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Notice of Privacy Practice

Castlewood Treatment Center Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

The terms of this Notice apply to Castlewood Treatment Center. This Notice is intended to inform you about our practices related to your protected health information (PHI). It explains how Castlewood Treatment Center may use and disclose your PHI, our obligations related to the use and disclosure of your PHI, and your rights related to any PHI that we have about you.

Castlewood Treatment Center is required to maintain the privacy of your health information; provide you with a notice as to our legal duties and privacy practices with respect to information we collect and maintain about you; notify you following a breach of unsecured protected health information; and abide by the terms of this Notice.

Below, we have listed some of the reasons why we might use or disclose your PHI with some examples. Not every potential use or disclosure is discussed, but all of the ways that we are allowed to use and disclose information fall into one of the categories below.

Use and Disclosure of Medical Information:

  • For Treatment: To provide you with medical treatment or services, we may need to use or disclose information about you to personnel involved in your treatment. For example our physician may need to review your medical history or consult with another healthcare provider before providing treatment.
  • For Payment: We may use and disclose your PHI to bill and receive payment for treatment you receive from us. For example, we may share medical information about you with your insurance company to determine your insurance coverage or to receive payment from your insurer for services provided by Castlewood Treatment Center.
  • For Health Care Operations: We can use and disclose PHI about you for our operations. These uses and disclosures are necessary to run our organization and make sure our clients receive quality care. For example, we may use your PHI to evaluate our staff’s performance in caring for you or to evaluate and improve our programs.

Uses and Disclosures of Medical Information that Do Not Require Your Authorization

We can use or disclose PHI about you without your authorization when there is an emergency, when we are required by law to treat you, or when we are required by law to use or disclose certain information. We may use or disclose your PHI without your authorization in any of the following circumstances:

  • When it is required by federal, state, or other law
  • When it is needed for public health activities
  • When disclosing information for the purpose of health oversight activities, such as audits or inspections.
  • When disclosing information for judicial and administrative proceedings, such as an order of court or subpoena.
  • When disclosing information for law enforcement purposes
  • When we believe in good faith that the disclosure is necessary to avert a serious health or safety threat.

Use of Psychotherapy Notes

Castlewood Treatment Center must obtain an authorization from you for any use or disclosure of psychotherapy notes pertaining to your sessions except to carry out the following treatment, payment, or health care operations:

  • Your therapist, who wrote the notes, may use them for treatment.
  • Castlewood Treatment Center may use or disclose what is contained in your psychotherapy notes in our own training programs in which staff or students learn, under supervision, to practice or improve their skills in individual, group, joint, or family counseling.
  • Castlewood Treatment Center may use psychotherapy notes pertaining to your sessions to defend itself in a legal action or other proceeding brought against our organization by you.
  • Castlewood Treatment Center may use or disclose psychotherapy notes without written authorization when legally required by law, to investigate Castlewood Treatment Center’s compliance, for use of oversight of the therapist who wrote them, to a coroner or medical examiner, or to avert serious threats to health or safety. 

Planned Uses or Disclosures:

We may use or disclose your health information for any of the purposes described in this section unless you affirmatively object to or otherwise restrict a particular release.

  • We may use or disclose your health information to provide you with information about or recommendations of possible treatment options or alternatives that may interest you.
  • We may share information about you with family members and friends who are involved in your care or payment for your care. Whenever possible, we will allow you to tell us who you would like to be involved in your care. However, in emergencies or other situations in which you are unable to tell us who to share information with, we will use our best judgment and share only information that others need to know. We may also share information about you with a public or private agency during a disaster so the agency can help contact your family or friends about your location and tell them how you are doing.
  • We may use or disclose your health information to pre-certify you for treatments you may need to seek at other facilities while you are in treatment at Castlewood Treatment Center.

 Other Uses or Disclosures:

Castlewood Treatment Center holds your protected health information in strictest confidence. We do not give out, exchange, barter, rent, sell, lend, or disseminate any information about applicants who apply for or clients who actually receive our services that is considered patient confidential, is restricted by law, or has been specifically restricted by a patient/client in a signed HIPAA consent form. We will not contact you with appointment reminders or solicit you in fundraising efforts. Written authorization from you is required for most marketing purposes.  There are services provided in our facility through contacts with business associates (Business Associates). Examples include pharmacy services, record storage services, and shredding services. When these services are contracted, we may disclose your PHI to our Business Associate so that they can perform the job we have asked them to do.  So that your health information is protected, however, we require the Business Associate to appropriately safeguard your information.

For all other types of uses and disclosures not described in this notice, Castlewood Treatment Center will use or disclose clinical information only with a written authorization signed by you that states who may receive the information, what information is to be shared, the purpose of the use or disclosure and an expiration for the authorization. If you provide us written authorization to use or disclose your protected health information, you can change your mind or revoke your authorization in writing at any time. If you revoke your authorization, we will no longer use or disclose the information for the reasons stated in your authorization. We will not, however, be able to take back any disclosures that we made prior to your revocation, and we must retain protected health information that indicates the services we have provided to you.

