PRIVACY PRACTICE NOTICE:
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THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND
DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS
INFORMATION. PLEASE REVIEW IT CAREFULLY.
We respect the privacy of your personal health
information. We are committed to maintaining the
confidentiality of our clients' personal health
information. This notice applies to all information
and records related to your care that Cornerstone
Christian Counseling has received or created. It
extends to information received or created by our
staff and counselors. This notice informs you about
the possible uses and disclosures of your personal
health information. It also describes your rights
and our obligations regarding your personal health
information.
We are required by law to:
• Maintain the privacy of your protected health
information;
• Provide to you this detailed notice of our legal
duties and privacy practices relating to your
personal health information; and
• Abide by the terms of the notice that is currently
in effect.
I. WITH YOUR CONSENT WE MAY USE AND DISCLOSE YOUR
PERSONAL HEALTH INFORMATION FOR PAYMENT AND HEALTH
CARE OPERATIONS
You will be asked, as part of the "Consent for
Treatment", to consent to enabling us to use and
disclose your personal health information for
purposes of payment and health care operations. We
have described these uses and disclosures below and
provide examples of the types of uses and
disclosures we may make in each of these categories.
FOR PAYMENT: We may use and disclose your personal
health information so that we can bill and receive
payment for the treatment and services you receive
at our clinic. Unless you object, we may use and
disclose your personal health information in order
to bill and receive payment for the treatment and
services from your health insurance plan. For
example, we may contact your health insurance plan
to verify that you are eligible for benefits and for
what range of benefits.
FOR HEALTH CARE OPERATIONS: We may use and disclose
your personal health information in connection with
our health care operations. These uses and
disclosures are necessary to manage the clinic and
to monitor our quality of care. Health care
operations include:
• Reviewing the competence or qualifications of
health care professionals, evaluating practitioner
and provider performance, conducting training
programs, accreditation, certification, licensing or
credentialing activities;
• Medical review, legal services, and auditing,
including fraud and abuse detection and compliance;
• Business planning and development; and
• Business management and general administrative
activities, including management activities relating
to privacy, customer services, and resolution of
internal grievances.
For example, we may use personal health information
to evaluate our clinic services, including the
performance of our staff.
II. WE MAY USE AND DISCLOSE PERSONAL HEALTH
INFORMATION ABOUT YOU FOR OTHER SPECIFIC PURPOSES
APPOINTMENT REMINDERS: We may use or disclose
personal health information to remind you of
appointments.
TREATMENT ALTERNATIVES: We may use or disclose
personal health information to inform you about
treatment alternatives and health-related benefits
and services that may be of interest to you.
AS REQUIRED BY LAW: We will disclose your personal
health information when required by law to do so.
Sometimes we must report some of your health
information to legal authorities, such as law
enforcement officials, court officials, or
government agencies. For example, we may have to
report abuse, neglect, certain physical injuries, or
respond to a court order.
FOR PUBLIC HEALTH ACTIVITIES: We may be required to
report your health information to authorities to
help prevent injury. This may include using your
health record to report information related to child
abuse or neglect.
FOR HEALTH OVERSIGHT ACTIVITIES: We may disclose
your health information to authorities so they can
monitor, investigate, inspect, discipline or license
those who work in the health care system or for
government benefit programs.
FOR ACTIVITIES RELATED TO DEATH: We may disclose
your health information to the State Department of
Health and Family Services so they can carry out
their duties related to deaths associated with a
psychotropic medication or suicide.
TO AVOID A SERIOUS THREAT TO HEALTH OR SAFETY: As
required by law and standards of ethical conduct, we
may release your health information to the proper
authorities if we believe, in good faith, that such
release is necessary to prevent or minimize a
serious and approaching threat to you or the
public's health or safety.
FOR MILITARY, NATIONAL SECURITY, OR
INCARCERATION/LAW ENFORCEMENT CUSTODY: If you are
involved with the military, national security, or
intelligence activities, or you are in the custody
of law enforcement officials or an inmate in a
correctional institution, we may release your health
information to the proper authorities so they may
carry out their duties under the law.
FOR WORKERS' COMPENSATION: We may disclose your
health information to the appropriate persons in
order to comply with the laws related to workers'
compensation or other similar programs. These
programs may provide benefits for work-related
injuries or illness.
III. YOUR AUTHORIZATION IS REQUIRED FOR OTHER USES
OR DISCLOSURES OF PERSONAL HEALTH INFORMATION
You may give us written authorization to use your
personal health information or to disclose it to
anyone for any purpose. If you give us an
Authorization, you may revoke it in writing at any
time with Cornerstone Christian Counseling. Your
revocation will not affect any use or disclosures
permitted by your Authorization while it was in
effect. Unless you give us a written Authorization,
we cannot use or disclose your personal health
information for any reason except those described in
this notice.
A NOTE ON OTHER RESTRICTIONS
Please be aware that state and federal law may have
more requirements than HIPAA on how we use and
disclose your health information. If there are more
specific restrictive requirements, even for some of
the purpose listed above, we may not disclose your
health information without your written permission
as required by such laws. We are also required by
law to obtain your written permission to use and
disclose your information related to treatment for a
mental illness, developmental disability, or alcohol
or drug abuse.
There may be other restrictions on how we use and
disclose your health information than those listed
above. We believe state and federal laws discussing
such restrictions are Minnesota Statutes Sections
144.335, 144.651; Minnesota Rule 9520; Minnesota
Data Practices Act; and 42 C.F.R. Part 2 and 45
C.F.R. Parts 160 and 164.
