HIPPA Privacy Notice

Notice of Privacy Practices

This notice describes how your medical information may be used and disclosed (provided to others) and how you can get access to this information. Please review this notice carefully.

This Notice of Privacy Practices explains how Reinforcement Unlimited, LLC, its staff members, contractors, employees, volunteers, and clinics may use and provide your Protected Health Information (called PHI) to others for treatment, payment, and health care “operations” as described below, and for other purposes allowed or required by law.

I. OUR RESPONSIBILITIES:

Reinforcement Unlimited takes the privacy of your child’s (your) health information seriously. We are required by law to keep your health information private and provide you with this Notice of Privacy Practices. We will act according to the terms of this Notice. We reserve the right to change this Notice of Privacy Practices and to make any new practices effective for all Protected Health Information that we keep. Any changes made to the Notice of Privacy Practices will be posted in the Client Registration area, posted on our Web site (www.reinforcementunlimited.com) and given to you at your next appointment.

II. WHAT IS “PROTECTED HEALTH INFORMATION” (PHI)?

Protected Health Information (PHI) is information about a client’s age, race, sex, and other personal health information that may identify the client. The information relates to the client’s physical or mental health in the past, present, or future, and to the care, treatment, and services needed by a client because of his or her health.

III. WHAT DOES “HEALTH CARE OPERATIONS” INCLUDE?

“Health care operations” includes activities such as discussions between Reinforcement Unlimited staff and contractors and other health care providers; evaluating and improving quality; making travel arrangements to and from Reinforcement Unlimited; arranging temporary housing; reviewing the skills, competence, and performance of health care staff; training future health care staff; dealing with insurance companies; carrying out medical/psychological reviews and auditing; collecting and studying information that could be used in legal cases; and managing business functions.

IV. HOW IS MEDICAL INFORMATION USED?

Reinforcement Unlimited uses medical records to record health information, to plan care and treatment, and to carry out routine health care functions. For example, your insurance company may need us to give them procedure and diagnosis information to bill for client treatment we provide. Other health care providers or health plans reviewing your records must follow the same privacy laws and rules that Reinforcement Unlimited is required to follow.

Client records also greatly help our researchers find the best possible treatment for diseases and medical conditions. All Reinforcement Unlimited researchers must follow the same rules and laws that other health care providers have to follow to keep client information private. Details that may identify clients will not be disclosed for research purposes to anyone outside of Reinforcement Unlimited without written permission from the client or the client’s parent or legal guardian.

V. EXAMPLES OF HOW MEDICAL INFORMATION MAY BE USED FOR TREATMENT, PAYMENT, OR HEALTH CARE OPERATIONS

• Medical information may be used to show that a client needs certain care, treatment, and services (such as lab tests, prescriptions, treatment plans, and research study requirements).
• We will use medical information to plan treatment.
• We may disclose Protected Health Information to another provider for treatment (such as, referring doctors, specialists, and contractors to Reinforcement Unlimited).
• We may send claims to your insurance company containing medical information. We might also contact their utilization review department to receive precertification (approval for treatment in advance).
• We may use the emergency contact information you gave us to contact you if the address we have on record is no longer correct.
• We may contact you to remind you of the client’s appointment by calling you or mailing a postcard.
• We may contact you to discuss other possible treatments or benefits related to health that might interest you.
• We may use information to schedule travel to and from Reinforcement Unlimited.
• We may use information to provide temporary housing at places like local hotels.

VI. WHY DO I HAVE TO SIGN A CONSENT FORM?

When you sign the Consent for Release of Information, you are giving Reinforcement Unlimited permission to use and disclose (provide to others) Protected Health Information for treatment, payment, and health care operations, as described above. This permission does not include psychotherapy and personal notes (defined in Section VII below), psychosocial information (defined in Section VIII below), alcoholism and drug abuse treatment records, and other privileged categories of information, all of which require a separate permission. You will need to sign a separate consent form to have Protected Health Information given out for any reason other than treatment, payment, or health care operations or as required or permitted by law.

VII. WHAT ARE PSYCHOTHERAPY & PERSONAL NOTES?

Psychotherapy and Personal notes are notes recorded (in any form) by a mental health professional for the purpose of studying a conversation that took place or that serve as a personal memory aid for that professional.  Conversation notes and personal notes are separated from the rest of the client’s medical record. Psychotherapy and Personal notes do not include: notes about which medicines you are taking or how those medicines affect you; the start and stop times of therapy; the types of treatment you are given; how often treatments are given; the results of clinical tests; and any summary of the following items: diagnosis, functional state, the treatment plan, symptoms, expected outcome, and progress to date.

VIII. WHAT IS PSYCHOSOCIAL INFORMATION?

Psychosocial information is information given about your family’s social history and mental health services you have received.

IX. WHY DO I HAVE TO SIGN A SEPARATE PERMISSION FORM?

To provide client Protected Health Information to other people for any reason other than treatment, payment, and health care operations (described above) or as required or permitted by law, we must have a permission form known as an Authorization Form signed by the client or the client’s parent or legal guardian. This form clearly explains how they wish the information to be used and disclosed. The following are some examples of information that require separate permission before we can release it:

• Information and photographs shared with outside agencies for fundraising and public relations activities
• Information used in scientific and educational publications, presentations, and materials related to the work at Reinforcement Unlimited
• Information shared with other clinical and scientific cooperative groups that Reinforcement Unlimited works with in carrying out its mission through research and treatment.

