Privacy & Cost Notices

Our pledge regarding your health information

Information about you and your care is personal, and we are committed to protecting it. We create a record of the care and services you receive here in order to provide you with quality care and to meet legal requirements. This notice applies to all records of your care created by Ala Therapy Collective, and it covers every clinician, supervisee, student, and staff member who works here.

We are required by law to:

• Keep protected health information (PHI) that identifies you private, with limited exceptions described below.
• Give you this notice of our legal duties and privacy practices.
• Follow the terms of the notice currently in effect.
• Notify you if a breach occurs that may have compromised the privacy or security of your information.

We may change the terms of this notice, and any change applies to all information we hold about you. The current notice is always available on request, in our office, on our website, and in your SimplePractice client portal.

Who is covered by this notice

Ala Therapy Collective is a group practice. Your care may involve more than one person here:

• Your clinician, who provides your treatment.
• A licensed supervisor, when your clinician is a provisionally licensed clinician or a social work student in a supervised practicum. Supervision means your supervisor discusses your care with your clinician, reviews your record, and co-signs your documentation. This is required by law and is part of how we ensure quality care.
• A student in a supervised practicum, only with your knowledge and consent. You will always be told when a student is involved in your care, in writing and in person, and you may decline without any effect on your treatment.
• Administrative staff, who handle scheduling, billing, and records.

Everyone listed here is bound by this notice and by the same confidentiality requirements.

How we may use and disclose health information about you

The categories below describe the ways we use and disclose health information. Not every possible use or disclosure is listed, but every use we are permitted to make falls within one of these categories.

For treatment, payment, or health care operations. Federal privacy rules allow health care providers who have a direct treatment relationship with a client to use or disclose that client's PHI without written authorization in order to carry out treatment, payment, or health care operations.

We may also disclose your PHI for the treatment activities of another health care provider without your written authorization. For example, if your clinician consults with another licensed health care provider about your care, we may use and disclose your PHI in order to assist in diagnosis and treatment.

Disclosures for treatment purposes are not limited to the minimum necessary standard, because clinicians and other health care providers may need the full record in order to provide quality care. "Treatment" includes coordination and management of care with a third party, consultations between providers, and referral of a client from one provider to another.

Supervision. When your clinician practices under supervision, your record and information about your care are reviewed by their supervisor as part of treatment and quality of care.

Lawsuits and disputes. If you are involved in a lawsuit, we may disclose health information in response to a court or administrative order. We may also disclose health information in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only after efforts have been made to notify you of the request or to obtain an order protecting the information requested.

Certain uses and disclosures require your written authorization

Psychotherapy notes. We keep "psychotherapy notes" as that term is defined in 45 CFR § 164.501. Any use or disclosure of those notes requires your written authorization unless the use or disclosure is:

• For use by your clinician in treating you.
• For use in training or supervising mental health practitioners to help them improve their skills in group, joint, family, or individual counseling or therapy.
• For use in defending ourselves in legal proceedings instituted by you.
• For use by the Secretary of Health and Human Services to investigate our compliance with HIPAA.
• Required by law, and limited to the requirements of that law.
• Required by law for certain health oversight activities pertaining to the originator of the notes.
• Required by a coroner performing duties authorized by law.
• Required to help avert a serious threat to the health and safety of others.

Marketing. We will not use or disclose your PHI for marketing purposes.

Sale of PHI. We will not sell your PHI.

Anything else. Any other use or disclosure of your PHI not described in this notice will be made only with your written authorization. You may revoke an authorization in writing at any time, except to the extent we have already acted in reliance on it.

Certain uses and disclosures do not require your authorization

Subject to limitations in the law, we may use and disclose your PHI without your authorization for the following reasons:

• When disclosure is required by state or federal law, and the use or disclosure complies with and is limited to the relevant requirements of that law.
• For public health activities, including reporting suspected abuse or neglect of a child, an elder, or a vulnerable adult, or preventing or reducing a serious threat to anyone's health or safety. In Oklahoma, every person who has reason to believe a child under 18 is being abused or neglected is required by law to report it.
• For health oversight activities, including audits and investigations.
• For judicial and administrative proceedings, including responding to a court or administrative order, although our preference is to obtain your authorization first.
• For law enforcement purposes, including reporting crimes occurring on our premises.
• To coroners or medical examiners performing duties authorized by law.
• For research purposes, subject to the protections required by law.
• For specialized government functions, including military missions, protection of the President, intelligence and counter-intelligence operations, and the safety of people working within or housed in correctional institutions.
• For workers' compensation purposes, although our preference is to obtain your authorization first.
• For appointment reminders and information about treatment alternatives or other services and benefits we offer.

Certain uses and disclosures give you the opportunity to object

Disclosures to family, friends, or others. We may provide your PHI to a family member, friend, or other person you indicate is involved in your care or in payment for your care, unless you object in whole or in part. In an emergency, we may obtain your agreement afterward.

Your rights regarding your health information

The right to request limits on uses and disclosures. You may ask us not to use or disclose certain PHI for treatment, payment, or health care operations. We are not required to agree, and we may decline if we believe it would affect your care.

The right to request restrictions for services paid out of pocket in full. You may request that we not disclose your PHI to a health plan for payment or health care operations purposes when the information relates solely to a service you paid for out of pocket in full. We are required to agree to that request.

The right to choose how we contact you. You may ask us to contact you in a specific way, such as a particular phone number, or to send mail to a different address. We will agree to all reasonable requests.

The right to see and get copies of your record. Other than psychotherapy notes, you have the right to an electronic or paper copy of your record and other information we hold about you. We will provide it within 30 days of your written request, and we may charge a reasonable, cost-based fee. If we believe that reviewing part of your record could reasonably be expected to endanger your life or physical safety, or the life or safety of another person, we may deny access to that part and will tell you in writing why, and how to have that decision reviewed by another licensed professional. You may also choose to receive a summary instead of the full record, or to review your record together with your clinician in a session; both are options available to you, not conditions we place on access.

The right to a list of disclosures we have made. You may request a list of instances in which we disclosed your PHI for purposes other than treatment, payment, or health care operations, or other than disclosures you authorized. We will respond within 60 days. The list will cover disclosures in the last six years unless you request a shorter period. The first list in a 12-month period is free; we may charge a reasonable, cost-based fee for additional requests in the same period.

The right to correct or update your record. If you believe information in your record is wrong or incomplete, you may request that we correct it or add the missing information. We may decline, and if we do, we will tell you why in writing within 60 days.

The right to a paper or electronic copy of this notice. You may request a paper copy of this notice at any time, including if you have already received it electronically.

The right to complain. If you believe your privacy rights have been violated, you may file a complaint with us or with the U.S. Department of Health and Human Services.

• With us: contact Shylah Ridgway, LCSW, LICSW, Privacy Officer, Ala Therapy Collective, 8524 S Western Ave, Suite 115, Oklahoma City, OK 73139, (405) 776-9950, Shylah@AlaTherapyCollective.com.
• With HHS: Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Avenue SW, Washington, DC 20201, 1-877-696-6775, or online at hhs.gov/ocr/privacy/hipaa/complaints.

We will not retaliate against you for filing a complaint.

Oklahoma law

Where Oklahoma law provides greater protection for your health information than federal law, we follow Oklahoma law.

Mobile and text messaging

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties.

Acknowledgement of receipt

Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), you have certain rights regarding the use and disclosure of your protected health information. You will be given a copy of this Notice of Privacy Practices and asked to acknowledge that you received it.