Notice of Privacy Practices
Privacy is a very important concern for all those in association with
this company. It is also complicated because of federal and state
laws and our professional codes of ethics. Because the rules are so
complicated, some parts of this Notice are quite detailed and you
probably will have to read them several times to understand them.
Contents of this Notice
Introduction to our clients
What we mean by your medical information
Privacy and the laws about privacy
How your protected health information can be used and shared
Uses and disclosures with your consent
The basic uses and disclosures – For treatment, payment, and
health care operations (TPO)
Other uses and disclosures in health care
Uses and disclosures requiring your Authorization
Uses and disclosures not requiring your Consent or Authorization
Uses and disclosures requiring you to have an opportunity to object
An Accounting of disclosures we have made
If you have questions or problems
A. Introduction to our clients
This notice will tell you about how we handle information about you.
It tells how we use this information here in this office, how we share
it with other professionals and organizations, and how you can see
it. We want you to know all of this so that you can make the best
decisions for yourself and your family. We are also required to tell
you about this because of the privacy regulations of a federal law,
the Health Insurance Portability and Accountability Act of 1996
(HIPAA). Because this law and the laws of this state are very
complicated and we don’t want to make you read a lot that may not
apply to you, we have simplified some parts. If you have any
questions or want to know more about anything in this Notice,
please ask our Privacy Officer, whose name is at the end of this
Notice, for more explanation or more details.
B. What we mean by your medical information
Each time you visit with us or any doctor’s office, hospital, clinic, or
any other “healthcare provider” information is collected about you
and your son, daughter, or legal relative (referred herein as “the
consumer”) and their physical and mental health. It may be
information about your past, present or future health or conditions,
or the treatment or other services you or they got from us or from
others, or about payment for healthcare. The information we collect
from you is called, in the law, PHI which stands for Protected
Health Information. This information goes into their medical or
healthcare record or file at our office. In this office the PHI is likely
to include these kinds of information:
The consumer’s history. As a child, in school and at work, and
marital and personal history.
Reasons they came for treatment. Their problems, complaints,
symptoms, needs, goals.
Diagnoses. Diagnoses are the medical terms for your problems or
symptoms.
A treatment plan. These are the treatments and other services
which we think will best help the consumer.
Progress notes. Each time we visit we may write down some things
about how you are doing, what we observe, and what you tell us.
Records we get from others who treated or evaluated the consumer.
Psychological test scores, school records, etc.
Information about medications they took or are taking.
Pertinent legal or custody matters.
Billing and insurance information.
Functional assessment/treatment progress and termination notes.
This list is just to give you an idea and there may be other kinds of
information that go into a healthcare record here.
We use this information for many purposes. For example, we may
use it:
To plan their care and treatment.
To decide how well our treatments are working.
When we talk with other healthcare professionals who are also
treating them, such as their family doctor or the professional who
referred you to us.
To show that you actually received the services from us which we
billed to you or to your health insurance company.
For public health officials tiring to improve health care in this
country.
To improve the way we do our job by measuring the results of our
work.
When you understand what is in your record and what it is used for
you can make better decisions about who, when and why others
should have this information.
Although your health record is the physical property of the
healthcare practitioner or facility that collected it, the information
belongs to you. You can inspect, read, or review it. If you want a
copy we can make one for you but there is a charge associated with
the costs of copying (and mailing if you want it mailed to you). In
some very unusual situations you cannot see all of what is in your
records. If you find anything in your records that you think is
incorrect or you believe that something important is missing you
can ask us to amend (add information to) your record, although in
some rare situations we don’t have to agree to do that. Our Privacy
officer can explain more about this.
C. Privacy and the laws
The HIPAA law requires us to keep your PHI private and to give
you this notice of our legal duties and our privacy practices, which is
called the Notice of Privacy Practices or NPP. We will obey the rules
of this notice as long as it is in effect but if we change it the rules of
the new NPP will apply to all PHI we keep. If we change the NPP
we will post the new Notice in our office where everyone can see.
You or anyone else can also get a copy from our Privacy Office at
any time, and it will be posted on our website at www.ebip.com.
D. How your protected health information can be used and shared
When information is read by me or others in this office that is
called, in the law, “use”. If the information is shared with or sent to
others outside this office, that is called, in the law, “disclosure”.
