Notice of Privacy Practices

NOTICE OF PRIVACY PRACTICES FOR BLUE SAGE PSYCHOTHERAPY GROUP, LLC

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU MAY ACCESS THIS INFORMATION.

Because we provide mental health services, we are required by the Health Insurance Portability and Accountability Act (HIPAA) to protect the privacy of your personal health information (PHI). We are also required to give you this Notice describing your rights as a client and our obligations regarding the use and disclosure of your PHI for the provision of mental health services. We are required to comply with the terms of this Notice as it is currently in effect. You are welcome to use this Notice in determining your willingness to pursue services. You will be asked to sign a “Receipt of Notice of Privacy Practices” which will be kept in your record.

This Notice is effective September 1, 2015. We reserve the right to make changes to this Notice. Any material change will not be implemented prior to the effective date of the Notice in which such material change is reflected. If the Notice is revised, we will make the revised Notice available to you and will ask that you acknowledge receipt of the change.

PHI
As providers of behavioral health services, we have highly sensitive and personal health information about clients. Federal and state laws require us to keep your health information confidential unless we are specifically required or permitted by law to share information about you with others. The law is particularly restrictive regarding the use and disclosure of information that would identify you as a recipient of mental health services.

This practice reasonably ensures that the PHI it requests, uses, and discloses for any purpose is the minimum needed. Every reasonable effort will be made to ensure that PHI is only used by and disclosed to individuals who have a right to that information.

PHI refers to health information that identifies you, or information from which there is a reasonable basis to believe you could be identified, and is created or obtained by us for the purposes of providing mental health services to you. PHI may include information about your physical, mental, emotional, and chemical dependency conditions, as well as medical history, descriptions of symptoms, diagnoses, examinations, test results, treatment, treatment plans, and information related to payment for mental health services rendered.

GENERAL RULE FOR THE USE AND DISCLOSURE OF PHI
As a general rule, we may not use or disclose PHI that would identify you as a client receiving mental health services without your written authorization. After we disclose PHI pursuant to your authorization, we cannot guarantee that the recipient of your PHI will not further disclose your PHI. You can revoke your authorization at any time by giving written notice of your decision to do so. If you revoke your authorization, we will no longer use or disclose PHI about you for the reasons covered by your authorization. However, we will not be able to take back any disclosures made prior to your revocation.

EXCEPTIONS: TREATMENT, PAYMENT, AND HEALTH CARE OPERATIONS
The practice uses and discloses PHI for treatment, payment, and health care operations.

Treatment: Treatment includes those activities related to providing services to you, including releasing information to other health care providers involved in your care. Except in the case of urgency and/or emergency, consent for release of information will be requested first. In some cases wherein the timeliness of obtaining information from another health care provider is important and you wish to give verbal consent by phone, you will be allowed to do so, but written consent will be obtained at our next meeting. Whether a situation involves urgency and/or emergency will be determined based on our professional judgment. If information must be shared, only that information directly relevant to the client’s health care will be shared. Additionally, we participate as part of a provider group, Marla Vannucci, PhD & Associates, and your PHI may be shared with provider group staff for purposes of supervision and/or consultation as required and permitted by law.

Payment: Payment relates to all activities associated with getting reimbursed for services provided, including submission of claims to insurance companies, follow up with third party payers to collect reimbursement, and interactions with you regarding billing, such as sending you invoices or responding to your billing questions. Payment also refers to additional information requested by insurance companies in order to determine payment for claims. Before providing treatment or services, we may need to share PHI with third party payers to verify coverage. Additionally, your PHI may be shared with administrative staff and our contracted billing service, Billing Specialist Services, Inc., related to billing and payment processing. Billing Specialist Services, Inc. is held to the same HIPAA-compliance standards and laws that we are and will follow consistent procedures in protecting your PHI that are documented here.

Health Care Operations: We may use and disclose PHI without written authorization in order to perform business activities or health care operations. Health care operations include doing things that allow us to improve the quality of care. In addition, the practice uses and discloses PHI required by law for health oversight activities, including audits, investigations, licensure issues, or managed care reviews. Health care operations also include communication from us to you. We may contact you without prior written authorization to provide you with information about appointments, treatment options, or other health-related benefits or services that may be of interest to you. If we contact you for any of these purposes, we will do so in a way that does not identify you as a recipient of mental health services.

OTHER EXCEPTIONS
As required by law, the practice discloses PHI to public health officials when necessary, regarding communicable diseases and victims of abuse, neglect, or domestic violence. The client will be informed of the disclosure, unless to do so would put the individual at risk of serious harm or if it is believed that the individual is responsible for the abuse, neglect, or injury.

