Notice of Privacy Practices

Purpose

Circle Care Center respects your privacy. We are also legally required to maintain the privacy of your PHI under the Health Insurance Portability and Accountability Act (“HIPAA”) and other federal and state laws.

This Notice of Privacy Practices (this “Notice”) is not an authorization. This Notice describes:

• Our legal duties and privacy practices regarding your PHI, including our duty to notify you following a data breach of your unsecured PHI.
• Our permitted uses and disclosures of your PHI.
• Your rights regarding your PHI.

Uses and Disclosures Your PHI Without Your Authorization

Uses and Disclosures for Treatment, Billing and Payment, and Healthcare Operations

• Treatment. We may use or disclose your PHI and share it with other professionals who are treating you, including doctors, nurses or other personnel involved in your care. For example, your PHI may be provided to a physician to whom you have been referred to ensure that the physician has the necessary information to diagnose or treat you.
• Billing and payment. We may use and disclose your PHI to bill and get payment from health plans or others. In some cases, we may share information about you with your health insurance company to determine whether it will cover your treatment. For example, we share your PHI with your health insurance plan so it will pay for the services you receive.
• Running our organization. We may use and disclose your PHI to run our practice, improve your care, and contact you when necessary. For example, we may use your PHI to manage the services and treatment you receive or to monitor the quality of our health care services.
• Appointment reminders and health-related communications. We may use or disclose your PHI, as necessary, to contact you to remind you of appointments and to tell you about treatment alternatives or health-related benefits and services that may be of interest to you.

Other Uses and Disclosures

We may share your information in other ways, usually for public health or research purposes or to contribute to the public good. For more information on permitted uses and disclosures, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. For example, these other uses and disclosures may involve:

• Friends and family involved in your care. If you do not object, we may share your PHI with a family member, friend, relative, or close personal friend who is involved in your care or payment for your care, including following your death. If you are not able to tell us your preference, we may share information if we believe it is in your best interest. Parents and guardians will generally have the right to control the privacy of health information about minors unless the minors are permitted by law to act on their own behalf.
• Business associates and subcontractors. We may disclose your PHI to contractors, agents, and other business associates (“Business Associates”) (and their subcontractors) who perform services for us, such as billing, legal, auditing, or IT services. The law requires our Business Associates and their subcontractors to protect your PHI in the same way we do. We also contractually require these parties to use and disclose your PHI only as permitted and to appropriately safeguard your PHI.
• Incidental disclosures. Reasonable safeguards are used to protect your privacy, but certain incidental disclosures may occur as an unavoidable result of permissible uses or disclosures. For example, during the course of a treatment session, other patients in the treatment area may see or overhear discussion of your health information.
• Public health and safety activities. We may disclose PHI for public health reporting; to prevent disease; to report injuries, births, and deaths; to report adverse medication reactions or medical device product defects; to report suspected child abuse or neglect, or domestic violence; and to avert a serious and imminent threat to public health or safety.
• Complying with the law. For example, we will share your PHI if the Department of Health and Human Services requires it during investigations into our compliance with privacy laws.
• Responding to legal actions. For example, we may share your PHI to respond to a court order, administrative subpoena, or other lawful process, such as a discovery request.
• Research. For example, we may share your PHI for some types of health research that do not require your authorization.
• Working with medical examiners or funeral directors. For example, we may share PHI with coroners, medical examiners, or funeral directors when an individual dies.
• Addressing workers’ compensation, law enforcement, or other government requests. For example, we may use and disclose your PHI for: workers’ compensation claims; health oversight activities by federal or state agencies; law enforcement purposes or with a law enforcement official; or specialized government functions, such as military and veterans’ activities, national security and intelligence, presidential protective services, or medical suitability.
• Health information exchanges (including Connecticut’s Connie). We participate in one or more health information exchanges (“HIEs”) that allow us to securely share protected health information with other health care providers and entities for permitted purposes such as treatment, payment, and health care operations. As required by Connecticut law, we participate in Connie, the statewide HIE. Through Connie and other HIEs that we may participate in, we may disclose your health information electronically so that your treating providers and other authorized participants have timely access to information they need to coordinate your care. Given the sensitivity of the health information we routinely handle for our patients, such as information regarding reproductive health or HIV-related information, we generally only share this information through HIEs with your consent. You may opt into having your information accessible through Connie or other HIEs we participate in at any time, as described below. You can change your decision at any time. To opt into the HIE or opt back out (which will not affect disclosures already made), contact Connie Customer Care at 866-987-5514 with respect to Connie specifically, or contact our Privacy Officer for assistance with respect to Connie or other HIEs.

