I.
A commitment to your privacy
The practice is required by law to maintain the privacy and security of your protected health information, to follow the duties and privacy practices described in this notice, and to provide you with a copy of it.
Your information will not be used or shared other than as described here unless you provide written permission. Any such permission may be revoked, in writing, at any time — except to the extent that it has already been relied upon.
II.
How your information may be used and disclosed
Your health information may be used and disclosed, without separate written authorization, for the following purposes:
- Treatment
- To provide, coordinate, or manage your psychological care and related services, including consultation with other treating clinicians — for example, with a psychiatrist coordinating medication.
- Payment
- To bill for services and collect payment from you, your health plan, or another responsible party, which may include sharing your diagnosis and dates of service with an insurer.
- Health care operations
- For the necessary activities of running the practice, such as quality assessment, clinical training, and administration.
III.
Disclosures permitted without authorization
The law permits or requires disclosure without your authorization in a limited set of circumstances: when required by law (including mandatory reporting of suspected abuse or neglect of children, elders, or individuals with disabilities under Massachusetts law); to avert a serious and imminent threat to health or safety; for public health activities; for health oversight by an appropriate agency; in response to a valid court order or properly served subpoena; for narrowly defined law enforcement purposes; to coroners, medical examiners, and funeral directors; for workers' compensation; for research approved by an institutional review board; and for specialized government functions.
IV.
Disclosures requiring your written authorization
Beyond the purposes named above, your written authorization is required for any use or disclosure of your information — including for psychotherapy notes (subject to narrow exceptions), for marketing, for any sale of health information, and for fundraising. The practice does not engage in marketing, does not sell health information, and does not use health information for fundraising.
V.
Psychotherapy notes
Psychotherapy notes are kept separately from your clinical record. They are the clinician's personal observations, recorded for use in your care. They carry additional protections under HIPAA, are not included in the information available under your general right of access, and will not be released without your specific written authorization except in the very limited circumstances permitted by law.
VI.
Your rights regarding your health information
- To inspect and copy
- You may inspect and obtain a copy of the information maintained in your clinical record. Submit a written request; a response will be made within thirty days, with a possible thirty-day extension. A reasonable, cost-based fee may apply for copying and mailing.
- To request amendment
- If you believe information in your record is incorrect or incomplete, you may request an amendment, in writing, with a reason. A response will be made within sixty days. If declined, you may submit a written statement of disagreement, which will be included with your records.
- To an accounting of disclosures
- You may request an accounting of certain disclosures made within the six years prior to your request. The first such accounting in any twelve-month period is provided without charge. The accounting excludes disclosures for treatment, payment, or operations, disclosures made to you, and those you authorized in writing.
- To request restrictions
- You may ask that the use or disclosure of your information be restricted for treatment, payment, or operations, or to family members involved in your care. Agreement to such a request is not generally required. It is, however, required where you pay for a specific service entirely out of pocket and ask that information about that service not be shared with your health plan.
- To confidential communications
- You may request that communications regarding your health information be made in a particular manner or at a particular location — for example, by mail or only at work. Reasonable requests will be accommodated.
- To notification of a breach
- You will be notified promptly in the event of a breach of your unsecured health information.
- To a paper copy of this notice
- A paper copy of this notice will be provided to you at any time on request.
- To choose a personal representative
- You may designate another person to act on your behalf, such as through a health care power of attorney. Legal authority will be verified before any information is shared or instructions accepted.
VII.
A note on minors and adolescents in Massachusetts
In most cases a parent or legal guardian is the minor's personal representative and controls access to the minor's protected health information. Massachusetts law and professional standards, however, recognize important privacy protections for minors.
Where a minor has the legal right to consent independently to care — for example, to certain mental health services from age sixteen, or to treatment for substance use — the minor controls access to the related information. Access by a parent or guardian may also be limited where providing access is reasonably likely to endanger the physical safety or life of the minor or another person, or where a court has specifically limited parental access.
As a matter of practice, work with families proceeds through boundaried but open two-way communication. Parents and guardians typically receive general updates on progress, goals, and recommendations; information about attendance and engagement; immediate notification of significant safety concerns; and the opportunity for parent sessions or phone consultations. The specific content of therapy sessions, and session-by-session notes, are generally kept private. Disclosure may be required, without the minor's consent, where there is a serious and imminent risk of harm, where there is suspected abuse, neglect, or exploitation, where a court orders disclosure, or where a parent or guardian has a legal right to the information and no exception applies.
VIII.
Changes to this notice
The terms of this notice may be revised, with the new provisions made effective for all health information then maintained. Any material change will be promptly posted in the office and on this website, and a copy of the revised notice will be provided at your next visit or by mail or email.
IX.
Questions and complaints
To ask a question, exercise any of your rights, or request further information, please use the contact details listed at the foot of this notice.
If you believe your privacy rights have been violated, you may file a complaint directly or with the Secretary of the U.S. Department of Health and Human Services. No retaliation will be made for filing a complaint. Federal complaints may be directed to the U.S. Department of Health and Human Services, Office for Civil Rights, at 1-800-368-1019 or hhs.gov/ocr/privacy/hipaa/complaints.