HIPAA Notice

1. INTRODUCTION

At First Steps Recovery, we comply with HIPAA (Health Insurance Portability and Accountability Act of 1996) regulations to ensure the confidentiality of health information provided by our users or clients through our services. This information, known as “protected health information” or “PHI”, includes information that identifies you and relates to your past, present or future health, health care received or payment for health care. We are committed to safeguarding the privacy of your PHI, and as such, we are legally required to implement strict safeguards.

Our privacy practices, described in this notice, explain in detail our use and disclosure of your PHI. Generally, we do not use or disclose more information than is necessary for the purpose of the action. It should be noted that there are special protections for sensitive data, such as those related to HIV/AIDS, alcohol and drug abuse treatment, mental health and genetic information. These protections will be detailed in separate notices, which can be requested through the contact information provided in this notice.

We reserve the right to change the terms of this notice and our privacy policies at any time. Such changes will apply to PHI we already have. If our policies change significantly, we will update this notice and post a new notice on our website. In addition, you may request an updated copy of this notice at any time, either through the contact information provided here, by calling our office, during your next visit, or by viewing it directly on our website.

2. USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION (PHI)

During your admission and prior to receiving any health care services at First Steps Recovery, you will be asked to sign a statement authorizing our medical staff to use and disclose your protected health information for purposes of treatment, payment and health care operations. We use and disclose this information for a variety of reasons, and in some cases, it is necessary to obtain your prior consent or a specific authorization. Below are the different categories of uses and disclosures, along with specific examples of each, to detail how your information is handled.

2.1. Under the category of uses and disclosures related to treatment, payment or health care operations, we handle your protected health information (PHI) as follows:

1. In the treatment setting, your PHI may be shared with health care professionals, such as doctors, nurses, and medical students, who are involved in your care. For example, if you are being treated for a knee injury, your PHI may be disclosed to the physical therapy department to properly coordinate your care.
2. b. With respect to payment for treatment, we use and disclose your PHI to bill and collect payment for the services we have provided to you. This involves, for example, sending certain information to our billing department and your health plan to secure payment for health care services received. In addition, we may share your PHI with our business associates, such as billing and claims processing companies, that assist us in handling medical claims or provide services directly to you.
3. For health care operations, we use and disclose your protected health information (PHI) to manage and optimize our health care delivery system. This includes using your PHI to evaluate both the quality of health care services you have received and the performance of the professionals who have provided care to you. In addition, your PHI may be provided to our accountants, attorneys, consultants and other business associates to ensure compliance with applicable laws. In cases where it is necessary to disclose your PHI to contractors, agents and business associates who are involved in obtaining payment or conducting our business operations, we ensure that we have a written contract requiring such business associates to protect the privacy of your PHI.

2.2. In connection with other uses and disclosures of your protected health information (PHI) that do not require your consent or authorization, we proceed as follows:

1. We make disclosures of your PHI when required to do so by federal, state or local law, judicial or administrative proceedings, or law enforcement. This includes reporting to government agencies and law enforcement personnel in cases of abuse, neglect, domestic violence, gunshot wounds and other types of injuries, or in response to orders of judicial or administrative proceedings.
2. For public health reasons, we share information about births, deaths and diseases with government officials responsible for collecting such information. These activities are part of our commitment to public health and are conducted in accordance with applicable regulations.
3. In cases of abuse, neglect or domestic violence, we may disclose your PHI to public health authorities authorized to receive such information. We will always attempt to obtain your permission before making such a disclosure, although in certain circumstances we may be required or authorized to proceed without your consent.
4. In the health oversight setting, we provide relevant information to assist the government in investigations or inspections of health care providers or organizations.
5. In emergency situations where you require urgent care and we are unable to obtain your consent, we will use or disclose your PHI. Thereafter, we will seek to obtain your consent as soon as reasonably practicable.
6. If there are significant communication barriers that prevent us from obtaining your consent, and we believe you would want to receive treatment, we may use or disclose your PHI. This is based on an assessment that treatment is desired in the given situation.
7. In connection with product surveillance, repair and recall, we may disclose your information to companies or individuals required by the Food and Drug Administration to take actions such as reporting or tracking product defects and problems, making repairs, replacing or recalling defective or dangerous products, and monitoring the performance of products once they have been approved for public consumption.
8. In cases of litigation or lawsuits, if we receive an order from a court or administrative tribunal, we may disclose your PHI. This disclosure is made only when required as part of an ongoing judicial proceeding or litigation.
9. For law enforcement purposes, we may disclose your PHI to law enforcement officials in a variety of circumstances: if we need to comply with court orders or applicable laws; to assist in identifying or locating a suspect, fugitive, witness or missing person; in the event you are the victim of a crime and we were unable to obtain your consent due to emergency or incapacity, if the officials need the information immediately for their duties, and if we believe the disclosure is in your best interest based on our professional judgment; if we suspect that a patient’s death may have been the result of criminal conduct; to report crimes that occurred on our premises; or to report crimes discovered during medical emergencies off our premises.
10. For military and veterans, if you are a member of the Armed Forces, we may release PHI about you to the appropriate military command authorities for activities they deem necessary for their mission. We may also release health information about foreign military personnel to the appropriate foreign military authority.
11. In the context of inmates and correctional institutions, if you are an inmate or an inmate under the custody of law enforcement, your PHI may be disclosed to correctional officers or law enforcement officials. This is done when necessary to provide you with health care, maintain safety and order in the place of confinement, or protect the health and safety of other inmates and staff involved in supervising or transporting inmates.
12. With respect to coroners and funeral directors, in the event of your death, we may disclose your PHI to a coroner or medical examiner to determine cause of death or to funeral directors to facilitate their duties related to your death.
13. With respect to organ donation, your PHI may be shared with organ, eye or tissue procurement organizations for the purpose of assisting in donation and transplantation.
14. For research purposes, we generally request your written authorization before using your PHI. However, in certain limited circumstances, we may use and disclose your PHI without your consent if a special process, designed to minimize the risk to your privacy, gives us approval. In all instances, we guarantee that your name or identity will not be used publicly by researchers. In addition, your health information may be disclosed without your written authorization to individuals preparing for future research, ensuring that no identifiable information is disclosed outside of our facilities.
15. In order to prevent serious harm to the health or safety of a person or the public, we may provide your PHI to law enforcement officials or persons who can prevent or mitigate such a threat.
16. With respect to specific government functions, we are authorized to disclose PHI of military personnel and veterans in certain circumstances. We may also disclose PHI for national security purposes, such as protecting the President of the United States or in intelligence activities.
17. In the workers’ compensation context, we are permitted to share your PHI for the purpose of complying with workers’ compensation laws.
18. We use your PHI to send appointment reminders and to inform you about treatment options and other health care services or benefits our organization offers or provides. This use is to improve and personalize your health care experience.
19. With respect to de-identified information, we may disclose your PHI in a way that does not personally identify you. This is especially relevant in contexts such as research projects, where your information is used in a way that cannot be directly linked to you.
20. Regarding incidental disclosures, although we implement reasonable measures to protect the privacy of your PHI, inadvertent disclosures of your health information may occur in the course of permitted uses or disclosures. An example of this would be that other patients in a treatment room may unintentionally overhear conversations or view information related to your PHI.