Except in some special circumstances, when we use your PHI here
or disclose it to others, we share only the minimum necessary PHI
needed for the purpose. The law gives you rights to know about
your PHI, how it is used and to have a say in how it is disclosed and
so we will tell you more about what we do with your information.
We use and disclose PHI for several reasons. Mainly, we will use
and disclose (share) it for routine purposes and we will explain
more about these below. For other uses we must tell you about
them and have a written Authorization form unless the law lets or
requires us to make the use or disclosure without your
authorization. However, the law also says that we are allowed to
make some uses and disclosures without your consent or
authorization.
Uses and disclosures of PHI in healthcare with your consent
After you have read this Notice you will be asked to sign a separate
Consent form to allow us to use and share the consumers PHI. In
almost all cases we intend to use the PHI here or share your PHI
with other people or organizations to provide treatment, arrange
for payment for our services, or some other business functions
called health care operations. Together these routine purposes are
called TPO, and the Consent form allows us to use and disclose your
PHI for TPO. Re-read that last sentence until it is clear because it is
very important.
1a. For treatment, payment, or health care operations.
We need information about the consumer and their condition to
provide necessary care. You have to agree to let us collect the
information and to use it and share it as necessary to care for you
properly. Therefore, you must sign the Consent form before we
begin to treat the consumer, because if you do not agree and
consent, we cannot begin treatment.
Generally, we may use or disclose your PHI for three purposes:
treatment, obtaining payment, and what are called healthcare
operations. Let’s see what these are about.
For treatment
We use medical information to provide you with behavioral
consultation services.
We may share or disclose the consumer’s PHI to others who
provide treatment to them. We may share this information with
their personal physician. If the consumer is being treated by a team
we can share some of their PHI with them so that the services
received will be coordinated. They will also enter their findings, the
actions they took, and their plans into consumer’s record and so we
all can decide what treatments work best and make up a Treatment
Plan. We may refer you to other professionals or consultants for
services we cannot offer, such as special testing or treatments.
When we do this we need to tell them some things about the
consumer and their conditions. We will get back their findings and
opinions and those will go into their records here. If they receive
treatment in the future from other professionals we can also share
their PHI with them. These are some examples so that you can see
how we use and disclose your PHI for treatment.
For payment
We may use your information to bill you, or others to be paid for
the consultation we provide to you.
For health care operations
There are some other ways we may use or disclose the consumer’s
PHI which are called health care operations. For example, we may
use the PHI to see where we can make improvements in the care
and services we provide. We may be required to supply some
information to government health agencies so they can study
disorders and treatment and make plans for services that are
needed. If you request, your name and identity will be removed
from what we send.
1b. Other uses in healthcare
Appointment Reminders.We may use and disclose medical
information to reschedule or remind you of appointments for
treatment or other care. If you want us to call or write to you only
at your home or your work or prefer some other way to reach you,
we usually can arrange that. Just tell us.
Treatment Alternatives. We may use and disclose the PHI to tell
you about or recommend possible treatments or alternatives that
may be of interest to you.
Other Benefits and Services. We may use and disclose the PHI to
tell you about health-related benefits or services that may be of
interest to you.
Research. We may use or share your information to do research to
improve treatments. For example, comparing two treatments for
the same disorder to see which works better or faster or costs less.
In all cases your name, address and other information that reveals
who you are will be removed from the information given to
researchers. If they need to know who you are we will discuss the
research project with you and you will have to sign a special
Authorization form before any information is shared.
Business Associates. There are some jobs we hire other businesses
to do for us. They are called our Business Associates in the law.
Examples include a copy service we use to make copies of your
health record and a billing service that figures out, prints, and mails
our bills. These business associates need to receive some of the
consumer’s PHI to do their jobs properly. To protect your privacy
they have agreed in their contract with us to safeguard your
information.
Uses and disclosures requiring your Authorization
If we want to use your information for any purpose besides the
TPO or those we described above we need your permission on an
Authorization form. We don’t expect to need this very often.
If you do authorize us to use or disclose the PHI, you can revoke
(cancel) that permission, in writing, at any time. After that time, we
will not use or disclose your information for the purposes that we
agreed to. Of course, we cannot take back any information we had
already disclosed with your permission or that we had used in our
office.
Uses and disclosures of PHI form medical records Not requiring
Consent or Authorization
The law lets us use and disclose some of your PHI without your
consent or authorization in some cases.
