Connecting Point Community Children and Counselling Services Privacy Statement 2005

Effective Date April 14, 2003

CONNECTING POINT2006

NOTICE OF PRIVACY PRACTICES THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.

PLEASE REVIEW CAREFULLY. UNDERSTANDING YOUR HEALTH RECORD/INFORMATION
Each time you visit Connecting Point a record of your visit is made. Typically, this record contains your symptoms, examination and test results, diagnosis, treatment and a plan for future care or treatment. This information often referred to as your health or medical record, serves as a basis for planning your care and treatment and serves as a means of communication among the many health professionals who contribute to your care. Our Billing department also collects and maintains a record of services provided to you in order to receive payment. Understanding what is in your record and how your health information is used helps you to ensure its accuracy, better understand who, what, when, where, and why others may access your health information, and make more informed decisions when authorizing disclosures to others.

OUR DUTY TO SAFEGUARD YOUR PROTECTED HEALTH INFORMATION
Unless otherwise required by law your health record is the physical property of Connecting Point or the healthcare practitioner or facility that compiled it, however the information belongs to you. Individually identifiable information about your past, present, or future health or condition, the provision of health care to you, or payment for the health care is considered "Protected Health Information" ("PHI"). We are required to extend certain protections to your PHI, and to give you this Notice about our privacy practices that explains how, when and why we may use or disclose your PHI. Except in specified circumstances, we must use or disclose only the minimum necessary PHI to accomplish the intended purpose of the use or disclosure.

CHANGES TO THIS NOTICE
We are required to follow the privacy practices described in this Notice, though we reserve the right to change our privacy practices and the terms of this Notice at any time and to make the revised or changed notice effective for all Protected Health information we already have about you as well as any information we may receive in the future. You may request a copy of the new notice from any Connecting Point site. A copy will be posted at all of our locations as well as on our Website at http://www.connectingpoint.org/

FOR MORE INFORMATION OR TO REPORT A PROBLEM
If you have questions and would like additional information, you may contact the Privacy Official, Linda Willie at 419-321-6820

HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION
We use and disclose PHI for a variety of reasons. We have a limited right to use and/or disclose your PHI for purposes of treatment, payment, or healthcare operations. For uses beyond that, we must have your written authorization unless the law permits or requires us to make the use or disclosure without your authorization. If we disclose your PHI to an outside entity to perform a function on our behalf, we must have in place an agreement from the outside entity that it will extend the same degree of privacy protection to your information that we must apply to your PHI. However, the law provides that we are permitted to make some uses/disclosures without your consent or authorization. The following offers more description and some examples of our potential uses/disclosures of your PHI. It is not meant to be an all-inclusive list.

USES AND DISCLOSURES RELATING TO TREATMENT, PAYMENT, OR HEALTH CARE OPERATIONS.

Generally, we may use or disclose your PHI as follows:

For treatment: We may disclose your PHI to doctors, nurses and other health care personnel who are involved in your health care. For example, your PHI will be shared among members of your treatment team. Our community-based treatment providers may need to carry portions of your record with them when they visit your home. For example in order to work on developing an individualized treatment plan and obtain your signature, your provider will need to transport the completed plan with them.

To obtain payment: We may use/disclose your PHI in order to bill and collect payment for your health care services. For example, we may contact your employer to verify employment status, and/or release portions of your PHI to the Medicaid program, the local ADAMH/CMH Board (through the Multi-Agency Community Information Services Information System (MACSIS) and/or a private insurer to get paid for services that we delivered to you. This may include certain activities that your health insurance plan may undertake before it approves or pays for the health services we recommend for you such as; making a determination of eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity, and undertaking utilization review activities. We may release information to the Office of Attorney General for collection purposes.

For Health Care Operations: We may use/disclose your PHI in the course of operating our Agency. Members of our quality improvement team may use information in your health record to assess the care and outcomes in your case and others like it. The results will then be used to continually improve the quality of care for all clients we serve. For example, we may combine treatment information about many clients to evaluate the need for new services or treatment, we may also ask you to participate in client satisfaction surveys. We may take your photograph for medication identification purposes, or disclose your PHI to our accountant or attorney for audit purposes. Release of your PHI to the Multi-Agency Community Services Information System and/or state agencies might also be necessary to determine your eligibility for publicly funded services.

