Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
PER THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) OF 1996, WE HAVE A LEGAL DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION. We will protect the privacy of information that we maintain that identifies you or your health. This notice does not apply to health information that does not contain identifiers that could reasonably be linked to you. We are required to provide you with this Notice about our privacy practices. It explains how, when, and why we may use and disclose your health information. With some exceptions, we will use or disclose no more of your health information than is necessary to accomplish the purpose of the use or disclosure. We are legally required to follow the terms described in this Notice, which is currently in effect.

We reserve the right to change the terms of this Notice and our privacy practices at any time. Any changes will apply to any of your health information that we already have. Before we make an important change to our policies, we will promptly change this Notice and post a new Notice in our waiting room or reception area. You may also request, at any time, a copy of our current Notice of Privacy Practices from our Compliance Officer/Privacy Officer by calling 412-351-0222.

We would like to take this opportunity to answer some common questions concerning our privacy practices:

QUESTION: HOW WILL TURTLE CREEK VALLEY MH/MR, INC. (TCV) USE AND DISCLOSE MY PROTECTED HEALTH INFORMATION?
Answer: We may use and disclose your health information for many different reasons. Below, we describe different reasons and provide examples in which your health information may be used or disclose. These examples do not include all of the specific ways we may use or disclose your information, but any uses or disclosure will fall the general reasons outlined below.

