Notice of Policies & Practices Regarding Protection & Privacy of Protected Health Information
The following describes how your protected health information (PHI) may be used and disclosed and how you can access your own information. Please review it carefully. Thomas Miller Coaching (TMC) is committed to Health Information Privacy.
I. Uses and Disclosures:
Thomas Miller & Thomas Miller Coaching (TMC) is permitted to use or disclose your protected health information (PHI) as part of your decision to receive coaching services. To help clarify these terms, here are some definitions:
Use applies only to activities within TMC that would involve sharing or examining information that identifies you.
Disclosure applies to activities outside of TMC such as releasing, transferring, or providing access to information about you to other parties.
PHI refers to information in your client record that could identify you.Coaching is when Thomas Miller & TMC provides, coordinates, or manages your coaching services.
Payment is when Thomas Miller & TMC obtains reimbursement for rendering your coaching services.
Coaching Operations are activities that relate to business related matters such as scheduling and all administrative services.
Authorization is your written permission to disclose confidential health information.
II. Other Uses and Disclosures Requiring Authorization:
Thomas Miller & TMC is permitted to use or disclose PHI for purposes outside of coaching, payment, or coaching operations with your written authorization. You may revoke authorizations of PHI in writing at any time. You may not revoke authorization to the extent that Thomas Miller & TMC has relied on your authorization already to provide specified information.
III. Uses and Disclosures without Authorization:
Thomas Miller & TMC is permitted and in some cases required to use or disclose your PHI without your consent in the following circumstances:
Child Abuse If Thomas Miller & TMC knows or has reasonable cause to suspect that a child has been/is being abused or neglected, TMC is required by law to report the matter to the appropriate authorities.
Adult and Domestic Abuse If Thomas Miller & TMC suspects that an adult has been abused, neglected, or exploited and have reasonable cause to suspect that the adult in question is incapacitated or dependent. I am required by law to report the matter to the appropriate authorities.
Health Oversight Activities – Thomas Miller & TMC is permitted to disclose PHI to the Board of Examiners of Psychotherapists, or one of its designated representatives, pursuant to standards or regulations for regulation, accreditation, licensure, or certification.
Judicial and Administrative Proceedings – If you are involved in a court proceeding and a request is made for information about your coaching services, such information is privileged under state law. Thomas Miller & TMC will not release information without written authorization from you or your legally appointed representative. However, if there is a court order then Thomas Miller & TMC will be required to follow the guidelines of the court order. If this is the case then you will be informed in advance.
Serious Threat to Health or Safety
If Thomas Miller & TMC deems that a situation poses a direct threat of imminent or serious harm to the health or safety of any individual, including yourself, we will disclose necessary PHI to the appropriate authorities.
Worker’s Compensation (most likely not applicable)
Thomas Miller & TMC may disclose PHI as authorized by and to the extent necessary to comply with laws relating to worker’s compensation or other similar programs, established by law, that provide benefits for work-related injuries or illness without regard to fault.
IV. Client’s Rights and Thomas Miller’s Duties:
Client’s Rights with regard to PHI:
Right to Request Restrictions – You have the right to request restrictions on certain uses and disclosures of protected health information. However, Thomas Miller & TMC is not required to agree to a restriction that you request.
Right to Receive Confidential Communications by Alternative Means and at Alternative Locations – You have the right to request and receive confidential communications of PHI by alternative means and at alternative locations. At your request, Thomas Miller & TMC will send bills or other PHI to an address other than your home.
Right to Inspect and Copy – You have the right to inspect or obtain a copy (or both) of your PHI maintained by Thomas Miller & TMC for as long as the PHI is maintained by Thomas Miller & TMC. Thomas Miller & TMC is permitted to deny or limit your access under certain circumstances, but in some cases you could have such a decision reviewed. On your request, Thomas Miller & TMC will discuss with you the details of a request and denial process.
Right to Amend – You have the right to request an amendment of your PHI for as long as the PHI is maintained in the record. Thomas Miller & TMC is permitted to deny such a request. On your request, Thomas Miller & TMC will discuss with you the details of the amendment process.
Right to an Accounting – You generally have the right to receive an accounting of disclosures of your PHI. At your request, Thomas Miller & TMC will discuss with you the details of the accounting process.
Thomas Miller & TMC Duties with regard to PHI:
Thomas Miller & TMC is required by law to maintain the privacy of PHI and to provide you with a notice of Thomas Miller & TMC legal duties and privacy practices with respect to PHI.
Thomas Miller & TMC reserves the right to change the privacy policies and practices described in this notice. Unless Thomas Miller & TMC notifies you of such changes, Thomas Miller & TMC is required to abide by the terms currently in effect.
If TMC revises the policies and procedures, TMC will provide you with a paper copy of the revised notice on your next visit following the change or by mail if requested.
V. Questions/Complaints:
If you have questions about this notice, disagree with a decision that Thomas Miller & TMC makes with regard to your access to your records, or have other concerns about your privacy rights, please contact Thomas Miller at Thomasm@Thomasmillercoaching.com. If you believe that your privacy rights have been violated and wish to file a complaint with Thomas Miller & TMC, you may send your written complaint to Thomas Miller Coaching 50 Water St. Ste. 246 Newburyport, MA 01950. You may also send a written complaint to the Secretary of the U.S. Department of Health and Human Services. That address is: Office of Civil Rights, U.S. Department of Health and Human Services, Government Center, J.F. Kennedy Federal Building — Room 1875, Boston, MA 02203. Voice Phone (617) 565-1340, Fax (617) 565-3809, TDD (617) 565-1343.
VI. Effective Date, Restrictions, and Changes to Privacy Policy:
This notice will go into effect on 10/1/18. Thomas Miller & TMC reserves the right to change the terms of this notice and to make the new notice effective for all PHI that Thomas Miller & TMC maintains.
