HIPAA Notice of Privacy Practices

A. ABOUT PRIVACY PRACTICES

We understand that your health information is personal, and we are committed to protecting it. This notice describes how we use and share your health information and explains your rights under the Health Insurance Portability and Accountability Act of 1996 (HIPAA).

• What is HIPAA? HIPAA is a federal law that protects the privacy of your health information. It sets rules for how healthcare providers, like therapists, can use and share your information. We follow these rules carefully to keep your information safe and private.

• Electronic Communications and Telehealth: To provide convenient and effective care, we may communicate with you electronically using secure methods, such as:

  • Telehealth platforms (video conferencing)

  • Encrypted email

  • Secure messaging We take steps to protect your privacy when using these technologies, including:

  • Using secure platforms that encrypt your information

  • Requiring strong passwords

  • Training our staff on privacy and security practices

• Business Associates and Partner Platforms: To help us run our practice and provide you with the best possible care, we may share your health information with third-party service providers ("business associates"). These business associates include but are not limited to:

  • Billing services

  • Scheduling systems

  • Billing platforms (e.g., SimplePractice, GrowTherapy, Headway, Alma, Tava, etc.)

  • Therapy directories (e.g., PsychologyToday, GrowTherapy, Alma, etc.)

  • Insurance directories

  • BastionGPT: For session notes, treatment planning, and case conceptualization. Important: We do not use BastionGPT for transcription services.

  • Bitwarden: For secure password management. These business associates are required by law and contract to protect your information.

• Billing Platform Requirements: Due to regulations and requirements set by certain billing platforms, your session notes may be uploaded to those platforms as part of your care and for compliance purposes. For example, GrowTherapy requires that session notes be uploaded following each session. For other platforms (such as Alma, Headway, and Tava), uploading session notes is not always required, but I may choose to do so for additional protections, such as clawback protection or compliance with evolving regulations. Each billing platform has its own privacy policies and terms, which you will be asked to review and consent to when you sign up for their services. Currently, I use the following billing platforms: Alma, GrowTherapy, Headway, and Tava. If you have questions about how your session notes are handled or about the privacy policies of these platforms, please let me know.

• Communication with Platform Staff: Because I use these platforms and related services, I may communicate with their staff, billing managers, case managers, or other authorized personnel as needed to coordinate your care, manage billing, scheduling, or resolve issues related to your treatment. Each platform has its own privacy policy and procedures for handling your information, which you will review and consent to when you sign up for their services. My communications with these platform staff are governed by their policies and are separate from my own privacy practices. Please note that while I select platforms that meet industry standards for privacy and security, I do not control the privacy practices or security measures of these third-party services. It is your responsibility to review and understand the privacy policies and terms of service for any billing platform you use. Staff or representatives from these platforms may contact you directly for scheduling, billing, or account management, and these communications are governed by the platform’s own policies. My communication with platform staff is limited to what is necessary to coordinate your care, manage billing and scheduling, or meet compliance requirements. If you wish to request a change in billing platform or have concerns about information sharing, please contact me to discuss your options.

• State Law: Texas and Vermont law may provide additional privacy protections for your health information. We will comply with the most protective applicable law.

B. YOUR RIGHTS REGARDING YOUR HEALTH INFORMATION

You have the following rights regarding your health information:

• Get a copy of your medical record:

  • You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you.

  • To do this, please submit a written request to us.

  • We will provide a copy or a summary of your health information, usually within 30 days of your request. If we need more time, we will notify you in writing within 30 days and provide the information within 60 days of your request.

  • We may charge a reasonable, cost-based fee for providing copies of your medical record. Our current fee schedule is: [Insert Fee Schedule Here].

• Ask us to correct your medical record:

  • You can ask us to correct health information about you that you think is incorrect or incomplete.

  • To do this, please submit a written request to us, explaining why you believe the information is inaccurate or incomplete.

  • We may say "no" to your request if we believe the information is accurate and complete, or if we did not create the information. If we deny your request, we will tell you why in writing within 60 days. If we need more time, we will notify you in writing within 60 days and provide the information within 90 days of your request.

• Request confidential communications:

  • You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.

  • We will make reasonable efforts to accommodate all reasonable requests.

  • To do this, please submit a written request to us, specifying how you would like us to contact you.

