Cornerstone Psychological Services, PA

NOTICE OF PRIVACY PRACTICES

Effective April 14, 2003

 

THIS NOTICE DESCRIBES HOW WE MAINTAIN MEDICAL INFORMATION ABOUT YOU, HOW IT MAY BE USED AND DISCLOSED, AND HOW YOU MAY GAIN ACCESS TO THIS INFORMATION.  PLEASE REVIEW THIS INFORMATION CAREFULLY.

Cornerstone Psychological Services (CPS) provides several types of services. In order to provide you with services, CPS must collect information about you. The information collected about you is stored in a Medical Record. Cornerstone Psychological Services understands that the information collected about you and your health is private and confidential. We are required by state and federal law to protect this information.  At times, state and federal laws contradict each other regarding your right to privacy.  If the laws contradict each other, we are required to follow the law that is most restrictive, that is, most protective of your privacy.

Much of the information that we collect about you or your health status has the potential to identify you as an individual.  That information is referred to as “protected health information” (PHI). Please be aware that we maintain the written PHI in our Medical Record.  We also maintain some PHI in electronic records (computers).  We may use or disclose your PHI in electronic or written forms, or we may do so verbally. Certain conditions must exist for us to use or disclose your PHI and those conditions are discussed later in this booklet.

 

UNDERSTANDING YOUR MEDICAL RECORD

Each time you visit, receive a service from, or speak to a representative of CPS, a record of that contact may be maintained.  The information is collected and maintained in your Medical Record. Your Medical Record contains information about your mental health history, your physical health (as appropriate), current symptoms, assessments, test results (if appropriate), diagnosis, treatment, medications, legal history (as appropriate), demographic information, financial information, family history (as appropriate), your progress, and a plan for your current and future treatment.  You may provide us some of the information contained in your Medical Record, while others involved in your care may provide additional information. The information contained in your Medical Record serves the following purposes:

  • It is the basis for the planning of your care and treatment.
  • It is a way for the various professionals involved in your care to communicate.
  • It is a legal document describing the care that you have received.
  • It is a means by which you or an insurance payer can verify that you actually received the services that were billed.
  • It is a source of information for state health officials who are charged with improving health care across the state.
  • It is a tool to assess the appropriateness and quality of care that you received.
  • It is a tool to improve the quality of health care and achieve better treatment  outcomes.

Understanding what information is contained in your Medical Record and how it is used helps you to:

  • Ensure the accuracy and completeness of the information.
  • Understand who, what, where, why, and how others may have access to your health information.
  • Make better informed decisions about authorizing disclosure to others.
  • Better understand your health information rights that are detailed below.

If you request to view the clinical information contained in your Medical Record, your therapist or a clinical professional will be available to you to help explain the information so that you can understand it. If you request to view financial or billing related information, CPS will make available someone from our financial office to you to help you understand the information.

Cornerstone Psychological Services is required to make a copy of this Notice of Privacy Practices available to you.  This Notice of Privacy Practices tells you how CPS may use or disclose the information we collect and keep about you. Not all situations are described. Cornerstone Psychological Services is required to follow the terms of the Notice of Privacy Practices currently in effect. However, we reserve the right to revise the Notice of Privacy Practices at any time. If we make revisions to this document, the changes will be posted in our office. Copies of the Notice that is in effect are always available from our receptionist.  We will also retain copies of outdated versions of the Notice of Privacy Practices for seven years.

 

Uses and Disclosures With Neither Consent nor Authorization

Cornerstone Psychological Services will use and disclose only the minimum information necessary to meet the following requirements.  We may uses or disclose PHI without your consent or authorization in the following circumstances:

  • For Treatment.   CPS may use or disclose information with health care providers who are involved in your health care. For example, if you are referred to us by a national employee assistance program, we may disclose PHI to ensure that your treatment is adequately planned and carried out. We may also disclose PHI to another physician if that physician referred you to us for services.
     
  • For Payment. Federal law allows CPS to use or disclose information to apply for payment for the health care services that you receive.  However, we must follow North Carolina law which requires that you consent to such an action.  We will always ask you to sign a consent form for us to seek payment for the health care services that we provide to you.
     