1. Uses and Disclosures Relating to Treatment, Payment, or Healthcare Operations. We may, by federal law, use and disclose your health information for the following reasons:
   1. For Treatment/Services: We will use your health information to provide you with health services. For example, we may disclose your medical history to a hospital if you need medical attention while at our facility or to a residential care program to which we are referring you. Reasons for such a disclosure may be: to get them the medical history information they need to appropriately treat your condition, to coordinate your care, or to schedule necessary testing. With the possible exception of information concerning drug and alcohol abuse and/or treatment, and HIV status (for which we may need your specific authorization), we may also disclose your health information to other health care providers who are involved in your care.
   2. To Obtain Payment for Treatment: For example, we may provide certain portions of your health information to your health insurance company, Medicare or Medicaid, managed care entity, county funded service coordination unit or the County (Mental Health/Mental Retardation, Behavioral Health, Children and Family Services or Community Services) in order to get paid for the provision of you care. With the possible exception of information concerning drug and alcohol abuse and/or treatment, and HIV status (for which we may need your specific authorization), we may use and disclose necessary health information in order to bill and collect payment for the treatment that we have provided to you.
   3. For Health Care Operations: We may, at times, need to use and disclose your health information for activities necessary to operate our organization. For example, we may use your health information to evaluate the quality of the treatment that our staff has provided to you. We may also need to provide some of your health information to our accountants, attorneys, and consultants in order to make sure that we’re complying with law. Because this information concerns mental health disorders and/or treatment, drug and alcohol abuse and/or treatment, and/or HIV status, we may be further limited in what we provide and may be required to first obtain your authorization.
      Turtle Creek Valley MH/MR, Inc. Effective Date: September 23, 2013
      REV 9/2013
   4. Other: Occasionally we have visitors working at or touring our facilities in consideration of services to be provided. No individually identifiable health information will be disclosed.
2. Certain Other Uses and Disclosures are permitted by Federal Law. We may use and disclose your health information without your authorization for the following reasons:
   1. When a Disclosure is required by Federal, State, or Local Law, in Judicial or Administrative Proceedings, or by Law Enforcement. For example, we may disclose your protected health information if we are ordered by a court, or if a law requires that we report that sort of information to a government agency or law enforcement authorities, such as suspected child abuse.
   2. For Public Health Activities. Under the law, we are required to report information for public health purposes. This includes, but is not limited to reporting certain diseases and deaths to government agencies responsible for collecting this information. We may also be required to notify people who have been
      exposed to disease. With the possible exception of information concerning HIV status (for which we may need your specific authorization), we are also permitted to provide some health information to the coroner or a funeral director, if necessary, after a client’s death.
   3. For Health Oversight Activities. We may need to provide your health information to government agencies that have a legal responsibility to monitor the health care system. For example, we may be required to disclose your health information if we are audited by Medicare or Medicaid or as part of the oversight activities of the County and/or State.
   4. For Organ Donation. If one of our clients wished to make an eye, organ, or tissue donation after their death, we may disclose certain necessary health information to assist the appropriate organ procurement organization.
   5. For Research Purposes. In certain limited circumstances (for example, where approved by an appropriate Privacy Board or Institutional Review Board under federal law), we may be permitted to use or provide protected health information for a research study.
   6. To Avoid Harm. If we believe that it is necessary to protect you, to protect another person, or the public as a whole, we may disclose your health information only to those who may be able to prevent or lessen the possible harm.
   7. For Specific Government Functions. Similarly, with the possible exception of information concerning drug and alcohol abuse and/or treatment, and HIV status (for which we may need your specific authorization), we may disclose your health information for national security purposes. We may disclose the health information of military personnel or veterans where required by U.S. military authorities.
   8. For Workers’ Compensation. We may provide your health information as described under the workers’ compensation and work site safety laws (OSHA, for example), if your condition was the result of a workplace injury for which you are seeking worker’s compensation.
   9. Appointment Reminders and Health-Related Benefits or Services. We may use or disclose your information to provide you with appointment reminders or alternative programs and treatments that may help you. If you do not wish to receive these, notify us of your desire to opt out of these communications.
   10. Fundraising Activities. We may use your information to contact you to ask for donations. For example, if our Organization chose to raise funds to support one or more of our programs or facilities, or some other charitable cause or community health education program, we may use your information to contact you to request donations. If you do not wish to be contacted as part of any fundraising activities, notify us, following initial contact, of your desire to opt out of such communication.
3. Certain Uses and Disclosures Require You to Have the Opportunity to Object.
   1. Disclosures to Family, Friends, or Others Involved in Your Care. We may provide a limited amount of your health information to a family member, friends, or other person known to be involved in your care or in the payment for your care, unless you tell us otherwise. For example, if a family member comes with you to your appointment and you allow them to come into the treatment room with you, we may disclose otherwise protected health information to them during the appointment, unless you tell us not to.
   2. Disclosures to Notify a Family Member, Friend, or Other Selected Person. When you first started in our program, we asked that you provide us with an emergency contact person in case something should (Turtle Creek Valley MH/MR, Inc. Effective Date: September 23, 2013 – REV 9/2013) happen to you while you are at our facilities. Unless you tell us otherwise, we will disclose limited health information about you (your general condition, location, etc.) to your emergency contact or another available family member. For example, should you need to be admitted to the hospital?
4. Other Uses and Disclosures Require Your Prior Written Authorization. In situations other than those categories of uses and disclosures mentioned above, or those disclosures permitted under federal law, we will ask for your written authorization before using or disclosing any of your protected health information.
   Most uses and disclosures of psychotherapy notes (where appropriate), uses and disclosures of PHI for marketing purposes, and disclosures that constitute sale of PHI require authorization.If you authorize us to use or disclose your health information, you have the right to revoke the authorization at any time. You must notify us of your revocation in writing, unless you are receiving drug and alcohol services, to which verbal revocation is acceptable. You may not revoke an authorization for us to use and disclose your information to the extent that we have taken action in reliance on the authorization. In addition, if the authorization is to permit disclosure of your information to an insurance company, as a condition of coverage, other laws may allow the insurer to continue to use your information to contest claims or your coverage, even after your revocation of authorization.

