Privacy Policy

Notice of Privacy Practices and Confidentiality of Alcohol and Drug Abuse Client Records

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please read this information carefully.

Health information which we receive and/or create about you, personally, in this program, relating to your past, present, or future health, treatment, or payment for health care services is ‘protected health information’ (PHI) under the Federal law known as the Health Insurance Portability and Accountability Act (HIPAA), 45 C.F.R. Parts 160 and 164. The confidentiality of alcohol and drug abuse patient records maintained by this program is protected by another Federal law as well, commonly referred to as the Alcohol and Other Drug (AOD) Confidentiality Law, 42 C.F.R. Part 2. Generally, the program may not say to a person outside the program that you attend the program, or disclose any information identifying you as an alcohol or drug abuser, or use or disclose any other protected health information except in limited circumstances as permitted by Federal law. Your health information is further protected by any pertinent state law that is more protective or stringent than either of these two Federal laws.

This notice describes how we protect personal health information (otherwise referred to as “protected health information”) we have about you, and how we may use and disclose this information. This Notice also describes your rights with respect to protected health information and how you can exercise these rights.

Uses and disclosures that may be made of your health information

Internal Communications: Your PHI will be used within our program that is between and among program staff who have a need for the information in connection with our duty to diagnose, treat, or refer you for substance abuse treatment. This means that your protected health information may be shared between or among personnel for treatment or health care operation purposes.  The program may also share your protected health information in a billing effort to receive payment for the health care services rendered to you, and/or, your PHI may be discussed within the program about your treatment in conjunction with others in the program, in an effort to improve the overall quality of care provided by our program personnel.

Qualified Service Organizations and/or Business Associates: Some, or all, of your PHI may be subject to disclosure through contracts for services with qualified service organizations and/or business associates, outside of this program, that assist our program in providing health care. Examples of qualified service organizations and/or business associates include billing companies, data processing companies, or companies that provide administrative or specialty services. To protect your health information, we require these qualified service organizations and/or business associates to follow the same standards held by this program through terms detailed in written agreements.

Medical Emergencies: Your health information may be disclosed to medical personnel in a medical emergency, when there is an immediate threat to the health of an individual, and when immediate medical intervention is necessary.

To Researchers: Under certain circumstances, this office may use and disclose your PHI for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one test or treatment to those who received another, for the same condition. All research projects, however, must be approved by an Institutional Review Board, or other private review board as permitted with the regulations, that has reviewed the research proposal and established protocols to ensure the privacy of your PHI.

To Auditors and Evaluators: This program may disclose PHI to regulatory agencies, funders, third-party payers, and peer review organizations that monitor alcohol and drug programs to ensure that the program is complying with regulatory mandates and is properly accounting for and disbursing funds received.

Authorizing Court Order: This program may disclose your PHI pursuant to an authorizing court order. This is a unique kind of court order in which certain application procedures have been taken to protect your identity, and in which the court makes certain specific determinations as outlined in the Federal regulations and limits the scope of the disclosure.

Crime on Program Premises or Against Program Personnel: This program may disclose a limited amount of PHI to law enforcement when a client commits, or threatens to commit, a crime on the program premises or against program personnel.
Reporting Suspected Child Abuse and Neglect: This program may report suspected child abuse or neglect as mandated by state law.
As Required by Law: this program will disclose PHI as required by law, when necessary, in a manner that does not identify you as a client in a substance abuse treatment program.

Appointment Reminders: This program reserves the right to contact you, in a manner permitted by law, with appointment reminders or information about treatment alternatives and other health related benefits that may be appropriate to you.

Other Uses and Disclosures of Protected Health Information: Other uses and disclosures of PHI not covered by this notice will be made only with your written authorization or that of your legal representative. If you, or your legal representative, authorize us to use or disclose PHI about you, you or your legal representative may revoke that authorization, at any time, except to the extent that we have already taken action relying on that authorization.

Your rights regarding Protected Health Information we maintain about you

Right to Inspect and Copy: In most cases, you have the right to inspect and obtain a copy of the PHI that we maintain about you. To inspect and copy your PHI, you must submit your request, in writing, to this organization. In order to receive a copy of your PHI, you may be charged a fee for photocopying, mailing, or other costs associated with your request. In some very limited circumstances we may, as authorized by law, deny your request to inspect and obtain a copy of your PHI. You will be notified of a denial to any part, or parts, of your request. Some denials, by law, are reviewable, and you will be notified regarding the procedures for invoking a right to have a denial reviewed. Other denials, however, as set forth in the law, are not reviewable.

Right to Amend Your Protected Health Information: If you believe that your PHI is incorrect or that an important part is missing, you have the right to ask us to amend your PHI while it is kept by, or for us. You must provide your request and your reason for the request in writing, and submit it to this office. We may deny your request if it is not in writing or does not include a reason that supports the request. In addition, we may deny your request if you ask us to amend PHI that we believe:

• Is accurate and complete;
• Was not created by us, unless the person or entity that created the PHI is no longer available to us;
• Is not part of the PHI kept by or for us; or
• Is not part of the PHI, which you would be permitted to inspect and copy.

If your right to amend is denied, we will notify you of the denial and provide you with instructions on how you may exercise your right to submit a written statement disagreeing with the denial and/or how you may request that your request to amend and a copy of the denial be kept together with the PHI at issue, and disclose together with any further disclosure of the PHI at issue.

Right to an Accounting of Disclosures: You have the right to request an accounting, or list, of the disclosures that we have made of PHI about you. This list will not include certain disclosures as set forth in the HIPAA regulations, including those made for treatment, payment, or health care operations within our program or made pursuant to your authorization or made directly to you. To request this list, you must submit your request in writing to this office. Your request must state the time period from which you want to receive a list of disclosures. The time period may be no be longed than six years, and may not include dates before November 1, 2014. Your request should indicate in what form you want the list (for example, written or electronically). The first list you request within a 12-month period will be free of charge. We may charge you for responding to any additional requests. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions: You have the right to request a restriction or limitation on the PHI we are permitted to use or disclose about you for treatment, payment or health care operations within our program and/or between our program and other payers. While we will consider your request, we are not required to grant the request. If we do agree to it, we will comply with your request, except in emergency situations where your PHI is needed to provide you with emergency treatment. We will not agree to restrictions on uses or disclosures that are legally required, or those which are legally permitted and which we reasonably believe to be in the best interest of your health.

Right to Request Confidential Communications: You have the right to request that we communicate with you about PHI in a certain manner or at a certain location. For example, you may ask that we only contact you at your work place, or by mail. To request confidential communications, you must make your request in writing to this office, and specify how or where you wish to be contacted. We will accommodate all reasonable requests.

Right to File a Complaint: If you believe your privacy rights have been violated, you may file a complaint with Sanford House at 616-288-6970, or with network 180 Office of Recipient Rights at 616-336-3765. You may also appeal to the Michigan Department of Community Mental Health at 1-800-854-9090.

To file a complaint with this office, please contact the Sanford House Recipient Rights Advisor Lisa Nargi at 616-288-6970. You will not be penalized or otherwise retaliated against for filing a complaint.

Availability of Notice of Privacy Practices: This Notice will be posted where admission occurs. You have a right to receive a copy of this Notice, and all individuals receiving care will be given a hard copy.

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