HIPAA Policy

Effective Date: March 17,2014

MICHIGAN PSYCHOTHERAPY

NOTICE OF PRIVACY PRACTICES

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.

If you have questions about this notice, please contact the Practice Administrator of Michigan Psychotherapy, 335 North Seymour, Suite A, Lansing, MI 48933, 517-482-9260.

WHO WILL FOLLOW THIS NOTICE:

This notice describes Michigan Psychotherapy’s practices and that of:

● Any mental health professional authorized to enter information into your record.
● Staff and students of all departments and units of Michigan Psychotherapy.

OUR PLEDGE REGARDING MENTAL HEALTH INFORMATION

We understand that information about you and your mental health is personal. We are committed to protecting mental health information about you. We create a record, paper and electronic, of the care and services you receive from us. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all records of your care generated by Michigan Psychotherapy (MP) or MP personnel.

This notice will tell you about the ways in which we may use and disclose mental health or medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of mental health and/or medical information.

We are required by law to:

● make sure that information that identifies you is kept private;
● give you this notice of our legal duties and privacy practices with respect to mental health and/or medical information about you;
● 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 mental health and/or medical information. For each category of uses or disclosures we will explain what we mean and try to give some examples. 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 information about you to provide you with mental health treatment or related services. We may disclose information about you to any doctors, treatment teams and their supervisors, support staff or students who are involved in taking care of you or your records while you are at MP. For example, a doctor treating you for depression may need to know if you are taking medication for seizures before prescribing medication for the depression. In addition, different departments within MP may need to share information about you in order to coordinate the different things you need. We may disclose information about you to people outside MP who may be involved in your care, such as hospitals, pharmacists or laboratories.

● For Payment. We may use and disclose information about you so that the treatment and services you receive at MP may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about the treatment you receive at MP so that your health plan will pay us or reimburse you for treatment. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment. We will give your name and other identifying information to our attorney or a collection agency if we have difficulty collection amounts owed.

● For Health Care Operations. We may use and disclose information about you for MP’s operations. These uses and disclosures are necessary to run MP, and make sure that all our consumers receive quality care. For example, we may use information to review our treatment and services and to evaluate the performance of our staff. We may also combine information about many consumers to decide what additional services MP should offer, what services are not needed and whether certain new treatments are effective. We may also disclose information to clinicians, doctors, nurses, students and other personnel for review and learning purposes. We may also combine the information we have with information from other mental health facilities to compare how we are doing and see where we can make improvements in the care and services we offer. We will remove information that identifies you from this set of mental health information so that others may use it to study mental health care without learning who the specific consumers are.
● Business Associates. There are some services provided in our organization through contacts with business associates. For example, we may send you for evaluation or treatment by a psychologist or social worker who is not a part of MP, but MP will have a business relationship with them. When any services are contracted, we may disclose your health information so they may perform the job we’ve asked them to do and bill you or your health plan. To protect your health information, however, we require the business associate to appropriately safeguard your information.

● Outside Services: We may, at your verbal request:

● send prescriptions to a pharmacy that you specify;
● send information to the Jury Administrator for your county or Federal District indicating that you are unable to adequately serve on a jury, possibly including the diagnosis code and dates;
● send information to an employer or school indicating that you are unable to work or attend school, possibly including the diagnosis code and dates;
● send information to a clinical laboratory to request that they perform laboratory measurements on you. This will include the diagnosis code.

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

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

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

● Secure E-mail. With his or her permission, you may communicate with your therapist via secure email. However, you must recognize that email is a much lower priority than phone calls and may not be received by your therapist the same day you send it. To use Secure E-Mail you must register on the secure server. Do this by going to the Michigan Psychotherapy web site (http://MichiganPsychotherapy.com) and choose “Contact us.” On the contact page click on the “click here” for the secure E-mail system. Then click to register. Secure e-mails will be delivered to the therapist the next time the therapist uses the Michigan Psychotherapy practice management system. Remember your user name and password. You can reset your password by clicking on the appropriate link on the secure e-mail page. We can not reset your password or access messages to/from you, only you can.

● Individuals Involved in Your Care or Payment for Your Care. With your consent, we may notify or release information about you to a friend or family member who is involved in your care. We may also, with your consent, give information to someone who helps pay for your care.

● As Required By Law. We will disclose 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 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.

● Military and Veterans. If you are a member of the armed forces, we may release information about you as required by military command authorities. We may also release information about foreign military personnel to the appropriate foreign military authority.

