Notice of privacy practices

Behavioral Health Services, LLC ("the practice") is required by law to maintain the privacy of your protected health information ("health information"), to give you this notice of our legal duties and privacy practices, and to follow the terms of the notice currently in effect. "You" in this notice means the client; for a minor client, it generally also includes the parent or guardian acting as the client's personal representative.

How we may use and disclose your health information

For treatment. We use your health information to provide and coordinate your care. For example, with appropriate permissions in place, Dr. Wald may consult with another professional involved in your or your child's care, such as a pediatrician or psychiatrist, about diagnosis and treatment planning.

For payment. We use your information to bill and collect payment for services, including processing card, HSA, and FSA payments. The practice is out of network with insurance plans. At your request we prepare a superbill containing the information insurers require (such as dates of service, diagnosis codes, and procedure codes), and you decide whether to submit it to your plan. If you submit it, your insurer will receive that information.

For health care operations. We may use your information for activities that support the practice, such as quality review, record keeping, professional consultation and supervision, and legal or accounting services for the practice.

Appointment contact. We may contact you by phone, text, or email to schedule, confirm, or follow up on appointments, using the contact methods you have provided. Tell us at any time if you prefer a specific method or location (see "Confidential communications" below).

Family and friends involved in your care. With your permission, or in an emergency where you are unable to agree and it is in your best interest, we may share relevant information with a family member or other person involved in your care. For child clients, parent and guardian involvement is a normal part of treatment, discussed openly at the start of care.

Business associates. Some services that support the practice, such as technology or billing vendors, may require access to limited health information. These vendors are bound by written agreements requiring them to protect your information as the law requires.

Emergencies and disaster relief. We may disclose information as needed in a medical emergency, or to disaster relief organizations assisting in locating or notifying family after an emergency.

Psychotherapy notes

Psychotherapy notes kept separate from the clinical record receive special protection under HIPAA. Most uses and disclosures of psychotherapy notes, including for payment, require your separate written authorization. Limited exceptions exist, such as use by Dr. Wald for treatment, supervised training, defense of a legal action brought by you, or where disclosure is required by law.

Uses and disclosures that do not require your authorization

We may use or disclose health information without your authorization only in limited circumstances permitted or required by law, including:

• when disclosure is required by federal, state, or local law;
• to report suspected abuse, neglect, or exploitation of a child or vulnerable adult as required by Florida law;
• for public health activities;
• to health oversight agencies, such as licensing boards, for audits and investigations;
• in judicial or administrative proceedings in response to a court order or other lawful process;
• to law enforcement in the narrow circumstances the law permits;
• to prevent or lessen a serious and imminent threat to the health or safety of a person or the public, consistent with applicable law and professional ethics;
• for workers' compensation as authorized by law;
• to a coroner, medical examiner, or funeral director as permitted by law;
• for specialized government functions such as military or national security purposes; and
• about an inmate to a correctional institution as permitted by law.

We may also use and disclose information that has been de-identified so it no longer identifies you.

Minor clients, parents, and guardians

Because the practice serves children and adolescents, parents or guardians generally have access to a minor child's health information as the child's personal representative. Florida law creates specific exceptions, and effective therapy with adolescents also depends on agreed expectations of privacy. How session privacy works, what is shared with parents, and what must always be shared (such as safety concerns) are discussed and agreed together at the start of care, and those expectations are honored within the limits of the law.

Uses and disclosures that require your authorization

Uses and disclosures not described in this notice will be made only with your written authorization. That includes most uses and disclosures of psychotherapy notes, uses of your information for marketing purposes, and any sale of health information. This practice does not market with client information, does not fundraise, and does not and will not sell health information. Research uses, if ever relevant, would occur only with your authorization. You may revoke an authorization at any time in writing, except to the extent we have already relied on it.

Your rights

Access and copies. You may inspect and receive a copy of your health information in the designated record set, on paper or electronically, with limited exceptions provided by law. Ask in writing; we will respond within 30 days, with one 30-day extension if needed, and may charge a reasonable, cost-based fee for copies.

Amendment. You may ask us in writing to correct information you believe is incorrect or incomplete. We may deny the request in certain cases; if so, you will receive the reason in writing and may add a statement of disagreement to your record.

Accounting of disclosures. You may request a list of certain disclosures we have made of your information during the six years before your request (this does not include disclosures for treatment, payment, operations, or those you authorized).

Restrictions. You may request restrictions on how we use or disclose your information. We are not always required to agree, but we must honor your request to restrict disclosure to your health plan when the disclosure is for payment or operations and you have paid for the service in full out of pocket. Because this practice is self-pay by default, this right is especially relevant here, and we honor it.

Confidential communications. You may ask us to contact you in a specific way or at a specific location, for example only at a certain phone number or email. You do not need to give a reason, and we will accommodate reasonable requests.

Paper copy. You may request a paper copy of this notice at any time, even if you agreed to receive it electronically. It is also available at the office.

Breach notification. If a breach of your unsecured health information occurs, we will notify you without unreasonable delay and no later than 60 days after discovery.

To exercise any of these rights, contact us using the information below.

Our duties

We are required by law to maintain the privacy and security of your health information, to provide this notice of our duties and practices, to abide by the terms of the notice currently in effect, and to notify you of a breach of unsecured health information. We reserve the right to change this notice and to make the new terms apply to information we already hold; the current version will always be posted on this page with its effective date, and paper copies will be available at the office.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with the practice using the contact information below, and with the Secretary of the U.S. Department of Health and Human Services, Office for Civil Rights: www.hhs.gov/ocr/complaints, or 1-800-368-1019. You will never face retaliation from this practice for filing a complaint.

Contact

Privacy contact: Dr. Emily Wald.

Behavioral Health Services, LLC
1390 S Dixie Hwy, Suite 1305, Coral Gables, FL 33146
(305) 431-0002  ·  Dremilywald@waldbhs.com