For Law Enforcement Purposes. We may release medical
information if asked to do so by a law enforcement official to
investigate a crime or criminal.
For public health activities. We might disclose some of your PHI to
agencies that investigate diseases or injuries.
Relating to Decedents. We might disclose PHI to coroners, medical
examiners or funeral directors, and to organizations relating to
organ, eye, or tissue donations or transplants.
For specific government functions. We may disclose PHI of military
personnel and veterans to government benefit programs relating to
eligibility and enrollment, to Workers’ Compensation programs, to
correctional facilities if you are an inmate, and for national security
reasons.
To Prevent a Serious Threat to Health or Safety. If we come to
believe that there is a serious threat to your health or safety or that
of another person or the public we can disclose some of your PHI.
We will only do this to persons who can prevent the danger.
Uses and disclosures requiring you to have an opportunity to object
We can share some information about you with your family or close
others. We will only share information with those involved in your
case and anyone else you choose, such as close friends or clergy. We
will ask you about who you want us to tell what information about
your condition or treatment. You can tell us what you want and we
will honor your wishes as long as it is not against the law.
If it is an emergency – so we cannot ask if you disagree – we can
share information if we believe that it is what you would have
wanted and if we believe it will help you if we do share it. If we do
share information, in an emergency, we will tell you as soon as we
can. If you don’t approve we will stop, as long as it is not against the
law.
An accounting of disclosures
When we disclose your PHI we keep some records of whom we sent
it to, when we sent it, and what we sent. You can get an accounting
(a list) of many of these disclosures.
E. If you have questions or problems
If you need more information or have questions about the privacy
practices described above please speak to the Privacy Officer whose
name and telephone number are listed below. If you have a
problem with how your PHI has been handled or if you believe your
privacy rights have been violated, contact the Privacy Officer. You
have the right to file a complaint with us and with the Secretary of
the Federal Department of Health and Human Services. We
promise that we will not in any way limit your care here or take any
actions against you if you complain.
If you have any questions regarding this notice or our health
information privacy policies, please contact our Privacy Officer,
Heidi Holdsambeck, M.A., who can be reached by phone at (805)
733-2363 or by e-mail at Office@Holdsambeck.com.
The effective date of this notice is April 14, 2003.
Privacy is a very important concern for all those in association with
this company. It is also complicated because of federal and state
laws and our professional codes of ethics. Because the rules are so
complicated, some parts of this Notice are quite detailed and you
probably will have to read them several times to understand them.
Contents of this Notice
Introduction to our clients
What we mean by your medical information
Privacy and the laws about privacy
How your protected health information can be used and shared
Uses and disclosures with your consent
The basic uses and disclosures – For treatment, payment, and
health care operations (TPO)
Other uses and disclosures in health care
Uses and disclosures requiring your Authorization
Uses and disclosures not requiring your Consent or Authorization
Uses and disclosures requiring you to have an opportunity to object
An Accounting of disclosures we have made
If you have questions or problems
A. Introduction to our clients
This notice will tell you about how we handle information about you.
It tells how we use this information here in this office, how we share
it with other professionals and organizations, and how you can see
it. We want you to know all of this so that you can make the best
decisions for yourself and your family. We are also required to tell
you about this because of the privacy regulations of a federal law,
the Health Insurance Portability and Accountability Act of 1996
(HIPAA). Because this law and the laws of this state are very
complicated and we don’t want to make you read a lot that may not
apply to you, we have simplified some parts. If you have any
questions or want to know more about anything in this Notice,
please ask our Privacy Officer, whose name is at the end of this
Notice, for more explanation or more details.
B. What we mean by your medical information
Each time you visit with us or any doctor’s office, hospital, clinic, or
any other “healthcare provider” information is collected about you
and your son, daughter, or legal relative (referred herein as “the
consumer”) and their physical and mental health. It may be
information about your past, present or future health or conditions,
or the treatment or other services you or they got from us or from
others, or about payment for healthcare. The information we collect
from you is called, in the law, PHI which stands for Protected
Health Information. This information goes into their medical or
healthcare record or file at our office. In this office the PHI is likely
to include these kinds of information:
The consumer’s history. As a child, in school and at work, and
marital and personal history.
Reasons they came for treatment. Their problems, complaints,
symptoms, needs, goals.
Diagnoses. Diagnoses are the medical terms for your problems or
symptoms.
A treatment plan. These are the treatments and other services
which we think will best help the consumer.
