NOTICE OF PRIVACY PRACTICES FOR PROTECTED HEALTH INFORMATION EFFECTIVE DATE: JUNE 30, 2021
Stride understands that we collect private and/or potentially sensitive medical information about you and/or your family. This notice explains how Stride Autism Centers may use and disclose your protected health information to carry out treatment, payment and health care operations and for other purposes that are permitted or required by law. It also describes your rights to access and control your protected health information.
Protected Health Information (“PHI”) is the information we create and obtain in providing our services to you. Such information may include demographic information; information that may identify you and that relates to your past, present or future physical or mental health condition and related health care services; and documentation of your symptoms, behaviors, examination and test results, diagnoses, and treatment. It also includes billing documents for those services.
Stride is required by law to abide by the terms set forth in this notice. Your protected health information will not be used or disclosed without your written authorization, except as described in this notice.
Examples of uses of your health information for treatment purposes:
• A behavior analyst may use your health information to provide you with services
• A behavior analyst may obtain past treatment information and record it in your client file
• During the course of treatment, the behavior analyst may need to consult with other professional or individuals (e.g., physicians, social workers, educators, family members, etc.) involved in your medical care or treatment. They will obtain authorization to share your personal information with these individuals
• Your health information may be shared with other clinical staff at Stride for support in developing your treatment program
Example of use of your health information for payment purposes:
We submit requests for payment to your health insurance company. The health insurance company (and/or third parties / billing agencies helping us obtain payment) requests information from us regarding medical care given. We will provide information to them about you and the services provided.
Example of use of your information for healthcare operations:
We obtain services from insurers, third-party administrative agencies, clinical software providers, and other business associates, including quality assessment/ improvement, outcome evaluation, clinical protocol/guideline development, training, credentialing, medical review, and legal services. When these services are contracted, we may disclose some or all of your health information to our business associates so that they can perform the job we have asked them to do. To protect your health information, however, we require the business associates to appropriately safeguard your information.
Your Health Information Rights
The health and billing records we maintain are the physical property of Stride Autism Centers. The information in it, however, belongs to you. You have the right to:
• Obtain a paper copy of the current version of this Notice of Privacy Practices for Protected Health Information by making a request at our office
• Request a restriction on certain uses and disclosures of your health information by contacting our office. Stride is not required to grant the request, but we will comply with any request if granted
Request a restriction on disclosures of medical information to a health plan that is:
i. for purposes of carrying out payment or health care operations;
ii. is not for purposes of carrying out treatment; and
iii. solely pertains to a health care service for which the provider has been paid out of pocket in full.
Stride must comply with this request.
• Request that you be allowed to inspect and copy your health record and billing record by contacting our office
• Appeal a denial of access to your protected health information, except in certain circumstances
• Request that your health care record be amended to correct incomplete or incorrect information by delivering a request to our office.
We may deny your request if you ask us to amend information that:
o Is accurate and complete as-is;
o Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
o Is not part of the health information kept by or for the office;
o Is not part of the information that you would be permitted to inspect and copy
If your request is denied, you will be informed of the reason for the denial and will have an opportunity to submit a statement of disagreement to be maintained with your record
• Request that communication of your health information be made by alternative means or at an alternative location by delivering the written request to Stride
• Obtain an accounting of disclosures of your health information as required to be maintained by law by delivering a request to Stride. An accounting will not include uses and disclosures of information for treatment, payment, or operations; disclosures or uses made to you or made at your request; uses of disclosures made pursuant to an authorization signed by you; uses or disclosures made in facility directory or to family members or friends relevant to their involvement in your care or in payment for such care; or uses or disclosures to notify family or others responsible for your care of your location, condition, or your death
• Revoke authorizations that you made previously to use or disclose information by delivering a written revocation to Stride, except to the extent information or action has already been taken
• Elect to opt out of receiving further communications from Stride
If you would like to exercise any of the above rights, please contact Stride during regular business hours to schedule an appointment and/or make a request in writing. Stride will inform you of the steps that need to be taken to exercise your rights.
Stride is required to:
• Maintain the privacy of your health information as required by law
• Provide you with this Notice as to our duties and privacy practices as to the information we collect and maintain about you
• Abide by the terms of this Notice
• Notify you if we cannot accommodate a requested restriction or request
• Accommodate your reasonable requests regarding methods to communicate health information with you
We reserve the right to amend, change, or eliminate provisions in our privacy practices and access practices and to enact new provisions regarding the protected health information we maintain. If our information practices change, we will amend our Notice. You are entitled to receive a revised copy of the Notice by calling and requesting a copy or by visiting our office.
