Notice of Privacy Practices

Developmental Pathways, Inc.

This is a summary of how we may use and disclose your protected health information and your rights and choices when it comes to your information. We will explain these in more detail on the following pages.

We may use and disclose your information as we:

• Treat you.
• Bill for services.
• Run our organization.
• Do research.
• Comply with the law.
• Respond to organ and tissue donation requests.
• Work with a medical examiner or funeral director.
• Address workers’ compensation, law enforcement, or other government requests.
• Respond to lawsuits and legal actions.

You have some choices about how we use and share information as we:

• Communicate with you.
• Tell family and friends about your condition.
• Provide disaster relief.
• Market our services.
• Raise funds.

You have the right to:

• Get a copy of your paper or electronic protected health information.
• Correct your protected health information.
• Ask us to limit the information we share, in some cases.
• Get a list of those with whom we’ve shared your information.
• Request confidential communication.
• Get a copy of this privacy notice.
• Choose someone to act for you.
• File a complaint if you believe we have violated your privacy rights.

Developmental Pathways (DPor We) respects your privacy. We are also legally required to maintain the privacy of your protected health information (PHI) under the Health Insurance Portability and Accountability Act (HIPAA).

As part of our commitment and legal compliance, we are providing you with this Notice of Privacy Practices (Notice). This Notice describes:

• Our legal duties and privacy practices regarding your PHI, including our duty to notify you following a data breach of your unsecured PHI.
• Our permitted uses and disclosures of your PHI.
• Your rights regarding your PHI.

If you have any questions about this Notice, please contact Sarah Jacobson at s.jacobson@dpcolo.org.

Your PHI:

• Is health information about you:
  • from which someone may identify you; and
  • which we keep or transmit in electronic, oral, or written form.
• Includes information such as your:
  • name;
  • contact information;
  • past, present, or future physical or mental health or medical conditions;
  • payment for health care products or services

We create a record of the care and health services you receive, to provide your care, and to comply with certain legal requirements. This Notice applies to all the PHI that we generate.

We follow and our employees and other workforce members follow the duties and privacy practices that this Notice describes and any changes once they take effect.

We can change the terms of this Notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website.

We will promptly notify you if a data breach occurs that may have compromised the privacy or security of your PHI. We will notify you within the legally required time frame if we discover such a breach. Most of the time, we will notify you in writing, by first-class mail, or we may email you if you have provided us with your current email address and you have previously agreed to receive such notices electronically. In some circumstances, our business associates, which are described in more detail below, may provide the notification.

The law permits or requires us to use or disclose your PHI for various reasons, which we explain in this Notice. We have included some illustrative examples, but we have not listed every permissible use or disclosure. When using or disclosing PHI or requesting your PHI from another source, we will make reasonable efforts to limit our use, disclosure, or request about your PHI to the minimum we need to accomplish our intended purpose.

• We may use or disclose your PHI and share it with other professionals who are treating you, including doctors, nurses, technicians, medical students, or other hospital personnel involved in your care. For example, we might disclose information about your overall health condition with physicians who are treating you for a specific injury or condition.
• We may use and disclose your PHI to bill and get payment from health plans or others. For example, we share your PHI with your health insurance plan so it will pay for the services you receive.
• Health Care Operations.We may use and disclose your PHI to run our practice and improve your care. For example, we may use your PHI to manage the services you receive or to monitor the quality of our health care services.

We may share your information in other ways, usually for public health or research purposes or to contribute to the public good. For more information on permitted uses and disclosures, see www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. For example, these other uses and disclosures may involve:

• Legal Compliance.For example, we will share your PHI if the Department of Health and Human Services requires it when investigating our compliance with privacy laws.
• Public Health and Safety Activities.For example, we may share your PHI to:
  • report injuries, births, and deaths;
  • prevent disease;
  • report adverse reactions to medications or medical device product defects;
  • report suspected child neglect or abuse or domestic violence; or
  • avert a serious threat to public health or safety.
• Responding to Legal Actions.For example, we may share your PHI to respond to:
  • a court or administrative order or subpoena;
  • discovery request; or
  • other lawful process.
• Medical Examiners or Funeral Directors.For example, we may share PHI with coroners, medical examiners, or funeral directors when an individual dies.
• Organ or Tissue Donation.For example, we may share your PHI to arrange an authorized organ or tissue donation from you or a transplant for you.
• Workers’ Compensation, Law Enforcement, or Other Government Requests. For example, we may use and disclose your PHI for:
  • workers’ compensation claims;
  • health oversight activities by federal or state agencies;
  • law enforcement purposes or with a law enforcement official; or
  • specialized government functions, such as military and veterans’ activities, national security and intelligence, presidential protective services, or medical suitability.

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, please contact Sarah Jacobson at s.jacobson@dpcolo.org and we will make reasonable efforts to follow your instructions.

You have both the right and choice to tell us whether to:

• Share information, such as your PHI, general condition, or location, with your family, close friends, or others involved in your care.
• Share information in a disaster relief situation, such as to a relief organization to assist with locating or notifying your family, close friends, or others involved in your care.

We may share your information if we believe it is in your best interest, according to our best judgment, and:

• If you are unable to tell us your preference, for example, if you are unconscious.
• When needed to lessen a serious and imminent threat to health or safety.

In these cases we will only share your information if you give us written permission:

• Most sharing of a mental health care professional’s notes (psychotherapy notes) from a private counseling session or a group, joint, or family counseling session.
• Marketing our services.
• Other uses and disclosures not described in this Notice.

You may revoke your authorization at any time. Please let us know in writing if you’d like to do so.

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

You have the right to:

• Inspect and Obtain a Copy of Your PHI.You have the right to see or obtain an electronic or paper copy of the PHI that we maintain about you (right to request access). Ask us how to do this.
  • you may request that we provide a copy of your PHI to a family member, another person, or a designated entity. We require that you submit these requests in writing with your signature, and clearly identify the designated person and where to send the PHI;
• Make Corrections or Amendments.You may ask us to correct or amend PHI that we maintain about you that you think is incomplete, incorrect or inaccurate.Ask us how to do this.
  • We may say “no” to your request, but we’ll tell you why in writing within 60 days.
• Ask us to Limit what We use or share.You have the right to ask us to limit what we use or share about your PHI (right to request restrictions). You can contact us and request us not to use or share certain PHI for treatment, payment, or operations, or with certain persons involved in your care.
  • We require that you submit this request in writing. For these requests: we are not required to agree; and we may say “no” if it would affect your care.
• Get a List of Those with whom We’ve Shared Information.You have the right to request an accounting of certain PHI disclosures that we have made. For these requests:
  • we will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make); and
  • we’ll provide one accounting a year for free, but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
• Choose Someone to Act for You.If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your PHI.
  • We will make sure the person has this authority and can act for you before we take any action.
• Request Confidential Communications.You have the right to ask that We communicate with you about health matters in a certain way or at a certain location; for example: you can ask us to contact you at your home or office phone number; or send email or traditional mail to a certain address. For these requests:
  • you must specify how or where you wish to be contacted; and
  • we will accommodate reasonable requests, and must say “yes” if you tell us you would be in danger if we do not.
• File a Complaint if you Feel your Rights are Violated. You have the right to file a complaint if you feel we have violated your rights. We will not retaliate against you for filing a complaint. You may file a complaint either:
  • directly with us by contacting please contact Sarah Jacobson at s.jacobson@dpcolo.org in writing; or,
  • with the Office for Civil Rights at the U.S. Department of Health and Human Servicesby sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting: hhs.gov/ocr/privacy/hipaa/complaints/