ALTERNATIVE CHOICES
514 South 4th Street Philadelphia, PA 19147
www.alternativechoices.com
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.
Notice of Privacy Practices
Privacy is a very important concern for all those who come to this office. It is
also complicated because of federal and state laws and our profession. The rules
are complicated and some parts of this Notice are quite detailed so you may have
to read them several times to understand them. If you have any questions our
Privacy Officer, whose name appears at the end of this Notice, can help you.
Contents of this Notice
A. Introduction
B. What we mean by medical information
C. Privacy and the laws about privacy
D. How protected health information can be used and shared
1. Uses and disclosures with your consent
a. Basic uses and disclosures - treatment, payment, and healthcare operations (TPO)
b. Other uses and disclosures in healthcare
2. Uses and disclosures requiring your Authorization
3. Uses and disclosures not requiring Consent or Authorization
4. Uses and disclosures requiring you to have an opportunity to object
5. An Accounting of disclosures made
E. If you have questions or problems
A. Introduction
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 may share it with other
professionals and organizations, and how it can be reviewed. We are 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 complicated and there is much 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
for more explanation or more details.
B. What we mean by your medical information
Each time you visit us or any doctor’s office, hospital, clinic, or other
healthcare provider information is collected about you and your physical and
mental health. It may be information about your past, present or future health
or conditions, or the treatment or services you received from us or from others,
or about payment for healthcare. The information we collect from you is called,
in the law, Protected Health Information (PHI). This information goes into your
medical or healthcare record. In this office PHI is likely to include these
kinds of information:
- Your history. As a child, in school and at work, and marital and personal
history.
- Reasons you came for treatment. Your problems, complaints, symptoms, needs,
goals.
- Diagnoses; the medical terms for your problems or symptoms.
- A treatment plan. The treatments and other services which we think will best
help you.
- Progress notes. Each time you come in we may write down some things about how
you are doing, what we observe about you, and/or what you tell us.
- Records we get from others who treated you or evaluated you.
- Psychological test scores, school records, etc.
- Information about medications you took or are taking.
- Legal matters
- Billing and insurance information
This list is just to give you an idea. There may be other kinds of information
that go into your healthcare record.
We use this information for many purposes. For example, we may use it:
- To plan your care and treatment.
- To decide how well our treatment is working for you.
- When we talk with other healthcare professionals who are also treating you
such as your family doctor or the professional who referred you to us.
- To show that you actually received services from us which we billed to you or
to your health insurance company.
- For teaching and training other healthcare professionals.
- For medical or psychological research.
- For public health officials trying to improve health care.
- 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 arrange to review it. It may also be possible to receive a copy but you will
be charged for the costs of copying (and mailing). In some situations you cannot
see all of what is in your record. If there is anything in your record that you
think is incorrect or something important is missing you can ask us to amend
(add information to) your record, although in some 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 the PHI
we keep. If we change the NPP we will post the new Notice in our office where
everyone can see it. You or anyone else can also get a copy from our Privacy
officer at any time and it will be posted on our website at
www.alternativechoices.com.
D. How protected health information can be used and shared
When your information is read by your therapist 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
very special circumstances, when we use 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 written Authorization from you
unless the law lets or requires us to make the use or disclosure without your
authorization.
1. Uses and disclosures of PHI in healthcare with consent
After you have read the Notice you will be asked to sign a separate Consent form
to allow us to use and share your PHI. In almost all cases we intend to use your
PHI here or share your PHI with other people or organizations to provide
treatment to you, 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 healthcare operations (TPO)
We need information about you and your condition to provide care to you. We need
your agreement 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 you because if you do not agree and consent we are
unable to treat you.
Generally, we may use or disclose your PHI for three purposes only: treatment,
obtaining payment, and what are called healthcare operations. Let’s see what
these are about.
For treatment
We use your medical information to provide you with psychological treatment or
services. These might include individual, family, or group therapy,
psychological, educational, or vocational testing, treatment planning, or
measuring the effects of our services.
We may share or disclose PHI to others who provide treatment to you. We are
likely to share information with your personal physician. If you are being
treated by a team we can share some of your PHI with them so that the services
you receive will be coordinated. They will also enter their findings, the
actions they took, and their plans into your record so that we all can decide
what treatments work best for you and make 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 may need to tell them some things
about you and your conditions. When we receive their findings and opinions,
those will go into your record. If you receive treatment in the future from
other professionals we can also share your 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, your insurance, or others to be paid
for the treatment we provide to you. We may contact your insurance company to
check on exactly what your insurance covers. We may have to tell them about your
diagnoses, what treatments you have received, and what we expect as we treat
you. We may also need to tell them about when we met, your progress, and other
similar things.
For health care operations
There are some other ways we may use or disclose your PHI which are called
health care operations. For example, we may use your PHI to see where we can
make improvements in the care and services we provide. We may be required to
supply some information to some government health agencies so they can study
disorders and treatment and make plans for services that are needed. If we do,
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.
Research. In all cases your name, address and other information that reveals who
you are will be removed from 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.
2. Uses and disclosures requiring your Authorization
If we want to use your information for any purpose besides the TPO (treatment,
payment, or healthcare operations) or those we described above we need your
permission on an Authorization form.
If you do authorize us to use or disclose your PHI, you can revoke or 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.
3. Uses and disclosures of PHI Not requiring Consent or Authorization
The law lets us use and disclose some of your PHI without your consent or
authorization in some cases.
When required by law
There are some federal, state, or local laws which require us to disclose PHI.
- We have to report suspected child abuse
- If you are involved in a lawsuit or legal proceeding and we receive a
subpoena, discovery request, or other lawful process we may have to release some
of your PHI. We will only do so after trying to tell you about the request, or
consulting your lawyer
- We may have to release some information to the government agencies which check
to see that we are obeying privacy laws.
For law enforcement purposes
We may release medical information if needed by a law enforcement official to
investigate a crime or criminal.
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, 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.
4. 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 care 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.
5. An accounting of disclosures
When we disclose your PHI we keep a record of whom we sent it to, when we sent
it, and what we sent. You can get 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 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: Dr. C. Ariel who can be
reached at 215-592-1333 or at
cariel@alternativechoices.com. Dr. R. Naseef can also be reached at
215 592-1333 or at
rnaseef@alternativechoices.com
The effective date of this notice is April 14, 2003