IV. YOUR RIGHTS REGARDING YOUR PERSONAL HEALTH
INFORMATION
While your health records are the physical property
Cornerstone Christian Counseling (CCC), the
information contained in the health record
ultimately belongs to you.
You have the following rights regarding your
personal health information that we maintain about
you:
CONFIDENTIAL COMMUNICATIONS: You have the right to
request that our practice communicate with you about
your health and related issues in a particular
manner or at a certain location. For instance, you
may ask that we contact you at home, rather than
work. In order to request a confidential
communication, submit a written request to
Cornerstone Christian Counseling, specifying the
requested method of contact or the location where
you wish to be contacted. Cornerstone Christian
Counseling will accommodate reasonable requests. You
do not need to give a reason for your request.
REQUEST RESTRICTIONS: You have the right to request
a restriction in how CCC uses or discloses your
personal health information for treatment, payment,
or healthcare operations. Additionally, you have the
right to request that CCC limits the disclosure of
your personal health information to individuals
involved in your care or the payment for your care,
such as family members and friends. CCC is not
required to agree to your request. However, if CCC
does agree, CCC is bound by the agreement except
when otherwise required by law, in emergencies, or
when the information is necessary to treat you.
You may verbally request that we restrict our
disclosure of your personal health information,
however, we may request you submit your request in
writing to CCC. Your request must describe in a
clear and concise fashion: (a) the information you
wish restricted; (b) whether you are requesting to
limit CCC's use, disclosure or both; and (c) to whom
you want the limits to apply.
ACCESS: You have the right to inspect and obtain a
copy of your personal health information that we use
to make decisions about you, including medical
records and billing records, except as excluded by
law such as psychotherapy notes. Submit your request
in writing to Cornerstone Christian Counseling
clinic in order to inspect or obtain a copy of your
personal health information. We may charge a
reasonable fee for our costs in copying and mailing
your requested information. We may deny your request
to inspect and/or copy in certain limited
circumstances. If you are denied access to personal
health information, in some cases you will have a
right to request review of the denial. This review
would be performed by a licensed health care
professional designated by Cornerstone Christian
Counseling who did not participate in the decision
to deny.
AMENDMENT: You have the right to request that we
amend your personal health information if you
believe it is incorrect or incomplete as long as the
information is kept by or for Cornerstone Christian
Counseling. You may ask to amend your health
information that created by CCC. You must make your
request in writing, and it must explain why the
information should be amended.
We may deny your request for amendment if the
information:
• Was not created by CCC, unless the originator of
the information is no longer available to act on
your request;
• Is not part of the personal health information
kept by or for CCC;
• Is not part of the information to which you have a
right to access; or
• Is already accurate and complete, as determined by
CCC.
If we deny your request for amendment, we will
provide you with a written explanation. You may
respond with a statement of disagreement to be
appended to the information you wanted to amend.
If we accept your request to amend the information,
we will make reasonable efforts to inform others,
including people you name, of the amendment and to
include the changes in any future disclosures of
that information.
ACCOUNTING OF DISCLOSURES: You have the right to
request an "accounting" of our disclosures of your
personal health information. This is a listing of
certain disclosures of your personal health
information made by CCC for purposes other than (a)
treatment, payment and health care operations, (b)
as consented and/or authorized by you, and (c) for
certain other activities, as of April 14, 2003. To
request an accounting of disclosures, you must
submit a request in writing to CCC. An accounting
will include, if requested: the disclosure date; the
name of the person or entity that received the
information; a brief description of the information
disclosed; and a brief statement of the purpose of
the disclosure or a copy of the request. The first
accounting within a 12-month period will be free;
for further requests, we may charge you a reasonable
cost-based fee.
RIGHT TO A PAPER COPY OF THIS NOTICE: You are
entitled to receive a paper copy of our notice of
privacy practices. You may ask us to give you a copy
of the notice at any time. To obtain a paper copy of
this notice, contact Cornerstone Christian
Counseling. This Notice is also available to you on
our web site at www.cstonechristianco.org.
V. COMPLAINTS
If you have concerns that we may have violated your
privacy rights, or you disagree with a decision we
made about access to your personal health
information or in response to a request you made to
amend or restrict the use or disclosure of your
personal health information, you may file a
complaint in writing with the Minnesota Board for
Behavioral Health and Therapy, 2829 University Ave.
SE, #210, Minneapolis, MN 55414-3251.
You may also submit a written complaint to the U.S.
Department of Health and Human Services.
We support your right to privacy of your personal
health information. We will not retaliate in any way
if you choose to file a complaint with us or with
the U.S. Department of Health and Human Services.
VI. CHANGES TO THIS NOTICE
We will promptly revise and distribute this Notice
whenever there is a material change to the uses or
disclosures, your individual rights, our legal
duties, or other privacy practices stated in the
Notice. We reserve the right to change this Notice
and to make the revised or new Notice provisions
effective for all personal health information
already received and maintained by Cornerstone
Christian Counseling as well as for all personal
health information we receive in the future. We will
post a copy of the current Notice. We will provide a
copy of the revised Notice to all Clients and/or
their representatives at the CCC office.
VII. FOR FURTHER INFORMATION
This Notice takes effect June 1, 2006 and will
remain in effect until we replace it. If you have
any questions about this Notice of our Privacy
Practices or would like further information
concerning your privacy rights, please contact
Daniel C. Loe, MS, LPC, NCC, President, Cornerstone
Christian Counseling, Inc., 507-354-1147.