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Draft — this page is pending review by legal counsel and may change.
Legal

Notice of privacy practices

How medical and substance use treatment information about you may be used and disclosed, and how you can get access to it. Please review it carefully.

Effective [effective date]. This notice applies to the P2H programs (P2H Recovery LLC, P2H Wellness, LLC and P2H CONNECT LLC). We are required by law to keep your health information private, to give you this notice of our legal duties and privacy practices, to follow the notice currently in effect, and to notify you if a breach affects your unsecured information.

Substance use treatment records have extra protection

Records of substance use disorder treatment are protected by a federal law, 42 CFR Part 2, in addition to HIPAA. In general, we cannot tell anyone outside the program that you attend it, or disclose information identifying you as having a substance use disorder, unless you give written consent, a court orders it under Part 2's specific rules, or a narrow exception applies.

Part 2 records, or testimony about their content, cannot be used or disclosed in a civil, criminal, administrative, or legislative proceeding against you without your written consent or a court order that meets Part 2's requirements.

How we may use and disclose your information

  • With your consent. You can sign one consent for future uses and disclosures for treatment, payment, and health care operations. Once you have, information may be shared with other providers and your health plan for those purposes, and they may redisclose it as HIPAA allows.
  • Within the program. Staff who need information to treat you, coordinate care, or bill for services may use it.
  • Medical emergencies. To medical personnel to the extent needed to treat a bona fide medical emergency.
  • Reporting abuse or neglect. Suspected child abuse or neglect as required by state law.
  • Crimes on our premises or against staff. Limited information to law enforcement.
  • Audits and evaluations. To qualified auditors and evaluators, including payers and accreditors, under Part 2 rules.
  • Research. Only as Part 2 and HIPAA allow, with protections for your identity.
  • Public health. De-identified information as the law allows.

We will not sell your information, use it for marketing, or share psychotherapy notes without your written authorization.

Fundraising

If we ever contact you to raise funds, you have the right to opt out of those communications.

Your rights

  • Get a copy of your records, in paper or electronic form, usually within 30 days.
  • Ask us to correct information you believe is wrong or incomplete.
  • Ask for confidential communications, such as a different phone number or address.
  • Ask us to limit what we use or share. If you pay for a service in full out of pocket, you can ask us not to share it with your health plan, and we will agree unless the law requires otherwise.
  • Get a list of disclosures we have made, as the law allows.
  • Revoke a consent in writing at any time, except for actions already taken in reliance on it.
  • Get a paper copy of this notice at any time.
  • Choose someone to act for you, such as a health care power of attorney.

Complaints

If you believe your privacy rights have been violated, you can complain to us using the contact below, or to the U.S. Department of Health and Human Services Office for Civil Rights at hhs.gov/ocr or 1-800-368-1019. You may also report a suspected Part 2 violation to the same office. We will not retaliate against you for filing a complaint.

Changes to this notice

We can change this notice, and the changes will apply to all information we have about you. The new notice will be posted here and available at our offices.

Contact

P2H Privacy Office
[mailing address — to be added]
Phone: (410) 555-0142