Notice of Privacy Practices

Effective Date: September 23, 2013
NOTICE OF PRIVACY PRACTICES
REGARDING YOUR HEALTH INFORMATION
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE REVIEW IT CAREFULLY.

This notice describes the Sheehan Counseling Center's privacy practices and those of:

Any health care professional authorized to enter information into your clinic chart.
All departments, units and sites of the clinic.
Any member of a volunteer group the clinic allowed to help you while you were at the clinic.
All employees, staff and other clinic personnel.
All these individuals, entities, sites and locations follow the terms of this Notice. They may share medical information with each other for treatment, payment or clinic operations purposes described in this Notice.
Any Business Associate of these entities that performs services for or on behalf of these entities is required by us to enter into a contract in which it undertakes to accord the same level of confidentiality to personal information that we afford.

OUR PRIVACY PRACTICES REGARDING MEDICAL INFORMATION

In order to provide you with quality care and to comply with legal requirements, we create a record of the care and services you receive from us at the clinic. We understand that medical information about you and your health is personal. We are committed to maintaining the confidentiality of medical information about you.
This notice applies to all the records of your care generated by us, whether made by clinic personnel or your personal doctor.

We are required by law to:


Make sure that medical information that identifies you is treated confidentially and maintain the privacy of your information;
Give you this Notice of Privacy Practices with respect to medical information about you;
Notify you following any breach of your health information in any form which is not electronically encrypted; and
Follow the terms of the Notice that is currently in effect.


HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU

The following categories describe different ways that we use and disclose medical information. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

For Treatment. We may use medical information about you to provide you with medical treatment or services. We may disclose medical information about you either electronically or on site to doctors, nurses, technicians, medical students, or other clinic personnel who are involved in taking care of you in the clinic. Different people at the clinic also may share medical information about you in order to coordinate the different things you need, such as prescriptions and lab work. We may disclose your medical information to pathologists at third-party laboratories or hospital laboratories for lab work and, in emergencies, may disclose your medical information to hospital emergency physicians. We may disclose medical information about you for treatment purposes to other doctors and health care providers who are involved in taking care of you outside the clinic. We also may disclose medical information about you to people outside the clinic who may be involved in your medical care, such as family members or others we use to provide services that are part of your care.

For Payment. We may use and disclose medical information about you so that the treatment and services you receive may be billed to and payment may be collected from you, an insurance company or a third party. Our payment process involves the electronic conveyance of your treatment information for payment purposes. We also may tell your health plan about a treatment you are going to receive in order to obtain prior approval or to determine whether your plan will cover the treatment.

For Health Care Operations. We may use and disclose medical information about you for clinical operations. These uses and disclosures are necessary to run the clinic and make sure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We also may combine medical information about many clinic patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We also may disclose information to doctors, nurses, technicians, medical students, and other clinic personnel for review and learning purposes. The medical information we have may be combined with medical information from other health care facilities in order to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.

Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have an appointment or to reschedule an appointment for treatment or medical care.

Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

Health-Related Benefits, Products and Services. We may use and disclose medical information to tell you about health-related benefits, products or services that may be of interest to you.

Data Breach Notification Purposes. We may use or disclose your medical information to provide legally required notices of unauthorized access to or disclosure of your medical information.

Business Associates. We may disclose medical information to our business associates who perform functions on our behalf or provide us with services if the medical information is necessary for them to perform the function or services. Our business associates are required by law to protect the privacy and ensure the security of your medical information.

Presence in Clinic. Your presence in the clinic may be made known to persons who try to contact you here. You will be given an opportunity to request restrictions on our use of your information for such purposes.

Individuals Involved in Your Care or Payment for Your Care. Unless you request that we not do so, we may release medical information about you to a friend or family member who is involved in your medical care. We also may give information to someone who helps pay for your care.

Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication or treatment to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with patients' need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, but we may disclose medical information about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the medical information they review does not leave the health care facility. We will almost always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care.

