Notice of Privacy Practices
NOTICE OF MEDICAL INFORMATION USE AND DISCLOSURE
This notice outlines how your medical information may be utilized and shared, as well as how you can access it. Please read it carefully.
Last Updated: August 8, 2023
OVERVIEW
This notice explains the ways in which Noraxhealth (“Practice,” “we,” or “us”) may share your health information and describes your rights and our obligations regarding the use and disclosure of that information. Headway is a behavioral health group operating through multiple legal entities, collectively referred to as an “organized health care arrangement” under the HIPAA Privacy Rule. Noraxhealth collaborates with the providers listed on our website and offers services through telehealth and at the providers’ service locations. Our legal entities may share protected health information as needed to facilitate treatment, payment, and healthcare operations. All entities within Noraxhealth agree to adhere to this Notice of Privacy Practices.
We are legally obligated to: ensure your identifiable health information remains private; provide you with this notice detailing our legal duties and privacy practices; inform you of any breaches involving your unsecured protected health information; and comply with the terms of this notice that are currently in effect. While this notice is delivered electronically, you may request a paper copy at any time. We reserve the right to change our privacy practices and the terms of this notice at any time; a revised notice can be found on our website. This notice is effective as of February 8, 2021.
HOW YOUR INFORMATION IS USED
We may use and disclose your health information to provide services and ensure quality care. Specifically, treatment services, payment collection, and healthcare operations are all essential for delivering quality care, as permitted by state and federal laws.
Here are some examples, although this list is not exhaustive:
Treatment: For instance, if your provider cannot prescribe medications but wants to refer you to a prescriber within your insurance network, they may share your health information to facilitate this referral.
Insurance Verification: The Practice or its business associates may use and disclose your health information to confirm your insurance coverage.
Payment Collection: The Practice or its business associates will submit claims to your insurance company to receive payment for the services rendered, which involves using your health information.
Healthcare Operations: The Practice or its business associates may review your health information to assess treatment procedures and ensure compliance among providers.
For any uses or disclosures beyond treatment, payment, and operations, we require your written consent unless the use or disclosure falls under specific exceptions. Most uses and disclosures of psychotherapy notes, marketing purposes, and transactions that involve the sale of Personal Information require your authorization. You can revoke authorizations at any time to prevent further uses or disclosures, except where we may have already acted based on your authorization
DISCLOSURES THAT CAN OCCUR WITHOUT AUTHORIZATION
Emergencies: We may share necessary information to address an immediate emergency you are experiencing.
Judicial and Administrative Proceedings: Your personal health information may be disclosed during a judicial or administrative process if required by a valid court order or other lawful requests, including in the case of a Workers’ Compensation claim.
Public Health Activities: If we believe you pose an immediate threat to yourself or others, we may disclose your health information to appropriate authorities and notify any individuals who may be at risk.
Child/Elder Abuse: We are obligated to disclose health information if there is suspicion of child or elder abuse or neglect.
Criminal Activity or Threats to Others: We may disclose health information if a crime occurs on our premises or against our staff, or if we suspect someone is in imminent danger.
Health Oversight Activities: We may share health information with a health oversight agency for legally authorized activities, such as audits or inspections, which are essential for monitoring the healthcare system and ensuring compliance with civil rights laws. Regulatory bodies may review your records to verify adherence to their standards, and only the minimum necessary information will be provided.
Business Associates: The Practice may share the minimum required health information with our business associates who perform services on our behalf. For instance, if we contract with a vendor to file insurance claims, that organization will access your information as part of the process. All business associates are required to sign confidentiality agreements and are prohibited from using or disclosing your information beyond what is specified in our contracts.
Research: In certain situations, we may use and disclose health information for research purposes, allowing researchers to review non-identifiable information to aid in their project planning.
Marketing: We may send newsletters or information about our services that we think may interest you. You can request to have your name removed from our mailing list at any time.
Appointment Scheduling: We may contact you via email or phone to schedule or remind you of your appointments.
YOUR INDIVIDUAL RIGHTS
Right to Inspect and Copy: You have the right to view or obtain copies of your health information, with some exceptions. Requests must be made in writing, and a reasonable fee may apply for copies.
