Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY

Last Updated: August 8, 2023

OVERVIEW
This notice will tell you about the ways Headway (“Practice,” “we,” or “us”) may disclose health information about you and will also describe your rights and certain obligations that we have regarding the use and disclosure of your health information. Headway is a behavioral health group that is operated across multiple legal entities which are referred to by the HIPAA Privacy Rule as an “organized health care arrangement.” Headway has relationships with the providers listed on this website and provides services via telehealth and at the service delivery sites of the providers listed on this website. Headway’s legal entities share protected health information with each other, as necessary to carry out Headway’s treatment, payment and health care operations. All of the legal entities that comprise Headway agree to comply with the terms of this Notice of Privacy Practices.

We are required by law to: make sure that health information that identifies you is kept private; give you this notice of our legal duties and privacy practices with respect to your health information; notify you following a breach of your unsecured protected health information; and follow the terms of the notice that are currently in effect. Although this notice is being provided to you electronically, and by signing an acknowledgment of receipt of this notice, you consent to the provision of this notice electronically, you have the right to request a paper copy of this notice. We reserve the right to change our privacy practices and the terms of this notice at any time. You may obtain a copy of the revised notice on this website. This notice is effective as of February 8, 2021.

HOW YOUR INFORMATION IS USED
We may use and disclose your health information for the purposes of providing services and quality care. For the avoidance of doubt, providing treatment services, collecting payment and conducting healthcare operations are all necessary activities for quality care. State and federal laws allow us to use and disclose your health information for these purposes.

Here are some helpful examples, but this list is not exhaustive:

• Using your information for providing treatment. For example, If your treating provider cannot prescribe medications but wants to refer you to a prescriber in your insurance network, he or she may use your health information for the purpose of referring you to a prescriber who is affiliated with the Practice.
  • The Practice or its business associates may use and disclose health information in order to verify your insurance and coverage.
• Example of using and disclosing your health information for collecting payment
  • The Practice or its business associates will submit claims for reimbursement to your insurance company in order for them to pay us for the services we provide to you, which requires using your health information.
• Examples of using and disclosing your health information for healthcare operations
  • The Practice or its business associates will use and disclose your health information for the review of treatment procedures, and may use it to review documentation to ensure provider compliance.

For uses and disclosures for purposes other than treatment, payment and operations, we are required to have your written authorization, unless the use or disclosure falls within an exception, such as those described below. Most uses and disclosures of psychotherapy notes (as that term is defined in the HIPAA Privacy Rule), uses and disclosures for marketing purposes, and disclosures that constitute the sale of Personal Information require your authorization. Authorizations can be revoked at any time to stop future uses/disclosures except to the extent that we may have already taken any action in reliance on your authorization.

DISCLOSURES THAT CAN BE MADE WITHOUT AN AUTHORIZATION

• Emergencies. Sufficient information may be shared to address an immediate emergency you are facing.
• Judicial and Administrative Proceedings. We may disclose your personal health information in the course of a judicial or administrative proceeding in response to a valid court order or other lawful process, including if you were to make a claim for Workers Compensation.
• Public Health Activities. If we felt you were an immediate danger to yourself or others, we may disclose health information about you to the authorities, as well as alert any other person who may be in danger.
• Child/Elder Abuse. We may disclose health information about you related to the suspicion of child and/or elder abuse or neglect.
• Criminal Activity or Danger to Others. We may disclose health information if a crime is committed on our premises or against our personnel, or if we believe there is someone who is in immediate danger.
• Health Oversight Activities. We may disclose health information to a health oversight agency for activities authorized by law. These activities might include audits or inspections and are necessary for the government to monitor the health care system and assure compliance with civil rights laws. Regulatory and accrediting organizations may review your case record to ensure compliance with their requirements. The minimum necessary information will be provided in these instances.
• Business Associates. The Practice may disclose the minimum necessary health information to our business associates that perform functions on our behalf or provide us with services if the information is necessary for such functions or services. For example, the Practice contracts with a vendor for filing claims with insurance companies. In the process of filing claims, that organization will come into contact with your information. We also contract with a vendor that collects and manages internet or other electronic network activity on our sites and services and internally encodes it so that we can determine and manage information that might be health information. All of our business associates sign agreements to protect the privacy of your information and are not allowed to use or disclose any information other than as specified in our contract.
• Research. Under certain circumstances, we may use and disclose health information for research. We may permit researchers to look at non-identifying information to help them plan research projects.
• Marketing. We may send you newsletters or information about services we provide in which we feel you might be interested. You may at any time request that your name be removed from our mailing list.
• Scheduling appointments. We may email or call you to schedule or remind you of appointments.

