Legal & Compliance

Compliant from the Beginning

From its inception, STYMCO Medical has employed full-time legal counsel. General Counsel’s role has been to be active in every aspect of STYMCO‘s development of its processes and program’s. As a result of this input STYMCO is confident that it is in compliance with all of the myriad of state and federal laws and regulations which govern both its business and its providers practices, including HIPAA rules on protecting Patient Health Information. Below you will find specific documents relating to some legal aspects of STYMCO‘s business, including its privacy policy and an outline of its compliance program.

Privacy Policy

STYMCO Medical, LLC (hereinafter, STYMCO) respects your privacy and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information provided or collected through the website. If you have any questions about our website’s Privacy Policy, please contact us at the mailing address, telephone number, or email address at the bottom of this page.

This Privacy Policy will assist you in understanding our practices regarding collection, use and disclosure of information that you may provide via this website. Please read this Privacy Policy carefully so that you understand our company’s privacy practices. By using this website, you are in agreement with the terms of this Privacy Policy and upon submitting any information via this site, you are consenting to the collection, use and disclosure of that information in accordance with this Privacy Policy.

Usage by Children

This website is not designed for use by persons under the age of 18, therefore we do not knowingly collect personal information from children in connection with this website. Children should always get permission from their parents before sending any personal information (i.e. name, address, email address, etc.) over the internet, to us or any other person.

Information Collection

We collect three basic types of information:

  • Information voluntarily supplied by you, when you answer specific questions or submit emails
  • Tracking information gathered as you navigate through our website
  • Privileged patient information protected by HIPPA

How We Collect Your Information

We actively collect information voluntarily supplied by you and not privileged or HIPPA protected. This information may include your full name, address, email address, phone number, demographic or psychographic information. This personal information may be supplied when responding to specific questions or in email correspondences. Some areas of the site request information in order for you to participate in activities, i.e. newsletter registration. Optional Information will be noted and marked as such.

We collect information through technology, such as cookies, flash cookies, and navigational data, which means some data is gathered on the website without you actively providing us with the information. This technology may include:

  • Cookies: Cookies are pieces of information that a website places on the hard drive of your computer when you visit the website. Cookies may involve the transmission of information from us to you and from you directly to us. We may use cookies to bring together information we collect about you.
  • Flash Cookies: We may use local shared objects, sometimes known as Flash cookies, to store your preferences or display content based upon what you view on our site to personalize your visit.
  • Session cookies: A session cookie is a piece of information that is enabled only during a particular website session. It provides statistical information as well as helps make improvements in website navigation. Session cookie files are deleted after logging off the Internet browser or powering off your computer.
  • IP (Internet Protocol) addresses: The IP address of your computer is a number automatically assigned to your computer by your Internet Service Provider (ISP). This number allows access to the Internet and is considered non-personally identifiable in nature. Collecting IP Addresses is standard practice on the Internet and is done automatically by many websites.
  • Other Information: This information typically does not reveal your specific identity; such as server log files, browser information, navigational data, information collected by cookies, location information, and aggregated information. Navigational data is used for marketing research, content improvement and system management purposes.

Non-HIPPA Protected Information Use and Disclosure

To serve you better, we may combine actively collected information with personally identifiable information to communicate information to you (upon your request), for marketing and research purposes, for website personalization or for purposes as outlined in this Privacy Policy. We will take reasonable measures to prevent personally identifiable information from being combined with passively collected information, unless you consent otherwise.

We may disclose your personally identifiable, non-HIPPA protected information to our partners in the US and internationally, upon their agreement to treat it in accordance with this Privacy Policy. Additionally, we may disclose your personally identifiable non-HIPPA protected information to third parties, located in the United States and/or internationally, specifically:

  • to contractors we use to support our business (e.g., fulfillment services, technical support, delivery services, and financial institutions); in these cases we will require third parties to agree to treat it in accordance with this Privacy Policy;
  • in connection with the sale, assignment, or other transfer of the business of this site to which the information relates; in these cases we will require any such buyer to agree to treat it in accordance with this Privacy Policy; or
  • where required by applicable laws, subpoena, court orders, or government regulations.

In addition, we will make full use of all information acquired through this site that is not in personally identifiable form.

To keep your personally identifiable information current and accurate, please contact us as specified below. We will take reasonable steps to update or correct personally identifiable information in our possession that you have previously submitted via this site.

