COUNCIL FOR RELATIONSHIPS
NOTICE OF POLICIES AND PRACTICES TO PROTECT THE PRIVACY
OF CLIENTS'/PATIENTS' HEALTH INFORMATION
This notice is given to and signed by CFR's clients, and describes how medical information may be used and disclosed and how they can get access to this information.
Council for Relationships values its clients and protection of their privacy is very important to us. In conducting our business, we will create and maintain records that contain health information about our clients and their health care.
"Protected Health Information" or "PHI" is information that can reasonably be used to identify you and that relates to your past, present or future physical or mental health condition. It includes the provision of health care to you and the payment for that care.
This Notice describes Council for Relationships' privacy practices, which include how we may use, disclose, collect, handle, and protect our clients' Protected Health Information. We are required by new federal and state laws to maintain the privacy of your Protected Health Information. We also are required by the Federal Health Insurance Portability and Accountability Act or "HIPAA" to give you this Notice about our privacy practices, our legal duties, and your rights concerning your Protected Health Information.
This Notice takes effect on April 14, 2003, and will remain in effect until we replace or modify it.
I. How we may Use and Disclose Health Information - Treatment, Payment, and Health Care Operations
Except in an emergency or other special circumstance, Council for Relationships may use and disclose your PHI for the purposes of treatment, payment, and health care operations with your consent.
We may use and disclose your PHI in connection with your treatment and/or other services provided to you - for example, to diagnose and treat you. In addition, we may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services. We may also disclose PHI to other providers (e.g., pharmacists or other members of our clinical staff) directly involved in your treatment.
We may use and disclose your PHI to obtain payment for services that we provide to you. An example of payment is when we disclose your PHI to your health insurer to obtain reimbursement for your health care or to determine eligibility for coverage. In some instances, we may use legal means, including hiring a collection agency, to secure payment if your account is overdue by 60 days and other arrangements have not been agreed upon.
C. Health Care Operations
We may use and disclose your PHI for our health care operations. These include internal administration and planning, and various activities that improve the quality and cost effectiveness of health care services. For example, we may use your PHI to evaluate the quality and competence of our clinical staff.
II. Uses and Disclosures of your PHI for which Neither Consent Nor Written Authorization is Required
Council for Relationship may use or disclose PHI without your consent or authorization in the following circumstances:
A. Public Health Activities
We may disclose your PHI for the following public health activities:
1) preventing or controlling disease, injury or disability;
2) reporting child abuse and neglect to public health or other government authorized by law to receive such reports;
3) reporting information about products and services under the jurisdiction of the United States Food and Drug Administration, such as reactions to medications and problems with products;
B. Victims of Adult Abuse, Neglect or Domestic Abuse
If we reasonably believe you are an adult victim of abuse, neglect or domestic violence, we may disclose your PHI to a governmental authority, including a social service or protective services agency, authorized by law to receive reports of such abuse, neglect or domestic violence.
C. Health Oversight Activities
We may disclose your PHI to a health oversight agency that is responsible for ensuring compliance with rules of government health programs such as Medicare or Medicaid.
D. Legal Proceedings
Information concerning the provision of psychotherapy services or the records thereof is usually regarded as privileged under state law. As such, this information will not be released without your written consent except in response to a court order.
E. Business Associates
We may disclose PHI to our business associates. A "business associate" is an organization or persons outside the workforce of Council for Relationships who receives PHI from us to provide services to, or on behalf of, our agency (e.g., accountant, lawyer, billing service, collection agency).
In most instances, we will ask for your written authorization when conducting research. However, we may use or disclose your PHI without specific authorization for research that has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of client information.
G. Public Safety
We may use or disclose your PHI to prevent or lessen a serious and imminent threat to the safety of a readily identified person or group of people. This may include directly advising the potential victim of the threat or intent.
H. Specialized Government Functions
We may release your PHI to units of the government with special functions, such as the U.S. military or the U.S. Department of State under certain circumstances, such as for intelligence, counter-intelligence or national security activities.
I. Workers' Compensation
We may disclose your PHI as authorized by state law relating to workers' compensation or other similar government programs.
J. As Required by Law
We may use and disclose your PHI when required to do so by any other laws not already referenced above.
III. Uses and Disclosures Requiring your Specific Written Authorization
Council for Relationships may use or disclose PHI for purposes outside of treatment, payment, and health care operations when your appropriate written authorization is obtained.