QUESTION: WHAT RIGHTS DO I HAVE CONCERNING MY PROTECTED HEALTH INFORMATION?
Answer: You have the following rights with respect to your protected health information:

1. The Right to Request Limits on Uses and Disclosures of Your Health Information. You have the right to ask us to limit how we use or disclose your health information. We are not required to agree, except to restrict your health information from going to a health plan for purposes of carrying out payment or health plan operations if you have first paid for the service out of pocket in full. If we do agree, we will comply with the request unless the information is needed to provide you with emergency treatment. We cannot agree to restrict disclosures that are required by law or for treatment purposes.
2. The Right to Choose How We Send Health Information to You or How We Contact You. You have the right to ask that we contact you at an alternative address or telephone number (for example, sending information to your work address instead of your home address) or by other alternative means. We will not ask you to explain why you are making the request. We will agree to any reasonable request.
3. The Right to See or to Get a Copy of Your Protected Health Information. You have the right to look at or receive a copy (hard copy or electronic) of the health information about you that we have in our records. This includes your request for us to send your health information to an entity or person designated by you such as a Personal Health Record. Your request must be made in writing using a request form, which is available at the reception desk or from the Medical Records Department by calling 412-351-0222, x4447. We will respond to you within 30 days after receiving your written request. If we do not have the health information that you are requesting, but we know who does, we will tell you how to get it. In certain situations, we may deny your request. If we do, we will provide a reason for the denial, in writing. In certain circumstances, you may have a right to appeal the decision.If you request a copy of any portion of your protected health information, we may charge a fee for the cost of copying, reproducing in electronic media, and mailing the records, only as permitted under Pennsylvania state law. We require that payment be made in full before we will provide the copy to you. If you agree in advance, we may be able to provide you with a summary or an explanation of your records in lieu of a full copy. There may be a charge for the preparation of the summary or explanation, including charge for staff time to develop the summary.
4. The Right to Receive a List of Certain Disclosures of Your Health Information That We Have Made. You have the right to get a list of certain disclosures of your health information that we have made to others. We will respond to you within 60 days of receiving your request. The list will include the date of the disclosure, the person or organization that received the information (with their address, if available), a brief description of the information (Turtle Creek Valley MH/MR, Inc. Effective Date: September 23, 2013 – REV 9/2013) disclosed, and a brief reason for the disclosure. You may not request an accounting for more than a six (6) year period.This list would not include uses or disclosures for the following purposes: treatment, payment or healthcare operations, disclosures to you or with your written authorization; disclosures to your family for notification purposes or due to their involvement in your care; any disclosures made for national security purposes; disclosures to corrections or law enforcement authorities if you were in custody at the time; disclosures made prior to April 14, 2003; and disclosures made directly to you.Your request must be made in writing using a request form, which is available at the reception desk or from the Medical Records Department by calling 412-351-0222, x4447. We will provide the first list of disclosures at no charge; but, if you make more than one request in the same calendar year, you will be charged a fee for each additional request that year.
5. The Right to Ask to Correct or Update Your Health Information. You have the right to ask us to amend, correct or update health information about you if you believe that there is a mistake or that a piece of important information is missing. Your request must be made in writing using a request form, which is available at the reception desk or from the Medical Records Department by calling 412-351-0222, x4447. We will respond within 60 days of receiving your request. If we approve your request, we will make the change to your health information, tell you when we have done so, and will tell others that need to know about the change.
   We may deny your request if the protected health information: (1) is correct and complete; (2) was not created by us; (3) is not allowed to be disclosed to you; or (4) is not part of our records. Our written denial will state the reasons that your request was denied and explain your right to file a written statement of disagreement with the denial. If you do not wish to do so, you may ask that we include a copy of your request form, and our denial form, with all future disclosures of that health information.
6. The Right to be Notified of a Breach of your Protected Health Information. We are required by law to notify you following a breach of unsecured protected health information.

QUESTION: HOW DO I COMPLAIN OR ASK QUESTIONS ABOUT THIS ORGANIZATION’S PRIVACY PRACTICES?
Answer: You have a right to complain about our privacy practices, if you think your privacy has been violated. You may file your complaint with the Compliance Officer/Privacy Officer at 412-351-0222. You also have the right to file a written complaint with the Secretary of the U.S. Department of Health and Human Services. All complaints must be in writing. We cannot take any retaliatory action against you if you lodge any type of complaint.

QUESTION: WHEN DOES THIS NOTICE TAKE EFFECT?
Answer: This Notice takes effect on September 23, 2013.