Privacy Policy

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. 

PLEASE REVIEW THIS NOTICE CAREFULLY.   

Your health record contains personal information about you and your health. This information about you that may identify you and relates to your past, present, or future physical or mental health or condition and related health care services is called Protected Health Information (“PHI”). This Notice of Privacy Practices describes how we may use and disclose your PHI following applicable law, including the Health Insurance Portability and Accountability Act (“HIPAA”), regulations promulgated under HIPAA, including the HIPAA Privacy and Security Rules, and the applicable NASW Code of Ethics. It also describes your rights regarding gaining access to and controlling your PHI.  

We are required by law to maintain PHI's privacy and provide you with notice of our legal duties and privacy practices concerning PHI. We are required to abide by the terms of this Notice of Privacy Practices. We reserve the right to change the terms of our Notice of Privacy Practices at any time. Any new Notice of Privacy Practices will be effective for all PHI we maintain now. We will provide you with a copy of the revised Notice of Privacy Practices by posting a copy on our website, sending a copy to you in the mail upon request, or providing one at your next appointment.  

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU 

  •  For Treatment. Your PHI may be used and disclosed by those involved in your care to provide, coordinate, or manage your healthcare treatment and related services. This includes consultation with clinical supervisors or other treatment team members. We may disclose PHI to any other consultant only with your authorization.  

  • For Payment. We may use and disclose PHI to receive payment for your treatment services. This will only be done with your authorization. Examples of payment-related activities are: deciding on eligibility or coverage for insurance benefits, processing claims with your insurance company, reviewing services provided to you to determine medical necessity, or undertaking utilization review activities. If it becomes necessary to use collection processes due to a lack of payment for services, we will only disclose the minimum amount of PHI necessary for collection purposes.   

  • For Health Care Operations. We may use or disclose, as needed, your PHI to support our business activities, including quality assessment activities, employee review activities, licensing, and conducting or arranging for other business activities. For example, we may share your PHI with third parties that perform various business activities (e.g., billing or typing services) provided we have a written contract with the business that requires it to safeguard the privacy of your PHI.   PHI will be disclosed only with your authorization for training or teaching purposes.  

  • Required by Law. Under the law, we must disclose your PHI to you upon request. In addition, we must make disclosures to the Secretary of the Department of Health and Human Services to investigate or determine our compliance with the requirements of the Privacy Rule. 

  • Without Authorization. Following is a list of the categories of uses and disclosures permitted by HIPAA without authorization. Applicable law and ethical standards permit us to disclose information about you without your authorization only in a limited number of situations. As social workers licensed in this state, we must adhere to more stringent privacy requirements for disclosures without authorization. The following language addresses these categories to the extent consistent with the NASW Code of Ethics and HIPAA. 

    • Child Abuse or Neglect. We may disclose your PHI to a state or local agency authorized by law to receive reports of child abuse or neglect.   

    • Judicial and Administrative Proceedings. We may disclose your PHI under a subpoena (with your written consent), court order, administrative order, or similar process. 

    • Deceased Patients. Based on your prior consent, we may disclose PHI regarding deceased patients as mandated by state law or to a family member or friend involved in your care or payment for care before death. A release of information regarding deceased patients may be limited to an executor or administrator of a deceased person’s estate or the person identified as next-of-kin. PHI of persons deceased for over fifty (50) years is not protected under HIPAA. 

    • Medical Emergencies. We may use or disclose your PHI in a medical emergency to medical personnel only to prevent serious harm. Our staff will try to provide you with a copy of this notice as soon as reasonably practicable after resolving the emergency. 

    • Family Involvement in Care. We may disclose information to close family members or friends directly involved in your treatment based on your consent or as necessary to prevent serious harm. 

    • Health Oversight. If required, we may disclose PHI to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections. Oversight agencies seeking this information include government agencies and organizations that provide financial assistance to the program (such as third-party payors based on your prior consent) and peer review organizations performing utilization and quality control. 

