Great Pathways Psychiatry must collect timely and accurate health information about you and make that information available to members of your health care team at Great Pathways Psychiatry, so that we can accurately diagnose your condition and provide the care you need. There may also be times when your health information will be sent to service providers outside Great Pathways Psychiatry for services that we cannot provide. It is the legal duty of Great Pathways Psychiatry to protect your health information from unauthorized use or disclosure while providing health care, obtaining payment for that health care, and for other services relating to your health care. The Notice describes how Great Pathways Psychiatry may use and disclose your protected health information.
This Notice also sets out Great Pathways Psychiatry’s legal obligations concerning your protected health information and describes your rights to control and access your health information under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), as amended by the Health Information Technology for Economic and Clinical Health Act. This Notice has been drafted in accordance with the HIPAA Privacy Rule, contained in the Code of Federal Regulations at 45 CFR Parts 160 and 164. Terms not defined in this Notice have the same meaning as they have in the HIPAA Privacy Rule.
Please review this document carefully and ask for clarification if you do not understand any portion of it.
Great Pathways Psychiatry is required by law to maintain the privacy of your protected health information and provide you with certain rights with regard to your protected health information. It is obligated to provide you with a copy of this Notice setting forth Great Pathways Psychiatry’s legal duties and its privacy practices with respect to your protected health information. Great Pathways Psychiatry and any of its business associate must abide by the terms of this Notice.
Your protected health information may be used and disclosed where it is necessary for the purpose of providing health care services to you. Your protected health information may also be used and disclosed to pay your health care bills and to support the operation of your counselor’s practice.
Business Associates**** Great Pathways Psychiatry contracts with service providers – called business associates – to perform various functions on its behalf. For example, we may contract with a service provider to perform the administrative functions necessary to process your payments for medical care. To perform these functions or to provide the services, business associates will receive, create, maintain, use, or disclose protected health information, but only after Great Pathways Psychiatry and the business associate agree in writing to contract terms requiring the business associate to appropriately safeguard your information.
Great Pathways Psychiatry uses external providers to enhance services including the Upheal platform. Upheal empowers counselors to concentrate on their services by offering automated notes and analytics for client conversations. As a part of this process, Upheal handles protected health information for counselors, adhering to HIPAA regulations as a Business Associate.
Great Pathways counselors who use the Upheal platform have signed a Business Associate Agreement (BAA) to protect data that is shared with Upheal. Under the BAA, Upheal adheres to regulations such as the HIPAA Security Rule and Privacy Rule. This ensures that electronic health information (ePHI) is safeguarded through appropriate administrative, physical, and technical measures, ensuring its confidentiality, integrity, and security. You can learn more about Upheal and its privacy practices at www.upheal.io/privacy.
Great Pathways Psychiatry may use or disclose personal health information in order to provide, coordinate, or manage your health care and related services. This includes sharing your health information with other health care providers, both within and outside Great Pathways Psychiatry, regarding your treatment when we need to coordinate and manage your health care. For example, we may share your health information with doctors, nurses and other health care personnel who are involved in providing your health care. Sharing health information can be essential for your protection and quality care.
Great Pathways Psychiatry may use and give your health information to other staff and health plans you designate to bill and collect payment for the health care services received by you. We will share adequate information with departments that prepare bills and manage client accounts in order to ensure payment for services rendered. If necessary, we may share your health information with agents of your insurance company or health plan to confirm services that were provided to you; and/or confirm diagnosis that were rendered at time of service(s).
Great Pathways Psychiatry may use or disclose, as needed, your protected health information in order to support the business activities of our practice. These “health care operations” allow us to improve the quality of care we provide to you and our other clients and help us to reduce health care costs. Such activities include, but are not limited to, quality assessment activities, employee review activities, training of medical students, group case consultation for the professional development of clinical staff, licensing, and conducting or arranging for other business activities.
Great Pathways Psychiatry may use and/or disclose your health information for those circumstances that have been determined by law to be so important that your authorization may not be required. Prior to disclosing your health information, we will evaluate each request to ensure that only necessary information will be disclosed. Those circumstances include disclosures that are:
We may use or disclose your protected health information to the extent required by federal, state, or local law. Public Health Activities
We may use or disclose your protected health information for public health activities that are permitted or required by law. For example, a disclosure may be made for the purpose of preventing or controlling disease, injury or disability.
We may disclose protected health information to health oversight agencies for purposes of legally authorized health oversight activities, such as audits and investigations necessary for oversight of the health care system and government benefit programs.
We may disclose your protected health information in the course of any judicial or administrative proceeding or in response to an order of a court or administrative tribunal (to the extent such disclosure is expressly authorized). If certain conditions are met, we may also disclose your protected health information in response to a subpoena, a discovery request, or other lawful process.
We may disclose your protected health information to a government authority that is authorized by law to receive reports of abuse, neglect, or domestic violence. Additionally, as required by law, if we believe you have been a victim of abuse, neglect, or domestic violence, we may disclose your protected health information to a governmental entity authorized to receive such information.