Progress notes. Each time we visit we may write down some things
about how you are doing, what we observe, and what you tell us.
Records we get from others who treated or evaluated the consumer.
Psychological test scores, school records, etc.
Information about medications they took or are taking.
Pertinent legal or custody matters.
Billing and insurance information.
Functional assessment/treatment progress and termination notes.
This list is just to give you an idea and there may be other kinds of
information that go into a healthcare record here.
We use this information for many purposes. For example, we may
use it:
To plan their care and treatment.
To decide how well our treatments are working.
When we talk with other healthcare professionals who are also
treating them, such as their family doctor or the professional who
referred you to us.
To show that you actually received the services from us which we
billed to you or to your health insurance company.
For public health officials tiring to improve health care in this
country.
To improve the way we do our job by measuring the results of our
work.
When you understand what is in your record and what it is used for
you can make better decisions about who, when and why others
should have this information.
Although your health record is the physical property of the
healthcare practitioner or facility that collected it, the information
belongs to you. You can inspect, read, or review it. If you want a
copy we can make one for you but there is a charge associated with
the costs of copying (and mailing if you want it mailed to you). In
some very unusual situations you cannot see all of what is in your
records. If you find anything in your records that you think is
incorrect or you believe that something important is missing you
can ask us to amend (add information to) your record, although in
some rare situations we don’t have to agree to do that. Our Privacy
officer can explain more about this.
C. Privacy and the laws
The HIPAA law requires us to keep your PHI private and to give
you this notice of our legal duties and our privacy practices, which is
called the Notice of Privacy Practices or NPP. We will obey the rules
of this notice as long as it is in effect but if we change it the rules of
the new NPP will apply to all PHI we keep. If we change the NPP
we will post the new Notice in our office where everyone can see.
You or anyone else can also get a copy from our Privacy Office at
any time, and it will be posted on our website at www.ebip.com.
D. How your protected health information can be used and shared
When information is read by me or others in this office that is
called, in the law, “use”. If the information is shared with or sent to
others outside this office, that is called, in the law, “disclosure”.
Except in some special circumstances, when we use your PHI here
or disclose it to others, we share only the minimum necessary PHI
needed for the purpose. The law gives you rights to know about
your PHI, how it is used and to have a say in how it is disclosed and
so we will tell you more about what we do with your information.
We use and disclose PHI for several reasons. Mainly, we will use
and disclose (share) it for routine purposes and we will explain
more about these below. For other uses we must tell you about
them and have a written Authorization form unless the law lets or
requires us to make the use or disclosure without your
authorization. However, the law also says that we are allowed to
make some uses and disclosures without your consent or
authorization.
Uses and disclosures of PHI in healthcare with your consent
After you have read this Notice you will be asked to sign a separate
Consent form to allow us to use and share the consumers PHI. In
almost all cases we intend to use the PHI here or share your PHI
with other people or organizations to provide treatment, arrange
for payment for our services, or some other business functions
called health care operations. Together these routine purposes are
called TPO, and the Consent form allows us to use and disclose your
PHI for TPO. Re-read that last sentence until it is clear because it is
very important.
1a. For treatment, payment, or health care operations.
We need information about the consumer and their condition to
provide necessary care. You have to agree to let us collect the
information and to use it and share it as necessary to care for you
properly. Therefore, you must sign the Consent form before we
begin to treat the consumer, because if you do not agree and
consent, we cannot begin treatment.
Generally, we may use or disclose your PHI for three purposes:
treatment, obtaining payment, and what are called healthcare
operations. Let’s see what these are about.
For treatment
We use medical information to provide you with behavioral
consultation services.
We may share or disclose the consumer’s PHI to others who
provide treatment to them. We may share this information with
their personal physician. If the consumer is being treated by a team
we can share some of their PHI with them so that the services
received will be coordinated. They will also enter their findings, the
actions they took, and their plans into consumer’s record and so we
all can decide what treatments work best and make up a Treatment
Plan. We may refer you to other professionals or consultants for
services we cannot offer, such as special testing or treatments.
When we do this we need to tell them some things about the
consumer and their conditions. We will get back their findings and
opinions and those will go into their records here. If they receive
treatment in the future from other professionals we can also share
their PHI with them. These are some examples so that you can see
how we use and disclose your PHI for treatment.
