifications, requests for information, account-related matters, and other communications related to your relationship with 2 Nurses Contracting, LLC.
Messages may be sent using automated or computer-assisted technology when applicable.
2. Consent Is Not Required for Services
Your consent to receive text messages is not a condition of purchasing or receiving any other goods or services from 2 Nurses Contracting, LLC.
3. Message Frequency and Charges
Message frequency varies depending on your interactions with 2 Nurses Contracting, LLC and the services you receive.
Message and data rates may apply. You are responsible for any messaging or data charges imposed by your wireless carrier. 2 Nurses Contracting, LLC is not responsible for such charges.
4. Opting Out
You may opt out of receiving text messages at any time by replying STOP to 253-905-0156.
After submitting an opt-out request, you may receive a one-time text message confirming that you have been unsubscribed. After that confirmation, you will no longer receive text messages covered by your opt-out unless you subsequently opt in again.
To rejoin the Service after opting out, text JOIN to 253-905-0156.
5. Help and Support
For assistance with the Service, reply HELP to 253-905-0156 or contact:
2 Nurses Contracting, LLC
Email: nurses@2nursescontracting.com
6. Wireless Carrier Disclaimer
Wireless carriers are not liable for delayed or undelivered messages. Message delivery may be affected by your wireless service, device, network availability, or other circumstances outside the control of 2 Nurses Contracting, LLC.
7. Access to Your Mobile Device
You understand that anyone with access to your mobile device may be able to view text messages you receive from 2 Nurses Contracting, LLC. You are responsible for controlling access to your device and mobile telephone number.
8. Changes to Your Mobile Number
If you discontinue or change the mobile telephone number used to enroll in the Service, please notify 2 Nurses Contracting, LLC so that our records can be updated.
9. Privacy
Information collected and used in connection with the Service is subject to the 2 Nurses Contracting, LLC Privacy Policy.
Mobile information, including mobile telephone numbers, SMS opt-in data, and consent information, will not be shared, sold, rented, or disclosed to third parties or affiliates for their own marketing or promotional purposes.
Information may be shared with service providers as necessary to provide and support the Service. Such service providers may use the information only as necessary to provide services on behalf of 2 Nurses Contracting, LLC and may not use the information for their own marketing or promotional purposes.
SMS opt-in consent and related information will not be shared with third parties or affiliates for their own marketing or promotional purposes.
10. Changes to the Service or Terms
2 Nurses Contracting, LLC may modify or discontinue the Service or update these Terms as permitted by applicable law.