Appointment reminders: Unless you provide us with alternative instructions, we may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.

Business associates: There are some services provided in our organization through contracts with business associates. For example, at times medical notes dictated by your physician may be contracted to a transcription service. When services are contracted, we may disclose your health information to our business associate so that they can perform the job we¹ve asked them to do. To protect your health information, however, we require the business associate to apply the same safeguards to your information as we do.

USES AND DISCLOSURES OF PHI REQUIRING AUTHORIZATION

For uses and disclosures beyond treatment, payment and operations purposes we are required to have your written authorization, unless the use or disclosure falls within one of the exceptions described below. Authorizations can be revoked at any time to stop future uses/disclosures except to the extent that we have already undertaken an action in reliance upon your authorization.

USES AND DISCLOSURES OF PHI FROM MENTAL HEALTH RECORDS NOT REQUIRING CONSENT OR AUTHORIZATION

The law provides that we may use/disclose your PHI from mental health records without consent or authorization in the following circumstances:

When required by law: We may disclose PHI when a law requires that we report information about suspected abuse, neglect or domestic violence, or relating to suspected criminal activity, or in response to a court order. We must also disclose PHI to authorities that monitor compliance with these privacy requirements.

For public health activities: We may disclose PHI when we are required to collect information about disease or injury, or to report vital statistics to the public health authority.

For health oversight activities: We may disclose PHI to the Ohio Department of Mental Health, Ohio Department of Drug and Alcohol Addiction Services, JCAHO, Ohio Department of Job and Family Services, Office of Inspector General, Health and Human Services, and Office of Civil Rights for monitoring the health care system for such purposes as reporting or investigation of unusual incidents, and monitoring of the Medicaid program.

For research purposes: We may disclose information to researchers when an institutional review board that has reviewed the research proposal and established protocols to ensure privacy of your health information has approved their research.

To avert threat to health or safety: In order to avoid a serious threat to health or safety, we may disclose PHI as necessary to law enforcement or other persons who can reasonably prevent or lessen the threat of harm.

For specific government functions: We may disclose information to correctional facilities in certain situations, to government benefit programs relating to eligibility and enrollment, and for national security reasons, such as protection of the President.

USES AND DISCLOSURES OF PHI FROM ALCOHOL AND OTHER DRUG RECORDS NOT REQUIRING CONSENT OR AUTHORIZATION

The law provides that we may use/disclose your PHI from alcohol and other drug records without consent or authorization in the following circumstances:

When required by law: We may disclose PHI when a law requires that we report information about suspected child abuse and neglect, or when a crime has been committed on the program premises or against program personnel, or in response to a court order.

Relating to decedents: We may disclose PHI relating to an individual¹s death if state or federal law requires the information for collection of vital statistics or inquiry into cause of death.

For research, audit or evaluation purposes: In certain circumstances, we may disclose PHI for research, audit or evaluation purposes.

To avert threat to health or safety: In order to avoid a serious threat to health or safety, we may disclose PHI.

To law enforcement: when a threat is made to commit a crime on the program premises or against program personnel.

YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION
You have the following rights relating to your protected health information:

To request restrictions on uses/disclosures: You have the right to ask that we limit how we use or disclose your PHI for treatment, payment or health care operations, and certain disclosures to family members. We will consider your request, but are not legally bound to agree to the restriction. To the extent that we do agree to any restrictions on our use/disclosure of your PHI, we will put the agreement in writing and abide by it except in emergency situations. We cannot agree to limit uses/disclosures that are required by law.

To request restrictions, you must make your request in writing to the Privacy Official. The complete address is noted at the end of this document.

In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure, or both; and (3) to whom you want the limits to apply, for example disclosures to your spouse.

