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NOTICE OF POLICIES AND PRACTICES UTILIZED BY THE
CLINICAL PSYCHOLOGY CENTER
TO PROTECT THE PRIVACY OF YOUR
THIS NOTICE DESCRIBES HOW PSYCHOLOGICAL AND MEDICAL
INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS
TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Uses and disclosures for treatment, payment and health care
The Clinical Psychology Center (CPC) may use
or disclose your protected health information (PHI), for
treatment, payment, and health care operations purposes
with your consent. To help clarify these terms, here are some
PHI refers to information in your clinical
record that could identify you.
Treatment occurs when the CPC provides,
coordinates, or manages your health care and other services related to
your health care. An example of treatment would be when your
therapist at the CPC consults with another health care provider, such as
your family physician or another psychologist.
Payment is when the CPC obtains reimbursement
for your health care. Examples of payment are when the CPC discloses
your PHI to your health insurer to obtain reimbursement for your health
care or to determine eligibility or coverage. However, note that
at this time the CPC does not accept insurance.
Health care operations are activities that
relate to the performance and operation of the CPC. Examples of
health care operations are quality assessment and improvement
activities, business-related matters, such as audits and administrative
services, and case management and care coordination.
Use applies only to activities within the CPC,
such as sharing, employing, applying, utilizing, examining, and
analyzing information that identifies you.
Disclosure applies to activities outside the
CPC, such as releasing, transferring, or providing access to information
about you to other parties.
II. Uses and disclosures requiring
The CPC may use or disclose PHI for purposes
outside of treatment, payment, and health care operations when your
appropriate authorization is obtained. An authorization is written
permission above and beyond the general consent that permits only specific
disclosures. In those instances when the CPC is asked for
information for purposes outside of treatment, payment, and health care
operations, we will obtain an authorization from you before releasing this
information. The CPC will also need to obtain an authorization
before releasing your psychotherapy notes. Psychotherapy notes are
notes made about your conversation during private, family, or group
counseling sessions, and when these exist, they are kept separate from the
rest of your clinical record. These notes are given a greater
degree of protection than the PHI. Further, the CPC will need to
obtain an authorization from you before using or disclosing PHI in a way
that is not described in this Notice.
You may revoke all
authorizations regarding PHI and/or psychotherapy notes at any time,
provided such revocation is in writing. You may not revoke an
authorization to the extent that (1) the CPC has relied on that
authorization, or (2) if the authorization was obtained as a condition of
obtaining insurance coverage, and the law provides the insurer the right
to contest the claim under the policy. However, remember that the
CPC does not currently accept insurance.
and disclosures with neither consent nor authorization
may use or disclose PHI without your consent or authorization in the
Child abuse. If a therapist in the CPC
has reasonable cause, on the basis of professional judgment and in the
course of professional activity within the CPC, to suspect abuse of an
identifiable child, the therapist is required by law to report this to
the Pennsylvania Department of Public Welfare.
Adult and domestic abuse. If a
therapist in the CPC has reasonable cause to believe that an older adult
is in need of protective services (in connection with abuse, neglect,
exploitation, or abandonment), the therapist may report this to a local
agency which provides protective services.
Judicial or administrative proceedings.
If you are involved in a court proceeding, and a request is made about
the professional services you received in the CPC or the records
thereof, such information is privileged under Pennsylvania law, and the
CPC will not release the information without your written consent or a
court order. The privilege does not apply when you are being
evaluated for a third party or when the evaluation is court
ordered. You will be informed in advance if this is the case.
Serious threat to health or safety. If
you express a serious threat or intent to kill or seriously injure an
identified or readily identifiable person or group of people, and your
therapist in the CPC determines that you are likely to carry out the
threat, the therapist must take reasonable measures to prevent harm.
Reasonable measures may include directly advising the potential victim
of the threat or intent.
Workers’ compensation. If you file a
workers’ compensation claim, the CPC will be required to file periodic
reports with your employer, which shall include, where pertinent,
history, diagnosis, treatment, and prognosis.
As allowed under other sections of Section 164.512
of the Privacy Rule and Pennsylvania law. This includes
certain narrowly-defined disclosures to law enforcement agencies, to a
health oversight agency (such as HHS or the Pennsylvania Department of
Health), a coroner or medical examiner, for public health purposes
related to disease or FDA-regulated products, or for specialized
government functions such as fitness for military duty, eligibility for
VA benefits, and national security and intelligence.
Records “converted” under FERPA. Consistent with the Family Educational Records Protection Act (“FERPA”), the records of current students at the University of Pittsburgh may on rare occasion be “converted,” resulting in a decreased level of privacy protection. This occurs when the records are used for purposes other than treatment of a physical or mental health disorder. Records are most commonly “converted” when they are used for research purposes or when they are inspected by someone not involved in the student’s treatment, such as a parent, the student, or another party. After this occurs, those portions of the students CPC record that were used for purposes other than treatment fall under FERPA guidelines. FERPA permits university officials to inspect records for cause and under some circumstances permits the students family member to inspect the records.
IV. Client rights and CPC
Right to request restrictions. You have
the right to request restrictions on certain uses and disclosures of PHI
about you. However, the CPC is not required to agree to a
restriction you request.
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 being seen here.
In such a case, upon your request the CPC would send any communications
to another address.
Right to inspect and copy. You have the
right to inspect or obtain a copy (or both) of such PHI in the CPC’s
clinical and billing records as is used to make decisions about you, for
as long as the PHI is maintained in the record. The CPC may deny
your access to PHI under certain circumstances, but in some cases you
may have this decision reviewed. On your request, CPC staff 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. The CPC may deny your request. On your request,
CPC staff will discuss with you the details of the amendment process.
Right to an accounting. You generally
have the right to receive an accounting of disclosures of PHI for which
you have neither provided consent nor authorization (as described in
Section III of this Notice). On your request, CPC staff will
discuss with you the details of the accounting process.
Right to a paper copy. You have the
right to obtain a paper copy of this Notice from the CPC upon request,
even if you have agreed to receive the Notice electronically.
Right to restrict disclosures when you have paid
for your care out-of-pocket. You have the right to restrict
certain disclosures of PHI to a health plan when you pay out-of-pocket
in full for CPC services. At present, however, the CPC does not
accept any insurance.
Right to be notified if there is a breach of your
unsecured PHI. You have a right to be notified if: (a) there
is a breach (a use or disclosure of your PHI in violation of the HIPAA
Privacy Rule) involving your PHI; (b) that PHI has not been encrypted to
government standards; and (c) the CPC risk assessment fails to determine
that there is a low probability that your PHI has been
The CPC is required to maintain the privacy of PHI
and to provide you with a Notice of its legal duties and privacy
practices with respect to PHI.
The CPC reserves the right to change the privacy
policies and practices described in this Notice. Unless the CPC
notifies you of such changes, however, it is required to abide by the
terms currently in effect.
If the CPC revises its policies and procedures, it
will provide clients with a revised Notice, either at the time of their
next appointment or by mail.
If you are
concerned that the CPC has violated your privacy rights, or you disagree
with a decision made by CPC staff about access to your records, you may
contact Andrew Koffmann, Ph.D., Director, CPC, at 412-624-2077.
You may also send a written complaint to the Secretary of the U.S.
Department of Health and Human Services. Dr. Koffmann can provide
you with the appropriate address upon request.
Effective date, restrictions, and changes to privacy
This revised notice is in effect as of April 1, 2016.
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