For payment
We may use your information to bill you, or others to be paid for
the consultation we provide to you.
For health care operations
There are some other ways we may use or disclose the consumer’s
PHI which are called health care operations. For example, we may
use the PHI to see where we can make improvements in the care
and services we provide. We may be required to supply some
information to government health agencies so they can study
disorders and treatment and make plans for services that are
needed. If you request, your name and identity will be removed
from what we send.
1b. Other uses in healthcare
Appointment Reminders.We may use and disclose medical
information to reschedule or remind you of appointments for
treatment or other care. If you want us to call or write to you only
at your home or your work or prefer some other way to reach you,
we usually can arrange that. Just tell us.
Treatment Alternatives. We may use and disclose the PHI to tell
you about or recommend possible treatments or alternatives that
may be of interest to you.
Other Benefits and Services. We may use and disclose the PHI to
tell you about health-related benefits or services that may be of
interest to you.
Research. We may use or share your information to do research to
improve treatments. For example, comparing two treatments for
the same disorder to see which works better or faster or costs less.
In all cases your name, address and other information that reveals
who you are will be removed from the information given to
researchers. If they need to know who you are we will discuss the
research project with you and you will have to sign a special
Authorization form before any information is shared.
Business Associates. There are some jobs we hire other businesses
to do for us. They are called our Business Associates in the law.
Examples include a copy service we use to make copies of your
health record and a billing service that figures out, prints, and mails
our bills. These business associates need to receive some of the
consumer’s PHI to do their jobs properly. To protect your privacy
they have agreed in their contract with us to safeguard your
information.
Uses and disclosures requiring your Authorization
If we want to use your information for any purpose besides the
TPO or those we described above we need your permission on an
Authorization form. We don’t expect to need this very often.
If you do authorize us to use or disclose the PHI, you can revoke
(cancel) that permission, in writing, at any time. After that time, we
will not use or disclose your information for the purposes that we
agreed to. Of course, we cannot take back any information we had
already disclosed with your permission or that we had used in our
office.
Uses and disclosures of PHI form medical records Not requiring
Consent or Authorization
The law lets us use and disclose some of your PHI without your
consent or authorization in some cases.
For Law Enforcement Purposes. We may release medical
information if asked to do so by a law enforcement official to
investigate a crime or criminal.
For public health activities. We might disclose some of your PHI to
agencies that investigate diseases or injuries.
Relating to Decedents. We might disclose PHI to coroners, medical
examiners or funeral directors, and to organizations relating to
organ, eye, or tissue donations or transplants.
For specific government functions. We may disclose PHI of military
personnel and veterans to government benefit programs relating to
eligibility and enrollment, to Workers’ Compensation programs, to
correctional facilities if you are an inmate, and for national security
reasons.
To Prevent a Serious Threat to Health or Safety. If we come to
believe that there is a serious threat to your health or safety or that
of another person or the public we can disclose some of your PHI.
We will only do this to persons who can prevent the danger.
Uses and disclosures requiring you to have an opportunity to object
We can share some information about you with your family or close
others. We will only share information with those involved in your
case and anyone else you choose, such as close friends or clergy. We
will ask you about who you want us to tell what information about
your condition or treatment. You can tell us what you want and we
will honor your wishes as long as it is not against the law.
If it is an emergency – so we cannot ask if you disagree – we can
share information if we believe that it is what you would have
wanted and if we believe it will help you if we do share it. If we do
share information, in an emergency, we will tell you as soon as we
can. If you don’t approve we will stop, as long as it is not against the
law.
An accounting of disclosures
When we disclose your PHI we keep some records of whom we sent
it to, when we sent it, and what we sent. You can get an accounting
(a list) of many of these disclosures.
E. If you have questions or problems
If you need more information or have questions about the privacy
practices described above please speak to the Privacy Officer whose
name and telephone number are listed below. If you have a
problem with how your PHI has been handled or if you believe your
privacy rights have been violated, contact the Privacy Officer. You
have the right to file a complaint with us and with the Secretary of
the Federal Department of Health and Human Services. We
promise that we will not in any way limit your care here or take any
actions against you if you complain.
If you have any questions regarding this notice or our health
information privacy policies, please contact our Privacy Officer,
Heidi Holdsambeck, M.A., who can be reached by phone at (805)
733-2363 or by e-mail at Office@Holdsambeck.com.
The effective date of this notice is April 14, 2003.
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