2.3. Disclosures that you may choose to object to:

1. For patient directories, we may include your name, your location in our facility, your general health condition and religious affiliation. This information is intended for use by clergy and visitors who request information about you, as long as you do not object. In emergency situations, your consent may be obtained retroactively.
2. With respect to disclosures of your PHI to family, friends or others you designate as part of your health care or in handling payment for your health care, we may share such information unless you indicate your opposition to this. Even in emergency situations, your consent may be obtained retroactively.

2.4. Disclosures Requiring Your Prior Written Authorization:

In situations not covered in the previous sections, we will require your written authorization before proceeding to use or disclose your PHI. You have the option to revoke such authorization in writing at any time, which will stop any future uses and disclosures of your PHI, provided that we have not already taken actions based on the prior authorization.

3. RIGHTS

With respect to your rights related to your protected health information (PHI), you have the following rights:

3.1. Right to Request Restrictions on Uses and Disclosures of Your PHI. You may request that we impose limitations on the way we use and disclose your PHI. We will consider your request carefully, although we are not legally required to agree to it. If we do agree to your request, we will put those limits in writing and abide by them, except in emergency situations. Please note that it is not possible to restrict the uses and disclosures that we are required or authorized by law to make.

3.2. Right to Determine Method of Receiving Your PHI: You have the right to request that we send your PHI to an alternative address or by alternative means. We will comply with your request as long as it is feasible to provide the information in the format and location you specify.

3.3. Right to Access and Obtain Copies of Your PHI: You have the right, in most cases, to access or receive copies of your PHI that we possess, but you must make the request in writing. If we do not have your PHI but know who does, we will tell you how to obtain it. We agree to respond to your written request within 30 days. We may deny your request in certain circumstances, and if we do, we will tell you in writing the reasons for our decision and explain how you can request a review of the denial. If you request copies of your PHI, we will charge a per page fee. Alternatively, we may provide you with a summary or explanation of PHI, provided you agree to both the format and the associated cost in advance.

3.4. Right to Receive an Accounting of Disclosures: You have the right to request and obtain an accounting of certain disclosures we have made of your PHI. This list will not include disclosures that have already been disclosed to you, such as disclosures made for treatment, payment, health care operations, or those made directly to you, your family, or those listed in our facility directory. In addition, disclosures made for national security purposes and disclosures to correctional institutions or law enforcement personnel will not be included in the list.

When requesting this list, you must specify the time period desired. We pledge to respond to your request within 60 days of receipt. The list we will provide will cover disclosures made in the last six years, unless you request a shorter period. Such list will detail the date each disclosure was made, the identity of the recipient of the PHI (including the recipient’s address, if known), a description of the information disclosed, and the purpose of the disclosure. The first annual list will be provided at no charge, but if you request additional lists within the same calendar year, you will be charged for each such additional request.

3.5 Right to Amend Your PHI: If you believe that your PHI contains errors or is missing important facts, you may request a correction or addition to the information. Your request must be submitted in writing, explaining the reasons for your request. We commit to respond within 60 days of receiving your request. We may deny your request if we determine that the PHI is accurate and complete, was not created by us, its disclosure is not permitted, or it is not part of our records. In the event of a denial, we will provide you with a written response detailing the reasons and explain your right to file a statement of disagreement. If you do not file such a statement, you may request that we attach your initial request and our denial to future disclosures of your PHI. If we approve your request for amendment, we will update your PHI, inform you of the update, and notify any party that needs to know about the change in your PHI.

3.6. Right to Receive This Notice by Email: You have the option to request and receive a copy of this notice via email. In addition, even if you opt for the electronic version, you retain the right to request a paper copy of this notice at any time.

4. CONTACT INFORMATION

If you have questions or concerns about this HIPAA notice and the processing of your protected health information (PHI) or have a complaint or concern about our privacy practices and our handling of your information or have a request regarding your rights under this HIPAA notice, please contact us using the following contact information:

First Steps Recovery LLC.

Email: (insert e-mail for this type of request)

Phone: (844) 489-0836