To request information or file a complaint
• We cannot, and will not, require you to waive the right to file a complaint as a condition of receiving treatment from Stride Autism Centers.
• We cannot, and will not, retaliate against you for filing a complaint.
If you have questions, would like additional information, or would like to report a problem regarding the handling of your information, you may contact our office at 847-322-9377.
Additionally, if you believe your privacy rights have been violated, you may file a written complaint at our corporate office by emailing the written complaint to firstname.lastname@example.org.
Health Insurance Portability and Accountability Act (HIPAA) Breach Policy
HIPAA’s Breach Notification Rule requires Stride Autism Centers to notify patients when their unsecured protected health information (PHI) is impermissibly used or disclosed—or “breached,”—in a way that compromises the privacy and security of the PHI. Upon discovery that a breach of PHI has occurred, Stride Autism Centers has an obligation to notify the relevant parties “without unreasonable delay” or up to 60 calendar days, following the date of discovery, even if upon discovery Stride was unsure as to whether PHI had been compromised. Stride Autism Centers is required to maintain a log of the compromised PHI and notify the Department of Health and Human Services, within 60 days after the end of the calendar via the HHS website.
Other disclosures and uses
Communication with family
Unless you object in writing, we may disclose health information to a family member, relative, friend, or any other person you identify in the “AUTHORIZATION FOR RELEASE AND EXCHANGE OF INFORMATION” and/or “AUTHORIZATION TO RELEASE CHILD AND/OR THEIR MEDICAL INFORMATION (STRIDE PICK-UP PROCEDURES)” forms, provided such health information is relevant to the person’s involvement in your care and/or in payment for such care, as authorized by you in the above forms. We may also disclose such information in case of emergency, as determined by Stride.
Pursuant to the foregoing, and unless you object in writing, we may use or disclose your protected health information to notify or assist in notifying a family member, personal representative, or other person responsible for your care about your location, your general condition, or your death.
We may disclose information to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your protected health information.
We may use and disclose your protected health information to assist in disaster relief efforts.
Organ procurement organizations
Consistent with applicable law, we may disclose your protected health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.
Food and drug administration (FDA)
We may disclose to the FDA your protected health information relating to adverse events with respect to food, supplements, products and product defects, or post-marketing surveillance information to enable product recalls, repairs or replacements.
We may release protected health information about you for programs that provide benefits for work related injuries or illness to the extent necessary to comply with laws relating to Worker’s Compensation.
Public health / communicable disease tracing
As authorized by law, we may disclose your protected health information to public health or legal authorities charged with preventing or controlling disease, injury, or disability; to report reactions to medications or problems with products; to notify people of recalls; and/or to notify a person who may have been exposed to a disease or who is at risk for contracting or spreading a disease.
Abuse and neglect
We may disclose your protected health information to public authorities as required by law to report abuse or neglect.
We may release health information about you to your employer if we provide health care services to you at the request of your employer, and if the health care services are provided either to conduct an evaluation relating to medical surveillance of the workplace, or to evaluate whether you have a work-related illness or injury. In such circumstances, we will give you written notice of such release of information to your employer. Any other disclosures to your employer will be made only if you execute a specific authorization for the release of that information to your employer.
If you are an inmate of a correctional institution, we may disclose to the institution or its agents the protected health information necessary for your health and the health and safety of other individuals.
We may disclose your protected health information for law enforcement purposes as required by law, such as when required by a court order, or in cases involving felony prosecution, or to the extent an individual is in the custody of law enforcement.
Federal law allows us to release your protected health information to appropriate health oversight agencies for health oversight activities.
We may disclose your protected health information in the course of any judicial or administrative proceeding as allowed or required by law, with your authorization, or as directed by a proper court order.
To avert a serious threat to health or safety, we may disclose your protected health information consistent with applicable law to prevent or lessen a serious, imminent threat to the health or safety of a person or the public.
For specialized governmental functions
We may disclose your protected health information for specialize government function as authorized by law such as to Armed Forces personnel / military command authorities, for national security purposes, or to public assistance program personnel.
Coroners, medical examiners and funeral directors
We may release health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release health information about clients to funeral directors as necessary for them to carry out their duties.
Other than those identified in this notice, additional uses and disclosures will be made only as otherwise required by law or with your written authorization, which you may revoke by the means previously provided under this Notice.