    • Law Enforcement. We may disclose PHI to a law enforcement official as required by law, in compliance with a subpoena (with your written consent), court order, administrative order, or similar document, to identify a suspect, material witness, or missing person, in connection with the victim of a crime, in connection with a deceased person, in connection with the reporting of a crime in an emergency, or in connection with a crime on the premises.

    • Specialized Government Functions. We may review requests from U.S. military command authorities if you have served as a member of the armed forces, authorized officials for national security and intelligence reasons, and to the Department of State for medical suitability determinations, and disclose your PHI based on your written consent, mandatory disclosure laws and the need to prevent serious harm.

    • Public Health. If required, we may use or disclose your PHI for mandatory public health activities to a public health authority authorized by law to collect or receive such information to prevent or control disease, injury, or disability, or if directed by a public health authority, to a government agency that is collaborating with that public health authority.  

    • Public Safety. We may disclose your PHI if necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public. Suppose information is disclosed to prevent or lessen a serious threat. In that case, it will be disclosed to a person or persons reasonably able to prevent or lessen the threat, including the target of the threat.  

    • Research.   PHI may only be disclosed after a unique approval process or with your authorization.  

  • With Authorization.   Uses and disclosures not explicitly permitted by applicable law will be made only with your written authorization, which may be revoked at any time, except to the extent that we have already made a use or disclosure based upon your authorization. The following uses and disclosures will be made only with your written authorization: (i) most uses and disclosures of psychotherapy notes which are separated from the rest of your medical record; (ii) most uses and disclosures of PHI for marketing purposes, including subsidized treatment communications; (iii) disclosures that constitute a sale of PHI; and (iv) other uses and disclosures not described in this Notice of Privacy Practices.  

    • Fundraising. We may send you fundraising communications at one time or another. You can opt out of such fundraising communications with each solicitation you receive. 

    • Verbal Permission. We may also use or disclose your information to family members directly involved in your treatment with your verbal permission. 

YOUR RIGHTS REGARDING YOUR PHI 

  • Right of Access to Inspect and Copy. You have the right, which may be restricted only in exceptional circumstances, to inspect and copy PHI maintained in a “designated record set.” A designated record set contains mental health/medical and billing records and any other records used to make decisions about your care. Your right to inspect and copy PHI will be restricted only in those situations where there is compelling evidence that access would cause serious harm to you or if the information is contained in separately maintained psychotherapy notes. We may charge a reasonable, cost-based fee for copies. If your records are maintained electronically, you may also request an electronic copy of your PHI. You may also request that a copy of your PHI be provided to another person.

  • Right to Amend. If you feel that the PHI we have about you is incorrect or incomplete, you may ask us to amend the information, although we are not required to agree. If we deny your request for amendment, you have the right to file a statement of disagreement with us. We may prepare a rebuttal to your statement and will provide you with a copy. Please get in touch with the Privacy Officer if you have any questions.

  • Right to an Accounting of Disclosures. You have the right to request an accounting of certain disclosures we make of your PHI. We may charge you a reasonable fee if you request more than one accounting in 12 months.

  • Right to Request Restrictions. You have the right to request a restriction or limitation on using or disclosing your PHI for treatment, payment, or health care operations. We are not required to agree to your request unless the request is to restrict disclosure of PHI to a health plan for carrying out payment or health care operations, and the PHI pertains to a health care item or service that you paid for out of pocket. In that case, we are required to honor your request for a restriction.

  • Right to Request Confidential Communication. You have the right to request that we communicate with you about health matters in a certain way or location. We will accommodate reasonable requests. We may require information regarding how payment will be handled or the specification of an alternative address or another method of contact as a condition for accommodating your request. We will not ask you to explain why you are making the request.

  • Breach Notification. If there is a breach of unsecured PHI concerning you, we may be required to notify you of this breach, including what happened and what you can do to protect yourself.

  • Right to a Copy of this Notice. You have the right to a copy of this notice.

COMPLAINTS 

Suppose you believe we have violated your privacy rights. In that case, you can file a written complaint with the Secretary of Health and Human Services at 200 Independence Avenue, S.W.  Washington, D.C. 20201, or by calling (202) 619-0257. We will not retaliate against you for filing a complaint.   

  The effective date of this Notice is March 2024.