  • For Health Care Operations. CPS may use or disclose information in order to manage its programs and activities.  For example, CPS may use PHI to review the quality of the services that you receive, conduct utilization management activities, or seek approval for your treatment. 
     
  • Appointments and Other Health Information. CPS may send you or call you with reminders for care or checkups.  We may also send you information about services that may be of interest to you. If we do this, we will send the information only to the address that you specify and in a manner that does not identify us as CPS. Phone calls will only be made to a number that you specify on the phone consent form and you must inform us if we can leave a message on a recording device.
     
  • For Health Oversight Activities. CPS may use or disclose PHI to persons inspecting or investigating health care providers.  For example, the North Carolina Psychology board has the power to subpoena relevant records if a therapist is the focus of an inquiry. 
     
  • As Required by Law and for Law Enforcement. CPS will use and disclose information when required or permitted by federal or state law or by a court order. PHI regarding substance abuse information can only be disclosed with your authorization or by a court order.
     
  • For Abuse Reports and Investigations.   CPS will use and disclose information required by law to report any suspicion of abuse, neglect, or exploitation to the Department of Social Services (DSS). CPS is required by North Carolina law to cooperate with DSS investigations into possible abuse, neglect, or exploitation allegations.
     
  • For Government Programs. CPS may use and disclose information for public benefits under other government programs. For example, CPS may disclose information for the determination of Supplemental Security Income (SSI) benefits if requested and authorized by you to do so. If you file a worker’s compensation claim, CPS is required by law to provide your PHI relevant to the claim to your employer and the North Carolina Industrial Commission. 
     
  • To Avoid Harm. CPS may disclose PHI to law enforcement in order to try to avoid a serious threat to the health and safety of a person or the public.
     
  • For Research. CPS may use and disclose information for studies and to develop reports. These reports do not specifically identify you as an individual.
     
  • Disclosures to Family, Friends, and Others. North Carolina law requires that you grant authorization before we can share information with others, except in very limited circumstances.  We retain the right to use and disclose PHI in those limited circumstances. We also retain the right to use and disclose PHI that is necessary for us to conduct treatment, payment, or other health care operations (TPO). We will always follow the laws that are most protective of your privacy.
     
  • In Emergency Situations. CPS may use or disclose information as necessary to meet the demands of emergency situations, such as medical, psychiatric, or behavioral conditions that require immediate attention.

It is important for you to remember that we will use and disclose only the minimum amount of PHI necessary to comply with the above requirements.

 

Other Uses and Disclosures Require Your Written Authorization

For all other situations, CPS must ask for your written authorization before using or disclosing information.  You may authorize us to disclose information to anyone that you wish. We will disclose only that information contained in your Medical Record that was created by us.  For example, if you had hospital records sent to us, we will not release those reports.  Instead, you must make that request directly to the agency, individual, or others that created those records.  You may cancel an authorization at any time in writing. CPS is not responsible for any uses or disclosures already made before you cancel an authorization.

  • Other Laws Protect PHI. Many other laws govern the protection of your information. North Carolina General Statutes § 122-C, Federal Law 42 CFR Part 2 and others are among those that require protection of information. An example of how the federal law protects your PHI is that CPS may only disclose information about chemical dependency with your authorization or by court order.  North Carolina law places limits on the amount of time that an authorization to disclose may cover (up to one year) that Federal laws do not.

Please be aware that CPS staff are trained in the allowable uses and disclosures of PHI. If a question ever exists as to whether PHI can be used with or without your authorization, the staff of CPS will consult an outside opinion from legal and ethical experts. 