Your Rights with Respect to Health Information

  • Right to obtain a paper copy of this Notice of Privacy Practices upon request
    • Right to Inspect and Copy Your Health Information: You have the right to inspect and copy your health information with certain exceptions. We ask that you make such a request in writing, sign it, date it, and send it to the Compliance Officer at the address listed below. We can provide you with a form to assist you with this written request; you may also download it from our website. If you request copies of information, we may charge a reasonable fee to cover copying, mailing, and other costs and supplies associated with your request.
    • Right to Request Information in Certain Form and Location: You have the right to request health information in a certain form or at a specific location. For instance, you can request that we not fax or email you. You can request that we not contact you at work or that we only send PHI to a Post Office Box. You may request an electronic copy of your health record if maintained in that format.  We ask that you make such a request in writing, sign it, date it, and send it to the Compliance Officer at the address listed below. We can provide you with a form to assist you with this written request; you may also download it from our website. You do not need to tell us the reason for your request. Your request must specify how or where you wish to be contacted. You will also be required to tell us what address to send bills to for payment. We will accept all reasonable requests. However, if we are unable to contact you using the requested ways or locations, we may contact you using any information we have.
    • Right to Request Amendment to Your Health Information: You have a right to request that your health information be amended if you believe that it is incorrect or incomplete. You must provide the reason that you want the amendment added to your health information. This request must be in writing, signed, and dated. We can provide you with a form to assist you with this written request; you may also download it from our website. Please send your request to the Compliance Coordinator at the address below.
    • Right to Request Restrictions: You have the right to ask that we limit our use or sharing of information about you for treatment, payment, or health care operations. You also have the right to ask us to limit the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not share information about a surgery you had. We reserve the right to accept or reject most requests. Generally, we will not accept restrictions for treatment, payment, or health care operations. We will notify you if we do not agree to your request. If we do agree, our agreement must be in writing, and we will comply with the restriction unless the information is needed to provide emergency treatment for you. You do, however, have the right to restrict certain disclosures of protected health information to a health plan if you pay for health care items or Castlewood Treatment Center’s services out of pocket in full; we must comply with such a request. If we agree to restrict our use or sharing of your information we are allowed to end the restriction if we tell you, unless you have paid for items or services in full out of pocket. If we end the restriction, it will only affect medical information that was created or received after we notify you.

Your request to restrict the use and sharing of your medical information must be in writing, signed, and dated. We can provide you with a form to assist you with this written request; you may also download it from our website. Please send it to the Compliance Coordinator at the address below. Your request must tell us: 1) what information you want to limit, 2) whether you want to limit our use, disclosure, or both, and 3) to whom you want the limits to apply.

  • Right to Receive an Accounting of Disclosures: You have the right to request a list of when your medical information was shared without your written consent in the six years or less prior to the date on which we receive the request. This list will not include uses or disclosures:
    • to carry out treatment, payment, or health care operations
    • to you or your personal representative
    • to your family members or friends who are involved in your care
    • as required or permitted by law as described above
    • as part of a limited data set with direct identifiers removed.

Any request for this list must be made in writing to the Compliance Coordinator at the address listed below. We can provide you with a form to assist you with this written request; you may also download it from our website. Your request must state the time period for which you want the list. The time period may not be longer than six years; it may be shorter. The first list you request within a 12-month period will be free. We will charge you a fee for additional requests in that same period.

  • Right to Breach Notification: You have the right to be notified following a breach of your unsecured protected health information.

Changes To This Notice 

Federal law gives all patients a right to a paper copy of this Notice. We have the right to change this Notice at any time. Any change could apply to medical information we already have about you as well as any information we receive in the future. The effective date of this Notice is May 3, 2013 and Castlewood Treatment Center is obligated to abide by its terms. We will post a copy of the current Notice at Castlewood Treatment Center facilities and on our website, http://castlewoodtc.com.  Should our information practices change, we will provide a copy of the current Notice of Privacy Practices to you when you come in for your next visit.

How to Ask a Question or Report a Complaint

If you have questions about this Notice or want to talk about a problem without filing a formal complaint, please contact the Compliance Officer at 636-386-6611. If you believe your privacy rights have been violated, you may file a written complaint with us. Please send it to the Compliance Officer at Castlewood Treatment Center, 1260 St. Paul Rd., Ballwin, MO 63012, Attn: Privacy Issues. You may also file a complaint with the Secretary of the Department of Health and Human Services by contacting the Office for Civil Rights, DHHS – Region VII, 601 East 12th Street – Room 248, Kansas City, MO 64106; Phone: (816) 426-7277; TDD: (816) 426-7065; Fax: (816) 426-3686. You will not be treated differently for filing a complaint.