X. CAN I CHANGE MY MIND AND WITHDRAW PERMISSION FOR REINFORCEMENT UNLIMITED TO DISCLOSE PHI?

You may change your mind and withdraw (revoke) permission, but we cannot take back information that has been released up to that point. Permission cannot be withdrawn if (1) the information is needed to maintain the integrity of the research study, or (2) if the permission was originally given to obtain insurance coverage. All requests to withdraw permission for uses and disclosures of PHI should be made in writing. The request should be submitted to Reinforcement Unlimited’s secure HIPPA compliant address, which will then forward this information to the Privacy Officer and the Director of Health Information Management.

XI. SHARING INFORMATION WITH REINFORCEMENT UNLIMITED BUSINESS ASSOCIATES

Some services at Reinforcement Unlimited are provided through contracts with business associates or business partners. Examples include billing transcription, in-home ABA therapy, scheduling travel to or from Reinforcement Unlimited, and assisting in arranging housing. When these services are contracted, we may disclose the minimum necessary amount of your health information to the business partner that they need to perform the job we have hired them to do. To protect your health information, we legally require our business associates and business partners to follow the same privacy laws that Reinforcement Unlimited must follow.

XII. WHEN IS MY CONSENT NOT REQUIRED?

The law requires that some information may be disclosed without your permission during the following times:

• In an emergency
• When communication or language is very limited
• When required by law
• When there are risks to public health
• To conduct health oversight activities
• To report suspected child abuse or neglect
• To certain government agencies who monitor activity
• In connection with court or government cases
• For law enforcement purposes
• To coroners and funeral directors and for organ donation
• If health or safety is seriously threatened

XIII. YOUR PRIVACY RIGHTS

The following explains your rights with respect to your Protected Health Information (called PHI) and a short description of how you may use these rights.

1. You have the right to review and to ask for a copy of your health information.

This means that except as explained below, you may review and get a copy of your PHI that is contained in a “designated record set” as long as we keep the PHI. A designated record set contains medical and billing records and any other records that Reinforcement Unlimited uses to make decisions about your child’s (your) health care. You may not read or be given a copy of psychotherapy or personal notes; information collected for use in a civil, criminal, or administrative action, or court case; and certain PHI that is protected by law. In some situations, you may have the right to have this decision reviewed. Please contact the Health Information Management Services (HIMS) Department if you have questions about access to your child’s (your) medical record.

If needed and at your request, Reinforcement Unlimited may provide an electronic copy of your child’s (your) record if Reinforcement Unlimited is able to do so.  A fee will be charged for requesting a copy of your health or medical records in accordance with Georgia Law.

2. You have the right to request that access to your health information be limited.

This means you may ask us to restrict or limit the medical information we use or disclose for treatment, payment, or health care operations (described above). Reinforcement Unlimited is not required to agree to a restriction that you ask for. We will tell you if we reject your request. If we do agree to the requested restriction, we will not violate that restriction unless it must be violated to provide emergency treatment. You may request a restriction by contacting the Reinforcement Unlimited Privacy Officer.

3. You have the right to request to receive private communications in another way or at other locations.

We will agree to reasonable requests. To carry out the request, we may also ask you for another address or another way to contact you, for example, mailing to a post office box. We will not ask you to explain why you are making the request. Requests must be made in writing.

4. You have the right to request changes to your health information.

This means you may ask for changes to be made (amended) in PHI about you in a designated record set for as long as we keep this information. In certain cases, we may deny your request for a change. If we deny your request, you have the right to file a statement with the Reinforcement Unlimited Privacy Officer, stating that you disagree. We may prepare a response to your statement and will provide you with a copy of this response. If you wish to change your PHI, please contact the Reinforcement Unlimited Privacy Officer. Requests for changes must be in writing.

5. You have the right to receive a record of when your health information has been disclosed by Reinforcement Unlimited.

You have the right to request a record (accounting) of when Reinforcement Unlimited has disclosed your PHI. This right applies to any time Reinforcement Unlimited discloses your PHI for purposes other than treatment, payment, or health care operations as described in this Privacy Notice. We are not required to account for information releases: that you requested, that you agreed to by signing an Authorization Form, that are given to family or friends involved in your care, or certain other releases we are allowed to make without your permission. The request for a record must be made in writing to the Reinforcement Unlimited Privacy Officer. The request should state the time period for the list. We are not required to provide a list for information released before April 14, 2003. Requests for records about Reinforcement Unlimited’s disclosures of your PHI may not be made for time periods of more than six (6) years or it could be an earlier time period depending upon what the law requires.

6. You have the right to receive a paper copy of this Notice of Privacy Practices.

XVI. WHAT IF I HAVE A QUESTION OR COMPLAINT?

If you have questions regarding your privacy rights, please call the Reinforcement Unlimited Privacy Officer at (770) 591-9552. If you believe your privacy rights have been violated, you may file a complaint by contacting the Reinforcement Unlimited Privacy Officer at (770) 591-9552, or by e-mail at compliance.privacy@reinforcementunlimited.com , or with the U.S. Department of Health and Human Services. You will not be penalized for filing a complaint. The address for the U.S. Department of Health and Human Services is:

Office For Civil Rights
US Department of Health and Human Services
Atlanta Federal Center
Suite 3B70
61 Forsyth St., SW
Atlanta, GA 30303-8909
(404) 562-7886 (phone)
(404) 562-7881 (fax)
(404) 331-2867 (TDD)
www.hhs.gov/ocr/hipaa

 Current as of July 15, 2010