Privacy Policy: Alternative Solutions Center (ASC)

NOTICE OF THE ALTERNATIVE SOLUTIONS CENTER'S
POLICIES AND PRACTICES TO PROTECT
THE PRIVACY OF YOUR HEALTH INFORMATION

As required by the Privacy Regulations Created as a result of the Health Insurance Probability and Accountability Act of 1996 (HIPAA)

THIS NOTICE DESCRIBES HOW PSYCHOLOGICAL AND MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO YOUR PROTECTED HEALTH INFORMATION.
PLEASE REVIEW THIS NOTICE CAREFULLY.

I. Disclosures for Treatment, Payment, and Health Care Operations

The Alternative Solutions Center (ASC) may disclose your protected health information (PHI), for treatment, payment, and health care operations purposes with your written authorization. To help clarify these terms, here are some definitions:

PHI refers to information in your file that could identify you (any information with your name or other description of you.)

Treatment is when the ASC provides, coordinates or manages your health care. An example of treatment would be when someone from the ASC consults with another health care provider, such as your family physician or another clinician.

Payment is when the ASC obtains reimbursement for your healthcare. Examples of payment are when the ASC shares your PHI with your health insurer to obtain payment for your health care or to determine eligibility or coverage.

Health Care Operations are activities that relate to the performance and operation of the ASC. Examples of health care operations are quality assessment and improvement activities or business-related matters such as audits and administrative services.

Disclosure applies to activities outside of the ASC, such as releasing, or providing access to information about you to people outside of the ASC.

Authorization is your written permission to disclose confidential mental health information. All authorizations to disclose must be on a specific ASC release form.

II. Other Uses and Disclosures Requiring Authorization

The ASC may disclose PHI for purposes other than treatment, payment, or health care operations when your appropriate authorization is obtained. In those instances when we are asked for information for purposes other than treatment, payment, or health care operations, we will obtain an authorization from you before releasing this information. We will also need to obtain an authorization before releasing your Psychotherapy Notes. Psychotherapy Notes are notes your clinician may have made about your conversation during a private, group, joint, or family counseling session, which he or she has kept separate from the rest of your record. These notes are given a greater degree of protection than PHI.
You may cancel all such authorizations (of PHI or Psychotherapy Notes) at any time, provided each request to cancel authorization is in writing. You may not cancel an authorization to the extent that (1) The ASC has relied on that authorization; or (2) if the authorization was obtained as a condition of obtaining insurance coverage, the law provides the insurer the right to contest the claim under the policy.

III. Uses and Disclosures without Authorization

The ASC may disclose PHI without your consent or authorization in the following circumstances:

Serious Threat to Health or Safety - If your clinician believes disclosure of PHI is necessary to protect you or another individual from a risk of imminent and serious physical injury, he or she may disclose the PHI to the appropriate individuals.

Child Abuse - If your clinician knows or has reasonable cause to suspect that a child known to him or her in a professional capacity has been or is in immediate danger of being a mentally or physically abused or neglected child, he or she must immediately report such knowledge or suspicion to the appropriate authority.

Dependent Adult Abuse - If your clinician believes that an elderly or disabled adult is in need of protective services because of abuse or neglect by another person, he or she must immediately report this belief to the appropriate authorities.

Court Proceedings - If you are involved in a court proceeding and a request is made for information about the professional services the ASC provided you, such information is privileged under D.C. law, and we will not release information without the written authorization of you or your legally appointed representative or a court order. The privilege does not apply when you are being evaluated for a third party or where the evaluation is court ordered. You will be informed in advance if this is the case.

IV. Client's Rights and Clinician's Duties

Client's Rights:

Right to Request Restrictions - You have the right to request restrictions on certain uses and disclosures of protected health information (PHI). However, your clinician is not required to agree to a restriction you request. In order to request a restriction in our use or disclosure of your PHI, you must make your request in writing to Privacy Official 301-493-6610 TTY. Your request must describe in a clear and concise fashion: a) the information wish restricted; b) whether you are requesting to limit our practice's use, disclosure or both; and c) to whom you want the limits to apply.

Right to Receive Confidential Communications by Alternative Means and at Alternative Locations - You have the right to request and receive confidential communications of PHI by alternative means and at alternative locations. For example, you may not want a family member to know that you are seeing me. On your request, the ASC will send your bills to another address. In order to request a type of confidential communication, your must make a written request to Privacy Official at 301-493-6610 TTY specifying the requested method of contact, or the location where you wish to be contacted. The ASC will accommodate reasonable requests. You do not need to give a reason for your request.

Right to Inspect and Copy - You have the right to inspect or obtain a copy (or both) of PHI in our mental health and billing records used to make decisions about you for as long as the PHI is maintained in the record. You must submit your request in writing to Privacy Official 301 493-6610 TTY. The ASC may deny your access to PHI under certain circumstances, but in some cases you may have this decision reviewed. You may be denied access to Psychotherapy Notes if our practice believes that a limitation of access is necessary to protect you from a substantial risk of imminent psychological impairment or to protect you or another individual from a substantial risk of imminent and serious physical injury. The ASC will notify you or your representative if he or she does not grant complete access. On your request, the ASC will discuss with you the details of the request and denial process.

Right to Amend - You have the right to request an amendment of PHI for as long as the PHI is maintained in the record. To request an amendment, your request must be made in writing and submitted to Privacy Official 301-493-6610 TTY. The ASC may deny your request. On your request, the ASC will discuss with you the details of the amendment process.

Right to a Listing - You generally have the right to receive a listing of disclosures of PHI. On your request, the ASC will discuss with you the details of this process. In order to obtain a listing of disclosures of PHI, you must submit your request in writing to Privacy Official 301-493-6610 TTY.

Right to a Paper Copy of This Notice - You are entitled to receive a paper copy of our notice of privacy practices. You may ask us to give you a copy of this notice at any time. To obtain a paper copy of this notice, contact Privacy Official 301 493-6610 TTY.

Clinician's Duties:

The ASC is required by law to maintain the privacy of PHI and to provide you with a notice of our legal duties and privacy practices with respect to PHI.

The ASC reserves the right to change the privacy policies and practices described in this notice. Unless we notify you of such changes, however, we required to abide by the terms currently in effect.

If the ASC revises our policies and procedures, we will supply you with a revised copy of this document.

V. Complaints
If you are concerned that someone at the ASC has violated your privacy rights, or you disagree with a decision made about access to your records, you may contact Privacy Official 301-491-6610 TTY.

You may also send a written complaint to the Secretary of the U.S. Department of Health and Human Services. The ASC can provide you with the appropriate address upon request. You will not be penalized for filing a complaint.

VI. Effective Date, Restrictions and Changes to Privacy Policy

This notice will go into effect on April 15, 2003 are required to abide by the terms currently in effect.

The ASC reserves the right to change the terms of this notice and to make the new notice provisions effective for all PHI that we maintain. We will provide you with a revised notice by providing you a copy of the notice upon revision.

AGAIN, IF YOU HAVE ANY QUESTIONS REGARDING THIS NOTICE OR OUR HEALTH INFORMATION PRIVACY POLICIES, PLEASE CONTACT:
ALTERNATIVE SOLUTIONS CENTER

Bethesda Office:
11110 Whisperwood Lane
N. Bethesda, MD 20852-3668
Privacy Official
301-493-6610 TTY 301 493-6044 FAX