To choose how we contact you: You have the right to ask that we send you information at an alternative address or by an alternative means. For example, you can ask that we contact you by phone only at work or by mail at an address other than your home address. We must agree to your request as long as it is reasonably easy for us to do so.

To request restrictions on confidential communications, you must make your request in writing to the Privacy Official. The complete address is noted at the end of this document.

We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

To inspect and request a copy your PHI: Unless your access to your records is restricted for clear and documented treatment reasons, you have a right to see your protected health information upon your written request. Usually, this includes medical and billing records. We will respond to your request within 30 days.

To inspect and copy medical information, you must make your request in writing to the Privacy Official. The complete address is noted at the end of this document.

If we deny your access, we will give you written reasons for the denial. You have the right to have the denial reviewed. Another licensed health care professional chosen by Connecting Point will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the results of the review. If you want copies of your PHI, a charge for copying may be imposed, depending on your circumstances. You have a right to choose what portions of your information you want copied and to have prior information on the cost of copying.

To request amendment of your PHI: If you believe that there is a mistake or missing information in our record of your PHI, you may request, in writing, that we correct or add to the record. We will respond within 60 days of receiving your request.

To request an amendment, your request must be in writing to the Privacy Official. The complete address is noted at the end of this document In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request.

In addition, we may deny the request if we determine that the PHI is:
   (1) Correct and complete;
   (2) Not created by us and/or not part of our records, or;
   (3) Not permitted to be disclosed.

If we deny your request for amendment, you have the right to file a statement of disagreement with us and we may prepare a rebuttal to your statement and will provide you with a copy of any such rebuttal.

The request and denial, along with any statement in response that you provide, will be appended to your PHI. If we approve the request for amendment, we will change the PHI and so inform you, and tell others that need to know about the change in the PHI. Should you have any questions about amendment of your PHI, please contact our Privacy Official.

To find out what disclosures have been made: You have a right to get a list of when, to whom, for what purpose, and what content of your PHI has been released other than instances of disclosure: for treatment, payment, and operations; to you, your family, or pursuant to your written authorization. The list also will not include any disclosures made for national security purposes, to law enforcement officials or correctional facilities, or disclosures made before April 14, 2003. We will respond to your written request for such a list within 60 days of receiving it. Your request can relate to disclosures going as far back as six years. There will be no charge for up to one such list each year. There may be a charge for more frequent requests.

To request a list or accounting of disclosures, you must make your request in writing to the Privacy Official. The complete address is noted at the end of this document.

Requests may also be made in person by presenting at any Connecting Point site. You will be asked to complete a request form.

To receive a paper copy of this notice You have the right to receive a paper copy of this notice. You may ask us to give you a copy of this notice at any time. You may also obtain a copy of this notice at our Website, www.connectingpoint.org. The current notice will be posted at all of our locations in the reception area. The effective date of the notice will be found in the upper right hand corner of the first page of the notice.

HOW TO COMPLAIN ABOUT OUR PRIVACY PRACTICES

If you think we may have violated your privacy rights, or you disagree with a decision we made about access to your PHI, you may file a complaint with Connecting Point by contacting Elaine Tait-Page, at 419-243-6326 or Linda Willie at 419 321-6820.

You may also file a complaint with the Lucas County Mental Health Board, 701 Adams St., Toledo, Ohio or The Alcohol and Drug Addiction Services Board, 701 Adams St. Toledo, Ohio, or a written complaint may be filed at any time with the Secretary of the U.S. Department of Health and Human Services at 200 Independence Avenue SW, Washington DC, or call 1-877-696-6775.

We will take no retaliatory action against you if you make such complaints.

If you have questions about this Notice or any complaints and/ or suggestions about our privacy practices, please contact the Client Right¹s Officers for Connecting Point, Elaine Tait-Page or Linda Willie at 1212 Cherry Street, Toledo Ohio 43608 or call 419-243-6326.

Please submit your information requests in writing to:
   Privacy Official Connecting Point, Inc.
   1212 Cherry Street
   Toledo, Ohio 43608

Effective Date: This Notice is effective on April 14, 2003.