			Contact Us Directory Site Map Search IUP Home

Notice of Privacy Practices Effective June 30, 2003

Indiana University of PA

Center for Counseling and Psychological Services (C-CAPS)

307 Pratt Hall

Indiana, PA 15705

(724) 357-2621

www.iup.edu/counselingcenter

Notice of Policies and Practices to Protect the Privacy of Your Health Information

As members of both the higher education and health care communities, the Center for Counseling and Psychological Services has a unique obligation to respect the privacy of your health care record. Records at the Center for Counseling and Psychological Services (C-CAPS) are governed by the Federal Educational Rights and Privacy Act (FERPA). The staff at C-CAPS will also voluntarily use the Health Insurance Portability and Accountability Act (HIPAA) to guide the standards used regarding the privacy of your medical information. Nothing herein contained shall be construed as an admission or representation that the Center for Counseling and Psychological Services is a covered entity under HIPAA.

This notice describes how information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Who will Follow This Notice?

· All C-CAPS personnel including student employees

C-CAPS understands that medical information about you and your health is personal. C-CAPS is committed to protecting medical information about you. C-CAPS creates a record of the care and services you receive. C-CAPS needs this record to provide quality care and to comply with certain legal requirements or regulations guiding psychological practice in the Commonwealth of Pennsylvania. This notice applies to all of the records of your care generated by C-CAPS personnel.

This notice will tell you about the ways in which the Center for Counseling and Psychological Services may use and disclose medical information about you. C-CAPS also describes your rights and certain obligations regarding the use and disclosure of medical information.

C-CAPS is required to:

· make sure that medical information that identifies you is kept private

· give you access to this notice of health center legal duties and privacy practices with respect to medical information about you; and

· follow the terms of this notice that is currently in effect

I. Uses and Disclosures for Treatment, Payment, and Health Care Operations

C-CAPS may use or disclose your protected health information (PHI), for treatment, payment, and health care operations purposes with your consent. To help clarify these terms, here are some definitions:

1. “PHI” refers to information in your health record that could identify you.

2. “Treatment, Payment and Health Care Operations”

· Treatment is when we provide, coordinate or manage your health care and other services related to your health care. An example of treatment would be when we consult with another health care provider, such as your family physician or another psychologist.

· Payment in this case is not applicable, as C-CAPS does not charge for services.

· Health Care Operations are activities that relate to the performance and operation of the center. Examples of health care operations are quality assessment and improvement activities, and case management and care coordination.

3. “Use” applies only to activities within our office, such as sharing, employing, applying, utilizing, examining, and analyzing information that identifies you.

4. “Disclosure” applies to activities outside of our office, such as releasing, transferring, or providing access to information about you to other parties.

II. Uses and Disclosures Requiring Authorization

C-CAPS may use or disclose PHI for purposes outside of treatment, payment, and health care operations when your appropriate authorization is obtained. An “authorization” is written permission above and beyond the general consent that permits only specific disclosures. In those instances when we are asked for information for purposes outside of treatment, payment and health care operations, we will obtain an authorization from you before releasing this information. Psychotherapy notes are not included in your PHI at C-CAPS, and not released. Psychotherapy notes may be released with a separate authorization. These notes are given a greater degree of protection than PHI.

You may revoke authorization at any time, provided each revocation is in writing. You may not revoke an authorization to the extent that we have already relied on it in making an authorized use or disclosure. Your revocation of an authorization must be in writing.