Abuse, Neglect, or Domestic Violence. We may disclose medical information to the appropriate government authority if we believe a patient has been the victim of abuse, neglect, or domestic violence, and the patient agrees or we are required or authorized by law to make the disclosure.

As Requested By Law. We will disclose medical information about you when required to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety. We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat. For instance, we report any defects in products or devices to those subject to Food and Drug Administration (FDA) oversight to ensure the safety of medical devices and products.

Coroners, Medical Examiners, and Funeral Directors. We may disclose medical information to a coroner, medical examiner, or funeral director so that they can carry out their duties.
SPECIAL SITUATIONS



Military and Veterans. If you are a member of the armed forces, we may release medical information about you as required by military command authorities.

Workers' Compensation. We may release medical information about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.

Public Health Risks. We may disclose medical information about you for public health activities. These activities generally include the following:

to prevent or control disease, injury or disability;
to report deaths;
to report reactions to medications or problems with products;
to notify people of recalls of products they may be using;
to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition.


Health Oversight Activities. We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure of our facilities. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We also may disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if we are assured that efforts have been made to tell you about the request or to obtain an order protecting the information requested.

Law Enforcement. We may release medical information if asked to do so by a law enforcement official:

In response to a court or other tribunal order, subpoena, warrant, summons or similar process;

To identify or locate a suspect, fugitive, material witness, or missing person;

About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement;

About a death we believe may be the result of criminal conduct;

About suspected criminal conduct at the clinic; and

In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.

National Security and Intelligence Activities. We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law. We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.

Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU.

You have the following rights regarding medical information we maintain about you:

Right to Inspect and Copy. You have the right to inspect and request a copy of the medical information that may be used to make decisions about your care, including an electronic copy. Usually, this includes medical and billing records, but does not include psychotherapy notes.

To inspect and have your medical information copied, you must submit your request in writing. We have a special form for that purpose that can be obtained from the Sheehan Counseling Center. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.

We may deny your request to have a copy in certain limited circumstances. If you are denied access to medical information for one of those reasons, you may request that the denial be reviewed. Another licensed health care professional chosen by us will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.

Right to Amend. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for the clinic.

To request an amendment, we have a special form for that purpose which may be obtained by contacting the Sheehan Counseling Center.

We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;

Is not part of the medical information kept by or for us;

Is not part of the information which you would be permitted to inspect and have a copy; or

Is accurate and complete.

Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures of your medical information we have made, other than for treatment, payment, health care operations, or as specifically authorized by you. To request this accounting of disclosures, you must submit your request in writing. We have a special form for that purpose which you may obtain by contacting the Sheehan Counseling Center. The first list you request within a 12 month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a past medical condition. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. We will, however, honor such a request where (1) the disclosure is made to a health insurer to carry out payment or health care operations and is not required by law, and (2) the information pertains solely to an item or service we provided to you, for which you pay us in full. To request restrictions, you must make your request in writing. We have a special form for that purpose which will be supplied to you if you ask for it. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply -- for example, disclosures to your spouse.

Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, we have a special form for that purpose which will be supplied to you if you ask for it. We will not ask you the reason for your request. We will accommodate all reasonable requests.


Right to a Paper Copy of This Notice. You have the right to a paper copy of this Notice. You may ask us to give you a copy of our current Notice of Privacy Practices at any time. To obtain a paper copy of our current Notice, ask the Receptionist.

CHANGES TO THIS NOTICE

We reserve the right to change this Notice. We reserve the right to make the revised or changed Notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current Notice in the clinic and on the clinic’s web site. The Notice will contain on the first page, in the top right-hand corner, the effective date.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with the clinic and/or with the Secretary of the Department of Health and Human Services. To file a complaint with the clinic, contact our Privacy Officer at 662-844-4364. All complaints must be submitted in writing.

You will not be penalized for filing a complaint.

OTHER USES OF MEDICAL INFORMATION.

Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you authorize us to use or disclose medical information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we have provided to you. Uses which require an authorization include certain uses or disclosures of psychotherapy notes; uses and disclosures made for marketing purposes; or, the sale of your protected health information.