HIPPA Protected and Privileged Information

STYMCO has created separate and distract protected website portals, pages or links for the purpose of receiving, storing, protecting and releasing or disclosing Protected Healthcare Information (PHI), including identifiers which would connect a patient to a specific health care record. Protected health care information (PHI) about patients and certain information about their health care provider are protected by federal law (HIPPA).This includes information from medical records concerning health history, laboratory and diagnostic testing results, diagnosis, treatment plans and prescription orders among other data and information and any information that would identify a specific medical record as belonging to a specific patient. All of the information provided by STYMCO through the proper portal or channel shall be kept strictly confidential and is not shared with anyone outside the company, nor anyone within the company who doesn’t have a reasonable need to know it, absent a written consent from the patient. While HIPPA does allow disclosure of certain PHI to third parties with the patient’s informed and written consent, STYMCO does not currently make such disclosures and will not disclose such PHI until the patient has received a HIPPA- compliant request form and has provided written consent to such disclosure. Finally HIPPA requires each patient to be promptly notified of any breach of STYMCO‘s computerized or other records which is reasonably believed to have the potential of, or has actually resulted in, a disclosure of a patient’s PHI within a reasonable period of time of not more than sixty (60) days from STYMCO‘s discovery of the breach.

Questions or Complaints

It is STYMCO‘s policy that all privacy complaints relating to the protection of health information be investigated in a timely manner. If you have any questions or concerns about our privacy practices or feel your privacy rights have been violated, please contact STYMCO‘s Privacy Officer at the address listed below.

You may file a Privacy Complaint at any time, if you feel your privacy rights have been violated. All complaints or concerns must be submitted to this office in writing at the address listed below. You may also file a written complaint to the Office for Civil Rights (OCR) of the United States Department of Health and Human Services, 200 Independence Avenue, SW, Room 509F, Washington, D.C. 20201. Or you may contact the OCR Hotline at 1-800-368-1019.

STYMCO supports your right to the privacy of your medical information. We will not retaliate in any way if you choose to file a complaint with us or with the U.S. Department of Health and Human Services.

Site Security

We use reasonable organizational, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure or error free. Such information will be reasonably protected from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. E-mail sent to or from this site may not be secure; caution and discretion should be used when sending personally identifiable information.

Third Party Web Sites

This site contains links or references to other Web sites. This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including any third party operating any site to which the Sites contain a link. The inclusion of a website link on the Site does not imply endorsement of the linked site by us or by our affiliates. Any information that you provide through use of this functionality is governed by the applicable third party’s privacy policy, and not by this Privacy Policy. We have no control over, and shall not be responsible for, any third party’s use of information that you provide through use of this functionality. We do not control other Web sites and this Privacy Policy does not apply to other Web sites.

Contact Us

If you have any questions about this Privacy Policy or the information practices of this site, please contact us as follows:

STYMCO Medical
7624 Bald Cypress Place
Tampa, Florida 33614
Email: privacyofficer@stymco.com
Phone 855-672-4174

Updates to This Privacy Policy

We may change this Privacy Policy; the revised policy will be posted on this site. Please check back periodically, and especially before you provide any personally identifiable information. Your use of the Sites following these changes means that you accept the revised Privacy Policy. This Privacy Policy was last updated on December 10, 2013.

Summary of the Florida Patient’s Bill of Rights and Responsibilities

Florida law requires that your health care provider or health care facility recognize your rights while you are receiving medical care and that you respect the health care provider’s or health care facility’s right to expect certain behavior on the part of patients. You may request a copy of the full text of this law from your health care provider or health care facility. A summary of your rights and responsibilities follows:

As a patient who has received a prescription for an electrotherapy device you have the right to have that prescription filled by the provider of your choice.

A patient has the right to be treated with courtesy and respect, with appreciation of his or her individual dignity, and with protection of his or her need for privacy.

A patient has the right to a prompt and reasonable response to questions and requests.

A patient has the right to know who is providing medical services and who is responsible for his or her care.

A patient has the right to know what patient support services are available, including whether an interpreter is available if he or she does not speak English.

A patient has the right to know what rules and regulations apply to his or her conduct.

A patient has the right to be given by the health care provider information concerning diagnosis, planned course of treatment, alternatives, risks, and prognosis.

A patient has the right to refuse any treatment, except as otherwise provided by law.

A patient has the right to be given, upon request, full information and necessary counseling on the availability of known financial resources for his or her care.

A patient who is eligible for Medicare has the right to know, upon request and in advance of treatment, whether the health care provider or health care facility accepts the Medicare assignment rate.

A patient has the right to receive, upon request, prior to treatment, a reasonable estimate of charges for medical care.

A patient has the right to receive a copy of a reasonably clear and understandable, itemized bill and, upon request, to have the charges explained.

A patient has the right to impartial access to medical treatment or accommodations, regardless of race, national origin, religion, handicap, or source of payment.

A patient has the right to treatment for any emergency medical condition that will deteriorate from failure to provide treatment.