● Workers’ Compensation. We may release 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 information about you for public health activities. These activities generally include the following:

● to prevent or control disease, injury or disability, as required by law;
● to report child abuse or neglect, as required by law;
● 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;
● to notify the appropriate government authority if we believe a person has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.

● Health Oversight Activities. We may disclose information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensures. 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 dispute, we may disclose information about you in response to a court or administrative order.

● Law Enforcement. We may release information to a law enforcement official:

● in response to a court order;
● to identify or locate a missing person;
● if we believe that there is a duty to warn an individual of risk of harm by another individual.

● Coroners and Medical Examiners. We may release information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death.

● National Security and Intelligence Activities. We may release information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

● Protective Services for the President and Others. We may disclose information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign head of state or to 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 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.

● Confidentiality of Alcohol and Drug Records. The confidentiality of alcohol and drug abuse records maintained by MP is protected by federal law and regulations. Generally, the program may not say to a person outside the program that you attend the program, or disclose any information identifying you as an alcohol or drug abuser unless one of the following conditions is met:

● you consent in writing;
● the disclosure is allowed by court order;
● the disclosure is made to emergency personnel for an emergency or to a qualified person for research, audit or program evaluation.

Violation of the federal law and regulations by MP is a crime. Suspected violations may be reported to appropriate authorities in accordance with federal regulations.

Federal law and regulations do not protect any information about a crime committed by you either at MP or against any person who works for MP or about any threat to commit such a crime.
Federal laws and regulations do not protect any information about suspected child abuse or neglect from being reported under state law to appropriate state or local authorities.

YOUR RIGHTS REGARDING MENTAL HEALTH/MEDICAL INFORMATION ABOUT YOU

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

● Right to Inspect and Copy. You have the right to inspect and copy information from your record that may be used to make decisions about your care. Usually, this includes medical and billing records, but does not include psychotherapy notes.

To inspect and copy information that may be used to make decisions about you, you must submit your request in writing to your primary therapist or practice administrator. 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 inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by MP 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 Your Record. If you believe that your personal health information or treatment record is incorrect or that an important part of it is missing, you have the right to ask us to amend your treatment record. You must provide your request and your reason for the request in writing, and submit it to your primary therapist or practice administrator. We may deny your request if it is not in writing or does not include a reason that supports the request. In addition, we may deny your request if you ask us to amend personal health information that:

● is accurate and complete;
● was not created by MP, unless the person or entity that created the Personal Health Information is no longer available to make the amendment;
● is not part of the Personal Health Information kept by or for MP;
● is not part of the Personal Health Information which you would be permitted to inspect and copy.

● Right to an Accounting of Disclosures. You have the right to request an “accounting of disclosures.” This is a list of the disclosures that we made, other than those covered in this notice, of information about you.

To request this list or accounting of disclosures, you must submit your request in writing to your primary therapist or practice administrator. Your request must state a time period which may not be longer than six years and may not include dates before April 14, 2003. 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 or your parent if you are a minor child, or your guardian, must provide written authorization to have information about your mental health treatment shared with others. However, you have the right to request a restriction or limitations on the 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 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 to your spouse about a particular drug you are taking.

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 emergency treatment to you.

To request restrictions, you must make your request in writing to your primary therapist or practice administrator. 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 in a certain way or at a certain location. For example, you can ask that we contact you only at work or only by mail.

To request confidential communications, you must make your request in writing to your primary care therapist or practice administrator. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

● 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 this notice at any time. To obtain a paper copy of this notice, contact your primary therapist or practice administrator.

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 at all MP locations. This notice will contain, on the first page, in the top right-hand corner, the effective date. In addition, when you register to begin treatment at MP, we will offer you a copy of the current notice in effect.

COMPLAINTS ABOUT PRIVACY PRACTICES

If you believe your privacy rights have been violated, you may file a complaint with MP or with the Secretary of the Department of Health and Human Services. To file a complaint with MP, contact the Practice Administrator, 335 North Seymour Avenue, Suite A, Lansing, MI 48933. You may also file a complaint with the

Office of Civil Rights
US Dept of Health and Human Services
233 N. Michigan Ave., Suite 240
Chicago, IL 60601

All complaints must be submitted in writing.

You will not be penalized for filing a complaint.

OTHER USES OF MENTAL HEALTH/MEDICAL INFORMATION

Other uses and disclosures of information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose 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 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 provided to you.