The practice uses and discloses PHI to public health and other authorities as required by law to avert a serious threat to health or safety. The practice discloses information for judicial and administrative proceedings in response to an order of a court or an administrative tribunal, as well as in response to a subpoena, discovery request, or other lawful process that is not accompanied by a court order or an ordered administrative tribunal. In all cases, a reasonable attempt will be made to obtain client consent first.

When required by law in specific circumstances, the practice may disclose PHI to law enforcement officials for law enforcement purposes without your written authorization. For example, we may disclose PHI about a crime committed at our facility or against an employee at our facility.

The practice uses and discloses PHI as appropriate to provide treatment in emergency situations. If the Notice of Privacy Practices has not been given to a client who receives direct treatment in an emergency situation, the Notice will be provided as soon as is practical, following provision of the emergency treatment.

We may disclose limited PHI to disaster relief agencies so that they can notify others about your location or general condition without written authorization if we can do so in a way that does not identify you as a recipient of mental health services. Under certain circumstances, we may disclose PHI without your written authorization for certain governmental activities related to national security or intelligence pursuant to the National Security Act. The practice does not participate in any research activities that would require disclosure of PHI without written consent of the client.

We may be required to disclose PHI without your written authorization to the Secretary of the Department of Health and Human Services when directed to do so in order to review compliance with federal privacy rules. The practice will inform the client of all PHI disclosures that occur for other than the purposes described above.

TELEHEALTH
The practice utilizes a HIPAA-compliant platform to enable telehealth sessions. However, the use of technology for communications or provision of services comes with risks unique from those with face to face services. No electronic communications format is completely risk-free related to privacy and security. However, your provider will take all precautions to protect your personal information. More information about specific telehealth practices and confidentiality is available in the Informed Consent and Office Policies and Telehealth Informed Consent documents provided to you.

YOUR RIGHTS REGARDING PHI
You, as the client, are encouraged to discuss any issue regarding privacy management with us as your first step. In addition, you may file complaints about privacy practices with the Secretary of the US Department of Health and Human Services. Complaints should be detailed and put in writing, and they must be filed within 180 days of the time you become aware of a potential violation. Every effort will be made to address clients’ questions and concerns regarding privacy practices, and no adverse action will be taken against any client who files a complaint.

You have the right to inspect and copy your PHI. The practice will document those requests, respond in a timely manner, and inform clients of their rights to appeal when a request is rejected in whole or in part. If a client requests copies, the practice may charge a reasonable fee for the cost of copying, mailing, or other related supplies, and will inform the client of this cost before completing the request. You have the right to request that the practice amend PHI maintained in your record. The practice will document those requests, respond in a timely manner, and inform clients of their rights to appeal when a request is rejected in whole or in part. The client may submit a written statement disagreeing with a denial of all or part of the initial request.

You have the right to request an accounting of PHI disclosures, except for disclosures made for treatment, payment, or health care operations purposes, certain disclosures required by law to be kept confidential, and disclosures you specifically authorized. Your written request must specify the time period for which the information is being requested. The request may be for a period of up to six years. You may request that the practice provide an accounting of disclosures in paper or electronic form. There may be a fee for requests based upon the cost of producing the accounting. You will be informed of the cost before the accounting of disclosures is prepared. You have the right to request and obtain a paper copy of this Notice at any time, even if you have already received a copy.

The practice accommodates all reasonable, written requests to keep communications confidential. The practice will determine the reasonableness and safety, from a mental health care standpoint, of complying with these requests. The practice will not refuse a request if the request indicates that the communication will cause endangerment, and the practice determines that such a risk exists. The practice accepts all written requests for restriction of disclosures of PHI but reserves the right to refuse to agree to any restrictions inconsistent with the above written policies.

The practice will obtain written consent from you or your representative for use or disclosure of PHI for purposes other than treatment, payment, or health care operations. However, if you are unwilling to give consent, information will be disclosed only within the scope of the guidelines described in this Notice. The practice never requires a client to waive any of his or her individual rights as a condition for the provision of treatment, except under very limited circumstances allowed under law.

QUESTIONS
The Privacy Act requires that each healthcare practice designate a Privacy Officer who will serve as the contact person for all issues related to privacy rules and practices. The Privacy Officer for the practice is Marla Vannucci, PhD. If you questions about this Notice or privacy practices, or if you require further information, she can be reached at 25 E. Washington, Suite 1002, Chicago, IL 60602 or at 312-281-2901.

This Notice is effective on September 1, 2022.