A patient has the right to know if medical treatment is for purposes of experimental research and to give his or her consent or refusal to participate in such experimental research.

A patient has the right to express grievances regarding any violation of his or her rights, as stated in Florida law, through the grievance procedure of the health care provider or health care facility which served him or her and to the appropriate state licensing agency.

A patient is responsible for providing to the health care provider, to the best of his or her knowledge, accurate and complete information about present complaints, past illnesses, hospitalizations, medications, and other matters relating to his or her health.

A patient is responsible for reporting unexpected changes in his or her condition to the health care provider.

A patient is responsible for reporting to the health care provider whether he or she comprehends a contemplated course of action and what is expected of him or her.

A patient is responsible for following the treatment plan recommended by the health care provider.

A patient is responsible for keeping appointments and, when he or she is unable to do so for any reason, for notifying the health care provider or health care facility.

A patient is responsible for his or her actions if he or she refuses treatment or does not follow the health care provider’s instructions.

A patient is responsible for assuring that the financial obligations of his or her health care are fulfilled as promptly as possible.

A patient is responsible for following health care facility rules and regulations affecting patient care and conduct.

Compliance Program

To insure that STYMCO meets it’s started goals and objectives of providing high quality products and industry leading services while remaining in compliance with all applicable federal and state laws, and to protect STYMCO from conduct by providers or independent contractors which is contrary to STYMCO‘s established policies and procedures, and to insure that all patients using STYMCO provided devices and services are ethically treated and provided the goods and services they have contracted for and are entitled to, STYMCO has established written policies and procedures and is implementing this program of investigation and review to identify and correct departures from said policies and procedures, identify and change or stop questionable or inappropriate practices, and to identify areas where new or different policies, procedures or practices need to be created or implemented and to insure continued compliance with state and federal laws.

The compliance program will use relevant methods of data testing and review, random audits and compliance reviews as precursor identifiers of employees, providers, Independent contractors or other entities which should be, or whose practices should be, more carefully examined or audited by management. Three particular aspects of the business will provide the base data sources for the program (Internal controls, Utilization Review, General practice Audits) as more specifically outlined below.

INTERNAL CONTROLS

Each manager within STYMCO is responsible for monitoring the conduct of the employees under the control of the manager to insure strict compliance with STYMCO‘s written policies and procedures and the terms of conditions of the employment and independent contractor agreements. Each employee of STYMCO is responsible for their own adherence to all policies, procedures and terms of employment and must report to designated management any departure from the practice standards.

The primary purpose of these internal controls is to identify and correct departures from the practice standards, particularly those which could lead to violation of an applicable law or regulation and to deter such conduct in the future. The second purpose is to identify practice standards that need to be clarified or modified.

A regular routine and random review of data such as sales numbers will be used to identify patterns or aberrant numbers that suggest further review is appropriate.

A quarterly review of all complaints received to identify continuing or related problems will part of the same internal process.

UTILIZATION REVIEW

Staff will track and bring to management’s attention any provider conduct with which staff has issues with the diagnostic coding used or questions a particular claim of medical necessity. While STYMCO does not, and will not, counsel providers on diagnostic decisions, selection of treatment modalities, or second guess claims of medical necessity a pattern of provider decisions by a specific provider which staff finds concerning should and will trigger an internal review of that providers practices. In an appropriate circumstance STYMCO may: ask for more information from the Provider (including medical records); obtain an independent peer review of the Providers practices; or conduct a site visit audit (which may include peer review).

STYMCO will use monthly reports to identify indices of possible over – utilization of electrotherapy by a particular provider. STYMCO does not pay referral fees as its payments for services actually provided after a medical necessary prescription has been issued is not intended to, and will not be allowed to, induce over- utilization of electrotherapy or electrotherapy devices. The data will be reviewed to identify Providers whose practices seem markedly different from similar practices in similar circumstances within Providers’ state or community. All orders will be reviewed to insure the patient is NOT a Medicare, Medicaid or other state or government funded program patient.

GENERAL ROUTINE AUDITS

The five-day and thirty-day follow- ups questionnaires will be used to inquire of patients to learn whether or not Providers are acting in conformance with the Provider Agreements, particularly as to fitting and monitoring services for which the Provider may bill STYMCO. Using these third-party “auditors” any reported failure to strictly comply with the Provider Agreement will be immediately brought to the attention of management for review.

Implementation of the Compliance program should be the responsibility of all STYMCO staff. Authority for insuring the effectiveness of the Compliance Program shall be vested in the President and General Counsel of the company.

To enforce the Compliance Program General Counsel may recommend any and all appropriate action including termination of an employee, independent contractor, or provider.

All perceived non-compliance issues shall be reported to General Counsel using the attached form.

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