You have the option to receive notification of additional services provided by the organization and to receive newsletter information. The consent form to receive such information will be shown to you for your signature by your therapist.
B. Fund Raising
Council for Relationships may contact you as part of a fund raising effort through its newsletter and other means. You have the right to request not to receive subsequent fund raising materials.
C. Highly Confidential Information
Federal and state laws require special privacy protections for certain highly confidential information about you. This includes PHI:
1) maintained in psychotherapy notes ("Psychotherapy notes" are notes recorded in any medium by a mental health professional documenting or analyzing a conversation during an individual, group, or family counseling session and that are separated from the rest of your medical record and accorded a higher level of privacy.);
2) documenting mental health and developmental disabilities services;
3) about drug and alcohol abuse, prevention, treatment and referral;
4) relating to HIV/AIDS testing, diagnosis or treatment and other sexually transmitted diseases; and generally, we must obtain your written authorization to release this type of information. However, there are limited circumstances under the law when this information may be released without your consent.
Your authorization for use or disclosure of psychotherapy notes may not be combined with your authorization for use or disclosure of other PHI.
IV. Your Rights Regarding your Protected Health Information
A. Right to Inspect and Copy your Health Information
You may request to see and receive copies of your medical and billing records. To do so, please submit request to the appropriate Council for Relationships office or department. You will be charged for copies in accordance with our cost. If you are a parent or legal guardian of a minor, certain portions of the minor's medical record may be inaccessible to you (for example, as specified by state or federal law or when a parent or legal guardian has previously agreed to a confidentiality agreement limiting access). Clients do not have a right to:
1). inspect and copy psychotherapy notes;
2). information compiled in reasonable anticipation of or for use in legal or administrative proceedings.
Under certain circumstances, Council for Relationships may deny your access to PHI (for example, if access were believed to cause physical danger to another person or to cause substantial harm to another person named in the PHI). If Council for Relationships denies you access, we will explain why and what your rights are, including how to seek review of our decision to deny.
B. Right to Request Restrictions
You have the right to request, in writing, that we place additional restrictions on our use or disclosure of your PHI. We are not required to agree to your request. However, if we do agree, we will be bound by our agreement except when required by law, in emergencies, or when information is necessary to treat you. An approved restriction continues until you revoke it in writing, or until we tell you that we are terminating our agreement to a restriction.
C. Right to Receive Confidential Communications
You may request, and we will accommodate, to the extent that we can feasibly do so, any reasonable written request from you to receive your PHI by alternative means of communication or at alternative locations. For example, you may instruct us not to contact you by telephone at home, or you may give us a mailing address other than your home for test results.
D. Right to Amend your Records
You have the right to request that we amend PHI maintained in your medical or billing records. To do so, you must submit a written request to the party creating the record or the appropriate Council for Relationships office or department. We may deny your request if Council for Relationships reasonably believes that the existing information is accurate and complete, if the PHI was not created by Council for Relationships, or other special circumstances apply.
E. Right to Receive an Accounting of Disclosures
You may request a record of certain disclosures of your PHI. Your request may cover any disclosures made in the six years prior to the date of your request. However, we are not required to give you a record of disclosures that occurred before April 14, 2003.
F. Right to a Paper Copy of the Notice
You have the right to obtain a paper copy of this Notice from Council for Relationships upon request.
G. Right to Further Information or Complaint
If you desire further information about your privacy rights, are concerned that your privacy rights were violated, or disagree with a decision made about access to your PHI, you may contact us at the following address:
ATTN: Privacy Officer
Council for Relationships
4025 Chestnut Street, 1st Floor
Philadelphia, PA 19104
The Privacy Officer can be contacted by telephone at (215) 382-6680
Additionally, you may also file a written complaint with the Director, Office for Civil Rights of the U.S. Department of Health and Human Services. Upon request, the Privacy Officer will provide you with the correct address for the Director.
V. Effective Date and Duration of this Notice
A. Effective Date
This notice is effective on April 14, 2003.
B. Right to Change Terms of this Notice
We may change the terms of this Notice at any time. If we change this Notice, we will post the revised Notice in appropriate locations around Council for Relationships offices and online at our website. You also may obtain any revised notice by contacting the Privacy Officer.
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