Right to Amend: You can request amendments to your health information in writing, providing reasons for the changes. We may deny your request under certain circumstances.
Right to an Accounting of Disclosures: You have the right to receive a record of instances where your health information has been disclosed for purposes other than treatment, payment, or healthcare operations. To obtain this accounting, submit a written request to the Privacy Officer. This information will be available for six years after your last service date at the Practice.
Right to Request Restrictions: You can request limitations on how your health information is used or disclosed. For example, you might ask that we refrain from sharing information with your insurance company, in which case you would be responsible for full payment. During treatment, this request should be made to your therapist; after therapy, it should be directed to the Privacy Officer. While we are not obligated to agree, we will take your request seriously. If granted, we will adhere to the agreement unless the information is needed in an emergency or required by law.
Right to Request Confidential Communications: You can request that we communicate with you about health matters in a specific way or at a certain location. For example, you may prefer we contact you only by mail or at your workplace. This request must be made in writing and specify the preferred methods or locations for communication. We will make every effort to accommodate reasonable requests.
Right to File Complaints: If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of Health and Human Services. To file a complaint with us, contact the Privacy Officer at compliance@headway.co or (646) 453-6777. You will not face retaliation for filing a complaint, and you may also reach out to the Privacy Officer for more information regarding this notice.
E-mails and Text Messages
Some of our patients prefer to communicate with their providers through email or text messages. However, it’s important to recognize that these methods come with inherent privacy and security risks. There can be errors in transmission or the possibility of messages being intercepted. Communication via email or text is not considered secure between you and your treating provider. At the discretion of your healthcare provider, any email or text communication, along with their responses, may be included in your medical record. Furthermore, for urgent or emergency situations, you should not depend on email communication with providers associated with the Practice; instead, you should call 911.
Assignment of Benefits / Financial Responsibility / Telehealth Consent
I acknowledge the payment and insurance information provided below and agree to cover the costs for services rendered to me, as well as assist in facilitating payment for services provided by the providers affiliated with any of the behavioral health groups managed by Headway (Practice).
1. Payment of Fees
I agree to pay for the services outlined in this agreement. I understand that:
Payments for sessions with providers affiliated with the Practice must be made online via debit or credit card or ACH transfer unless otherwise arranged.
Payment for each session is due after it concludes, unless we agree to different terms. The Practice will charge my card or bank account for my portion of the payment. Receipts may be provided at the time of the charge or on a monthly basis.
I will be charged for missed sessions unless I provide sufficient notice as specified by my treating provider at the Practice regarding cancellations.
I understand that I cannot submit cancellation fees to my insurance company or managed care plan.
2. Insurance and Managed Care Plans
The Practice is affiliated with various insurance and managed care plans. If my plan is accepted, I agree to pay all applicable deductibles, co-payments, co-insurances, and any other cost-sharing amounts. If my insurance benefits are exhausted, the Practice will notify me of the end date, and I will be responsible for all charges incurred after that date. If my insurance plan denies coverage for a visit, despite the Practice following necessary protocols, I understand that I may be required to pay the full amount for the service.
1. Assignment of Insurance Fees; Release of Confidentiality for Benefit Authorization and Clinical Care
I authorize my insurance or managed care plan to pay the Practice directly, rather than reimbursing me. If my plan pays me directly, I will promptly forward that payment to the Practice unless I have already settled the charges myself. I permit the Practice to provide my insurance or managed care plan with any information necessary to secure insurance benefits and authorization for services. I also authorize the Practice to obtain any relevant clinical information from other clinicians and facilities that have treated me during my treatment, and to share relevant clinical information with providers who will continue my care. Any exceptions to this must be indicated in writing.
1. Consent to Treatment Via Telehealth
I consent to participate in telemental health services. I understand that I have the right to decline these services and to be informed about alternative options that may be available. If I request alternative services, I recognize that the Practice may not be able to provide them, which could lead to delays, the necessity to travel, or other risks associated with not receiving services via telemental health, as well as risks related to receiving telehealth services in a remote location. I acknowledge that telehealth may entail certain risks that are less common in in-person services, such as technology failures, the need for specialized electronic security measures, and reduced visibility of non-verbal cues. However, telehealth can also offer advantages not available with in-person services, such as increased flexibility regarding the timing and location of services.