We may use or share information about you if we believe the use or disclosure is needed to:
(1) prevent or lessen a serious and immediate threat to the health and safety of a person or the public and the disclosure is made to a person reasonably able to lessen or prevent such a threat;
(2) help law enforcement authorities to identify or catch an individual who has admitted participating in a violent crime that resulted in serious physical harm to the victim, unless the information was learned while initiating or in the course of counseling or therapy; or
(3) help law enforcement authorities to catch an individual who has escaped from custody.
Under certain conditions, we also may disclose your protected health information to law enforcement officials for law enforcement purposes such as responding to a court order; as necessary to locate or identify a suspect, fugitive, material witness, or missing person; or as relating to the victim of a crime.
An authorization is not required to use or disclose protected health information for certain essential government functions. Such functions include: assuring proper execution of a military mission, conducting intelligence and national security activities that are authorized by law, providing protective services to the President, making medical suitability determinations for U.S. State Department employees, protecting the health and safety of inmates or employees in a correctional institution, and determining eligibility for or conducting enrollment in certain government benefit programs.
We may disclose your protected health information to a friend or family member that is involved in your health care.
We also may disclose your information to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, and location. If you are not present or able to agree to these disclosures of your protected health information, then, using professional judgment, we may determine whether the disclosure is in your best interest.
We are required to disclose your protected health information to the Secretary of the U.S. Department of Health and Human Services when the Secretary is investigating or determining HopeWorks Counseling’s compliance with the HIPAA Privacy Rule.
Great Pathways Psychiatry can use or share health information about you for research:
To allow a researcher to prepare a research protocol, as long as the researcher:
The following is a description of your rights with respect to your protected health information. Right to Inspect and Copy Your Protected Health Information
You have the right to inspect and copy protected health information that may be used to make decisions about your benefits. You must submit your request in writing. For your convenience, you may request a form using the Contact Information at the end of this Notice. Such requests will be fulfilled within 30 days where possible. If you request copies, we may impose reasonable copy charges (which may include a labor charge), as well as postage – if you request that copies be mailed to you.
You may also request that we disclose your protected health information to an individual who has been designated by you as your personal representative and who has qualified for such designation in accordance with relevant law. Prior to such a disclosure, however, we must be given written documentation that supports and establishes the basis for the personal representation. Note that under federal law, you may not inspect or copy the following records: information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding; and/or protected health information that is subject to law that prohibits access to protected health information. Depending on the circumstances, a decision to deny access may be reviewable. In some, but not all, circumstances, you may have a right to have this decision reviewed.
You have the right to request that Great Pathways Psychiatry restrict use or disclosure of protected health information for treatment, payment or health care operations, disclosure to persons involved in the individual’s health care or payment for health care, or disclosure to notify family members or others about the individual’s general condition, location, or death. We are under no obligation to agree to requests for restrictions. In circumstances in which we do agree to a restriction, we will comply with the agreed restrictions, except for purposes of treating you in a medical emergency.
A patient that pays in full for their services out of pocket have the right to demand that the information regarding the service not be disclosed to the patient’s third party payer since no claim is being made against the third party payer.
You have the right to request an alternative means or location for receiving communications of protected health information by means other than those that Great Pathways Psychiatry typically employs. For example, you may request that we communicate with you through a designated address or phone number. Similarly, you may request that we send communications in a closed envelope rather than a post card.
We will also accommodate reasonable requests if you indicate that the disclosure of all or part of the protected health information could endanger you. We will not question your statement of endangerment. Any confidential communication request must be done in writing and must explain how any payment will be handled.
The Rule gives individuals the right to have covered entities amend their protected health information in a designated record set when that information is inaccurate or incomplete. If we accept an amendment request, we will make reasonable efforts to provide the amendment to persons that you identify as needing it and to persons that we know might rely on the information to your detriment. If the request is denied, we will provide you with a written denial and allow you to submit a statement of disagreement for inclusion in the record. Furthermore we will amend protected health information in our designated record set upon receipt of notice to amend from another covered entity.
You have a right to an accounting of the disclosures of your protected health information by Great Pathways Psychiatry or any business associates with whom we do business. The maximum disclosure accounting period is the six years immediately preceding the accounting request, except we are not obligated to account for any disclosure made before our Privacy Rule compliance date.
The Privacy Rule does not require accounting for disclosures:
You have the right to be notified in the event that Great Pathways Psychiatry or any business associates with whom we do business discovers a breach of unsecured protected health information.
You have the right to a paper copy of this Notice, even if you have agreed to accept this Notice electronically. To obtain such a copy, please contact the appropriate person using the Contact Information at the end of this Notice.
Great Pathways Psychiatry is prohibited by law from sharing substance use disorder information about you or information that identifies you as seeking or getting substance use disorder treatment from a substance use disorder provider, program, or facility to anyone, including family members, relatives, or friends, without your written permission, unless permitted by law.
Great Pathways Psychiatry will not share information about your mental health (information about your identity, diagnosis, evaluation or treatment that are created or maintained by a professional for diagnosis, evaluation or treatment of any mental or emotional condition or disorder including alcoholism or drug addiction), unless expressly authorized by law.
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