III. Uses and Disclosures with Neither Consent nor Authorization

C-CAPS may disclose information in accordance to federal, state or local law without your authorization in the following circumstances:

To report Child Abuse or Neglect: If we have reasonable cause, based on our professional judgment (or judgment of the professional supervisor) to have reasonable cause to suspect abuse of children with whom we come into contact in our professional capacity, we are required by law to report this to the Pennsylvania Department of Public Welfare.
Adult and Domestic Abuse: If we have reasonable cause to believe that an older adult is in need of protective services (regarding abuse, neglect, exploitation or abandonment), we may report such to the local agency which provides protective services.
Judicial or Administrative Proceedings: If you are involved in a court proceeding and a request is made about the professional services we provided you or the records thereof, such information is privileged under state law, and we will not release the information without your written consent, or a court order. The privilege does not apply when you are being evaluated for a third party or where the evaluation is court ordered. You will be informed in advance if this is the case.
Serious Threat to Health or Safety: If you express a serious threat, or intent to kill or seriously injure an identified or readily identifiable person or group of people, C-CAPS must take reasonable measures to prevent harm. Reasonable measures may include directly advising the potential victim of the threat or intent.

IV. Your Rights regarding your medical record and counseling center duties:

Right to Inspect and Copy. You have the right to inspect and copy health information that may be used to make decisions about your care. Usually, this includes medical and billing records (C-CAPS DOES NOT OFFER THIRD PARTY BILLING). To inspect and copy health information that may be used to make decisions about you, you must submit your request in writing to C-CAPS. C-CAPS may deny your request to inspect and copy in certain very limited circumstances; however, you may request that the denial be reviewed. Another licensed health care professional chosen by C-CAPS will review your request and the denial. The person conducting the review will not be the person who denied your request.

Right to Amend. If you feel that health information C-CAPS has about you is incorrect or incomplete, you may ask to amend the information. You have the right to request an amendment for as long as the information is kept by or for C-CAPS. To request an amendment, your request must be made in writing and submitted to C-CAPS. In addition, you must provide a reason that supports your request. C-CAPS may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, C-CAPS may deny your request if you ask us to amend information that:

was not created by C-CAPS, unless the person or entity that created the information is no longer available to make the amendment
is not part of the health information kept by or for C-CAPS
is not part of the information which you would be permitted to inspect and copy or
is accurate and complete

Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures made of health information about you. This list will not include disclosures C-CAPS made to you, disclosures made for the purposes of treatment, payment or our operations or those authorized by you.

You generally have a right to receive an accounting of disclosures of PHI for which you have neither provided consent nor authorization. On your request, we will discuss with you the details of the accounting process.

Right to Request Restrictions. You have the right to request a restriction or limitation on the health information disclosed about you for treatment, payment or health care operations. C-CAPS is not required to agree to your request. To request restrictions, you must make your request in writing to C-CAPS. In your request, you must state (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, for example, disclosure to your spouse.

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. (For example, you may not want a family member to know that you are seeing us. Upon your request, we will send communications to another address.)

Right to a Paper Copy of This Notice. You have the right to a paper copy of this notice. You may ask C-CAPS to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. To obtain a paper copy of this notice you may stop by the C-CAPS, 307 Pratt Hall.

Changes To This Notice
C-CAPS reserves the right to change this notice. C-CAPS reserves the right to make the revised or changed notice effective for medical information we already have about you as well as any information received in the future. C-CAPS will post a copy of the current notice on the website www.iup.edu/counselingcenter. This notice will contain on the first page, in the top right-hand corner, the effective date. In addition, each time you register at C-CAPS for treatment or health care services, a copy of this notice will be available to you.

Complaints
If you believe your privacy rights have been violated you may file a complaint with Indiana University of Pennsylvania or with the Secretary of the Department of Health and Human Services. To file a complaint with Indiana University of PA, contact the Indiana University of PA Privacy Officer at (724) 357-6475 or by mail at: Chief Privacy Officer, Indiana University of Pennsylvania University, c/o 610 Pratt Drive, Indiana, PA 15705. All complaints must be submitted in writing. You will not be penalized for filing a complaint.

Other Uses of Health Information
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with written permission. If you provide permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, C-CAPS will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that C-CAPS is unable to take back any disclosures already made with your permission, and that C-CAPS is required to retain our records of the care that was provided to you.

Correspondence regarding this site should be sent to its maintainer, Eric Rosenberger. Please see IUP's statement regarding pages that do not officially represent the university.