 

Your PHI Privacy Rights

  • Right to See and Receive Copies of Your Records. You have the right to inspect and to receive a copy of your health care information that we maintain in certain groups of records.  If you would like to inspect or receive a copy of your health care information, you must make a request. We will ask you to sign a request form that specifically identifies the information you wish to review.  We must act on your request no later than 10 business days after receipt of the request.  We may deny your request for access in certain circumstances. If it is determined by a clinical professional that the information you requested could prove detrimental or harmful to you or someone else, we will deny access to only that specific information. We may choose to have specific information summarized and present you with that summary information. This is especially true if the documents in question are lengthy and contain information not pertaining to your specific request.  In any event, if we deny any part of your request, we will explain our reason for doing so in writing.  We will also inform you in writing if you have the the right to have our decision reviewed by another person and how to proceed with that request.  If your request is approved, you may view certain information contained in your Medical Record.  We cannot provide copies of any information that was sent to us by another source.  For example, if we receive information from a hospital about your stay there, we will not release a copy of that information to you.  However, you may request a copy of it directly from the hospital. Other limitations may be placed on your access to specific information contained in your Medical Record.
  • Right to Request to Correct or Update Your Records.  You may ask CPS to change or add missing information to your records if you think there is a mistake.  You must make the request in writing and provide a reason for your request. CPS cannot honor requests to change records provided to us by other sources, nor can we change some records that we generate.  We will place a statement in the record that indicates if you dispute certain information and will send that statement to anyone who has received a copy of the original information.  We will also send your statement along with any future disclosure.
  • Right to Get a List of Disclosures. You have the right to ask CPS for a list of disclosures made after April 14, 2003.  You must make the request in writing.  This list will include to whom the information was disclosed, the date it was disclosed, and what specific information was included.  This list will not include the times that information was disclosed for treatment, payment, or other health care operations (TPO).
  • Right to Request Limits on Uses or Disclosures of PHI. You have the right to ask CPS to limit how your information is used or disclosed.  You must make the request in writing and tell us what information you want to limit and to whom you want the limits to apply.  CPS is not required to agree to the restriction.  We cannot honor requests that limit our ability to engage in TPO. You can request that restrictions be terminated in writing or verbally. If you make a verbal request, we will ask that you verify it in writing during your next visit.
  • Right to Revoke Permission. If you sign an authorization to use or disclose information, you can cancel that authorization at any time.  You must make the request in writing.  This revocation will not affect information that has already been shared.
  • Right to Choose How We Communicate With You. You have the right to ask that CPS share information with you in a certain way or in a certain place. For example, you may ask CPS to send information to an address other than your home. You may also ask that we not leave messages on a home answering machine.  You must make these requests in writing.  You do not have to explain your reason for the requests.
  • Right to File a Complaint. You have the right to file a complaint if you do not agree with how CPS has used or disclosed your information. How to file a complaint is explained in the last section of this booklet.
  • Right to get a Copy of This Notice. You have a right to ask for a paper copy of the Notice of Privacy Practices that is in effect at any time.  If we revise our Notice of Privacy Practices, we will retain copies of the older versions for seven years. You may also request a copy of the older versions.

Please remember that we may deny your request to look at, copy, or change your records.  If we deny your request, we will send you a letter explaining why your request was denied and how you may ask for a review of our decision. You will also receive information on how to file a complaint with CPS or with the U.S. Department of Health and Human Services, Office of Civil Rights.

 

Who to Contact if You Have Questions, Complaints, or Want to Exercise Your Privacy Rights

If you have questions about this notice, feel free to ask to speak with your therapist or CPS Privacy Officer. They may be reached at 336.540.9400. If you wish to exercise your Privacy Rights as listed above please ask the receptionist for the forms you need. 

How to File a Complaint or Report a Problem

You may contact any of the people listed below if you want to file a complaint or report a problem with how CPS used or disclosed information about you. Your benefits will not be affected by any complaints that you make.  CPS cannot retaliate against you for filing a complaint, cooperating in an investigation, or refusing to agree to something that you believe to be unlawful. 

To file a complaint or report a problem with CPS, please contact the Compliance Officer at 336.540.9400. You may send the complaint or report in writing to:

Compliance Officer
Cornerstone Psychological Services
2711A Pinedale Road
Greensboro, NC 27408

To file a complaint or report a problem to the U. S. Department of

Health and Human Services, please contact:
U.S. Department of Health and Human Services, Office of Civil Rights
Medical Privacy Complaint Division
200 Independence Avenue, SW
Washington, DC 20201
Phone: 866.627.7748