  • Please note that there may be circumstances where we cannot guarantee confidentiality (e.g., emergencies).

• Ask us to limit what we use or share:

  • You can ask us not to use or share certain health information for treatment, payment, or our operations.

  • We are not required to agree to your request, and we may say "no" if it would affect your care.

  • If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say "yes" unless a law requires us to share that information.

  • To do this, please submit a written request to us, specifying what information you want to limit and how you want us to limit it.

  • Please note that we may be required to share your information in certain situations, such as legal mandates or reporting requirements.

• Get a list of those with whom we’ve shared information:

  • You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.

  • We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make).

  • We will provide one accounting of disclosures per year free of charge. For any additional requests within the same 12-month period, our current flat fee is $6.50. If you request a paper copy to be mailed, you will be responsible for the full cost of postage and handling (even if this is your first request).

  • To do this, please submit a written request to us, specifying the time period you want the accounting to cover.

• Get a copy of this privacy notice:

  • You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically.

  • We will provide you with a paper copy promptly.

  • This notice is always available on our website at [Insert Website Link Here].

• Choose someone to act for you:

  • If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.

  • We will make sure the person has this authority and can act for you before we take any action.

  • To do this, please provide us with a copy of the medical power of attorney or guardianship papers.

• File a complaint if you feel your rights are violated:

  • You can complain if you feel we have violated your rights by contacting us using the information at the end of this notice.

  • You can also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting: www.hhs.gov/ocr/privacy/hipaa/complaints/

  • We will not retaliate against you for filing a complaint.

C. YOUR CHOICES REGARDING CERTAIN HEALTH INFORMATION

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

• Share information with your family, close friends, or others involved in your care: We will obtain your written consent before sharing information with your family, close friends, or others involved in your care, unless you are unable to provide consent (e.g., in an emergency).

• Share information in a disaster relief situation: We may share your information in a disaster relief situation if it is necessary to identify, locate, or notify your family members or other individuals involved in your care.

• Marketing purposes: We will not use or disclose your PHI for marketing purposes without your written authorization.

• Sale of your information: We will not sell your information.

• Most sharing of psychotherapy notes: We will obtain your written authorization before sharing your psychotherapy notes, except in limited circumstances as permitted by law.

D. OUR USES AND DISCLOSURES

We typically use or share your health information in the following ways:

• Treat you:

  • We can use your health information and share it with other professionals who are treating you, such as:

    • Primary care physicians

    • Psychiatrists

    • Other therapists

  • Example: A doctor treating you for an injury asks another doctor about your overall health condition.

• Run our organization:

  • We can use and share your health information to run our practice, improve your care, and contact you when necessary. This includes activities such as:

    • Quality improvement

    • Training

    • Customer service

  • Example: We use health information about you to manage your treatment and services.

• Bill for your services:

  • We can use and share your health information to bill and get payment from health plans or other entities.

  • Example: We give information about you to your health insurance plan so it will pay for your services. This information may include:

    • Diagnosis codes

    • Procedure codes

    • Dates of service

• Help with public health and safety issues:

  • We can share health information about you for certain situations such as:

    • Preventing disease

    • Helping with product recalls

    • Reporting adverse reactions to medications

    • Reporting suspected abuse, neglect, or domestic violence

    • Preventing or reducing a serious threat to anyone’s health or safety

• Do research: We will obtain your written authorization before using or disclosing your PHI for research purposes.

• Comply with the law: We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.

• Respond to lawsuits and legal actions:

  • We can share health information about you in response to a court or administrative order, or in response to a subpoena.

  • We will only share information in response to a valid subpoena or court order, and we will take steps to protect your privacy to the extent possible.

E. OUR RESPONSIBILITIES

• We are required by law to maintain the privacy and security of your protected health information.

• We will let you know promptly, without unreasonable delay and as required by law, if a breach occurs that may have compromised the privacy or security of your information.

• We must follow the duties and privacy practices described in this notice and give you a copy of it.

• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

F. FURTHER INFORMATION

• To receive more information on HIPAA in a Q&A format, go here:
  https://www.hhs.gov/hipaa/for-individuals/faq/index.html

• To receive a booklet of this information, go here:
  https://www.hhs.gov/sites/default/files/ocr/privacy/hipaa/npp_booklet_hc_provider.pdf