• Most sharing of a mental health care professional’s notes (psychotherapy notes).
• Marketing purposes.
• Selling or otherwise receiving compensation for disclosing your PHI
• Certain research activities.
• Other uses and disclosures not described in this Notice.

In a civil, criminal, administrative, or legislative proceeding against an individual, we will not use or share information about your substance abuse treatment records unless a court order requires us, or you give us your written permission.

In the case of fundraising: We may contact you for fundraising efforts, but you can tell us not to contact you again. You may revoke your authorization at any time, but it will not affect information that we have already used and disclosed.

• Inspect and copy your paper or electronic protected health information. You have the right to inspect and obtain a copy of your health information, including medical and billing records. To inspect or obtain a copy of your health information, please submit your request in writing to the practice. We may charge a fee for the costs of copying, mailing or other supplies. If you would like an electronic copy of your health information, we will provide one to you as long as we can readily produce such information in the form requested. In some limited circumstances, we may deny the request. Under federal law, you may not inspect or copy the following records: Psychotherapy notes, information compiled in reasonable anticipation of, or used in, a civil, criminal, or administrative action or proceeding, protected health information restricted by law, information related to medical research where you have agreed to participate, information whose disclosure may result in harm or injury to you or to another person, or information that was obtained under a promise of confidentiality.
• Ask us to amend your medical record. If you believe that the health information we have about you is incorrect or incomplete, you may request an amendment in writing. If we deny your request, we will provide a written notice that explains our reasons. You will have the right to have certain information related to your request included in your records.
• Ask us to limit the information we share, in some cases. You have the right to ask us to limit what we use or share about your PHI (right to request restrictions). You can contact us and request us not to use or share certain PHI for treatment, payment, or operations or with certain persons involved in your care. For these requests: (a) we are not required to agree; and (b) we may say “no” if it would affect your care; but (c) we will agree not to disclose information to a health plan for purposes of payment or health care operations if the requested restriction concerns a health care item or service for which you or another person, other than the health plan, paid in full out-of-pocket, unless it is otherwise required by law.
• Get a list of those with whom we’ve shared your information. You have a right to request an “accounting of disclosures” every 12 months, except for disclosures made with the patient’s or personal representatives written authorization; for purposes of treatment, payment, healthcare operations; required by law, or six (6) years prior to the date of the request. To obtain a request form for an accounting of disclosures, please call our practice.
• Request confidential communication.
• Receive notification of a breach. You have the right to be notified within sixty (60) days of the discovery of a breach of your unsecured protected health information if there is more than a low probability the information has been compromised.
• Get a copy of this privacy notice. If you are receiving this Notice electronically, you have the right to a paper copy of this Notice.
• Choose someone to act for you. If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your PHI. We will confirm the person has this authority and can act for you before we take any action.
• File a complaint if you believe we have violated your privacy rights. You have the right to complain if you feel we have violated your rights. We will not retaliate against you for filing a complaint. You may either file a complaint:
  
  • 
    
    • directly with us by contacting our Privacy Officer at the contact information above. All complaints must be submitted in writing; or
    • with the Office for Civil Rights at the US Department of Health and Human Services at the contact information below; or visit www.hhs.gov/ocr/privacy/hipaa/complaints/. More information on the complaint process may be found at https://www.hhs.gov/hipaa/filing-a-complaint/complaintprocess/index.html.
    • To file a complaint with HHS, mail your complaint to:

Centralized Case Management Operations

U.S. Department of Health and Human Services

200 Independence Avenue, S.W.

Room 509F HHH Bldg.

Washington, D.C. 20201

OCRComplaint@hhs.gov

Special Protections for Certain Information

Some kinds of information, such as alcohol and substance abuse treatment, HIV- related, mental health, psychotherapy, and genetic information, are considered so sensitive that state or federal laws provide special protections for them. Therefore, some parts of this general Notice may not apply to these types of information. If you have questions or concerns about the ways these types of information may be used or disclosed, please speak with your health care provider.

State Law

Where Connecticut state law provides greater privacy protections or rights than HIPAA, we will follow state law.

Contact and Questions

If you have questions about this Notice or how your PHI may be used or disclosed, please contact our Privacy Officer at the contact information above.