Notice of Privacy Practices

Who this notice covers

This Notice of Privacy Practices applies to Ashé Counseling & Coaching LLC, its clinicians, interns, administrative staff, contractors, locations, telehealth services and other members of its workforce who are permitted to use or disclose protected health information.

“Protected health information,” sometimes called PHI, includes information that identifies you and relates to your physical or mental health, the care you receive or payment for your care.

This notice applies whether services are delivered in person, through telehealth, by telephone or through Ashé’s electronic systems and client portal.

Your privacy rights

You have important rights regarding your health information. Ashé will help you exercise these rights and may require a written request or verification of your identity before releasing records.

Electronic or paper copies of your record

We will generally provide a copy or summary of your health information within the timeframe required by law. We may charge a reasonable, cost-based fee when permitted.

Corrections to your record

You may ask us to amend information that you believe is incorrect or incomplete. We may deny your request in some circumstances, but we will explain the reason for the denial in writing within the period required by law.

Confidential communications

You may ask us to contact you through a particular method, such as telephone, email or mail, or at a different location. We will accommodate reasonable requests.

Restrictions on disclosures

You may ask us not to use or share certain information for treatment, payment or healthcare operations. We are generally not required to agree if the restriction could interfere with your care or our legal obligations.

When you pay for a service entirely out of pocket, you may ask us not to disclose information about that service to your health plan for payment or healthcare operations. We will honor that request unless disclosure is required by law.

Personal representatives

A person legally authorized to act on your behalf, such as a legal guardian or an individual holding an appropriate healthcare power of attorney, may exercise your privacy rights. We will verify that authority before taking action.

When you may direct what we share

In certain situations, you may tell us how you want your information shared. We will follow your instructions when the law permits or requires us to do so.

You may choose whether we:

• Share relevant information with a family member, partner, close friend or another person involved in your care.
• Share information with someone involved in paying for your care.
• Share information in connection with disaster relief.

If you are unable to communicate your preference, we may share information when we reasonably believe doing so is in your best interest or is necessary to reduce a serious and imminent threat to health or safety.

You may revoke a written authorization at any time by notifying us in writing. A revocation will not affect disclosures already made in reliance on the authorization.

How we may use and share your information

HIPAA allows us to use and disclose health information for certain purposes without obtaining a separate authorization from you. We limit these uses and disclosures to the minimum information reasonably necessary when that standard applies.

To provide treatment

We may use your information and share it with professionals involved in your care. This may include clinicians, supervisors, care coordinators, healthcare providers or other appropriate members of your treatment team.

For example, your clinician may consult with a clinical supervisor or coordinate care with another provider when appropriate and permitted by law.

To operate our practice

We may use and share information to manage Ashé’s operations, supervise and train clinicians, evaluate the quality of services, improve care, conduct compliance activities and contact you about appointments or services.

To bill and receive payment

We may disclose information to health plans, Medicaid managed care organizations, billing services, clearinghouses or other entities involved in determining eligibility, submitting claims, processing payment or reviewing services.

Business associates

We may share information with vendors and service providers that perform functions involving PHI on our behalf. Where required, those organizations enter into agreements obligating them to safeguard your information.

Appointment and service communications

We may contact you regarding appointments, forms, billing matters, care coordination, service updates or treatment-related information. Messages may contain limited information to protect your privacy.

Public health and safety

We may disclose information when permitted or required for public health and safety purposes, including:

• Preventing or controlling disease or injury.
• Reporting suspected abuse, neglect or exploitation.
• Reducing or preventing a serious and imminent threat to a person or the public.
• Reporting information to appropriate governmental or public health authorities when required.

Health oversight and legal compliance

We may disclose information to authorized oversight agencies for audits, inspections, investigations, licensing, credentialing, Medicaid compliance or other activities authorized by law.

We may also disclose information when required by federal, state or local law, including to the U.S. Department of Health and Human Services when it is reviewing our compliance with federal privacy requirements.

Legal proceedings and government requests

We may disclose information in response to a valid court order, administrative order, subpoena or other lawful process, subject to applicable protections for mental-health, psychotherapy and substance-use-disorder records.

We may also disclose information for workers’ compensation, authorized law-enforcement purposes, certain government functions, or as otherwise permitted or required by law.

Medical examiners and funeral directors

When applicable, we may disclose health information to a coroner, medical examiner or funeral director as authorized by law.

Research

Health information may be used or disclosed for research only when applicable legal and ethical requirements have been satisfied, including authorization or an approved waiver when required.

Behavioral health and psychotherapy records

Mental-health records may receive additional protection under Illinois and federal law. When a law provides greater privacy protection than HIPAA, Ashé will follow the more protective requirement.

We generally will not disclose mental-health treatment records without your written authorization unless the disclosure is permitted or required for treatment, payment, a medical emergency, mandatory reporting, prevention of a serious threat, a valid legal process or another purpose authorized by law.

Psychotherapy notes

Psychotherapy notes are treated differently from the remainder of the clinical record. Most uses and disclosures of psychotherapy notes require your written authorization, subject to limited exceptions under federal and state law.

Substance-use-disorder records

Certain substance-use-disorder treatment records may be protected by 42 CFR Part 2 in addition to HIPAA. When those protections apply, records generally may not be used or disclosed in civil, criminal, administrative or legislative proceedings against you without your written consent or a qualifying court order and subpoena.

Any disclosure of Part 2 records must comply with the specific requirements of federal law. A general authorization for the release of medical information may not always be sufficient.

Minors

Parents, guardians and other personal representatives may have access to a minor’s health information as permitted by law. In some circumstances, Illinois or federal law allows a minor to consent to certain services and may limit a parent or guardian’s access to related records.

Our responsibilities to you

Ashé Counseling & Coaching is required to:

• Maintain the privacy and security of your protected health information.
• Provide you with this notice describing our legal duties and privacy practices.
• Follow the terms of the Notice of Privacy Practices currently in effect.
• Notify affected individuals when a breach of unsecured protected health information occurs, as required by law.
• Use or disclose only the information reasonably necessary when the HIPAA minimum-necessary standard applies.

We will not use or share your information for purposes other than those described in this notice unless you give us written permission or the law otherwise permits or requires the use or disclosure.

Contact us about your privacy rights

You may contact Ashé if you have questions about this notice, need help exercising a privacy right or believe your privacy rights have been violated.

Filing a complaint with the federal government

You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by submitting a complaint through its online complaint portal, calling 1-877-696-6775, or writing to:

U.S. Department of Health and Human Services
Office for Civil Rights
200 Independence Avenue SW
Washington, DC 20201

Changes to this notice

We may revise this Notice of Privacy Practices. A revised notice may apply to health information we already maintain as well as information we receive in the future.

When this notice is materially revised, the updated version will be available upon request, posted at our service locations as appropriate and published on our website with a new effective date.

You may request a paper copy of the current notice at any time by contacting our office.