YOUR INDIVIDUAL RIGHTS

1. Right to Inspect and Copy. You have the right to look at or get copies of your health information, with limited exceptions. Your request must be in writing. If you request a copy of the information, a reasonable charge may be made for the costs incurred.
2. Right to Amend. You have the right to request that we amend your health information. Your request must be in writing, and it must explain why the information should be amended. We have the right to deny your request under certain circumstances.
3. Right to an Accounting of Disclosures. You have the right to receive a list of instances in which we have disclosed your health information for a purpose other than treatment, payment, or health care operations. To request an accounting of disclosures, you must submit your request in writing to the Privacy Officer. Such accountings remain available for six years after the last date of service at the Practice.
4. Right to Request Restrictions. You have the right to request a restriction or limitation on the health information we use or disclose about you. For example, you could ask that we not share information with an insurance company, in which case you would be responsible to pay in full for the services provided. While you are in treatment, a written request should be made with your therapist. To request a restriction after therapy is completed, you must make your written request to the Privacy Officer. We are not required to agree to your request, but we will consider the request very seriously. If we agree, we will abide by our agreement unless the information is needed in an emergency or by law.
5. Right to Request Confidential Communications. You have the right to request that we communicate with you about health matters in a certain way or at a certain location. For example, you may ask that we contact you only by mail or at work. You must make this request in writing and it must specify the alternative means or location that you would like us to use to provide you information about your health care. We will make every attempt to accommodate reasonable requests.
6. Right to File Complaints. You may complain to us and to the Secretary of Health and Human Services if you believe your privacy rights have been violated. You may file a complaint with us by contacting the Privacy Officer at compliance@headway.co or (646) 453–6777. You will not be retaliated against for filing a complaint. You may also contact the Privacy Officer for further information about this notice.

EMAIL AND TEXT MESSAGES
Some of our patients prefer to communicate with their provider via email or text message. Email and text messages have inherent privacy and security risks, and you should be aware of those before using emails and text messages. Errors in transmission or interception of messages can occur. Your email or text message is not a secure communication between you and your treating provider. At your health care provider’s discretion, your email or text message any and all responses may become part of your medical record. Additionally, for urgent or an emergency situation, you should not rely on email communication with providers affiliated with the Practice. In those situations, you should call 911.

Assignment of Benefits / Financial Responsibility / Telehealth Consent
I acknowledge the payment and insurance information set forth below and agree to pay for services rendered to me and/or facilitate the payment for services rendered to me by the providers affiliated with any of the behavioral health groups managed by Headway (Practice)

1. Payment of Fees: I agree to pay for charges for services as described in this agreement. I understand that:
   • Payment for sessions with providers affiliated with Practice is payable online through debit or credit card or ACH transfer, unless otherwise established
   • Payment for sessions is due after each session unless otherwise agreed upon and Practice will charge my card or bank account for my responsibility. Receipts may be provided at the time of the charge or monthly
   • I will be charged for sessions that I do not keep, unless I provide enough notice to the provider affiliated with the Practice (your treating provider will tell you how much notice is required to avoid being charged for sessions you do not keep)
   • I understand that I cannot submit bills for cancellations to my insurance company or managed care plan
2. Insurance and Managed Care Plans:

Practice participates in a number of insurance and managed care plans. If Practice participates in my plan, I agree to pay all applicable deductibles, co-payments, co-insurances and any other form of cost-sharing. If my insurance benefits run out, Practice will inform me of the ending date, and I will then be responsible for all charges dating from the end of insurance coverage. If my insurance plan denies the visit despite Practice following necessary procedures, I understand I may be responsible to pay in full for the service.

1. Assignment of Insurance Fees; Release of confidentiality for authorization of benefits and for clinical care:

I agree to allow my insurance plan or managed care plan to pay Practice directly, instead of paying me. In the event that my plan pays me directly, I will promptly turn the payment over to Practice unless I have already paid the charges myself. I authorize Practice to provide my insurance plan or managed care plan any information reasonably required to obtain insurance benefits and authorization for services. I authorize Practice to obtain at any time during my treatment here, any and all relevant clinical information from clinicians and facilities that have treated me and to furnish relevant clinical information to providers who will continue to treat me. I will indicate in writing any exceptions to this.

1. Consent to Treatment Via Telehealth:

I consent to participate in telemental health services. I understand that I have the right to refuse telemental health services and be informed of alternative services that may be available to me. If I request alternative services, I understand that Practice may not be able to provide those services, and that I may experience delays in service, the need to travel, or any other risks associated with not having services provided via telemental health, as well as risks associated with receiving telemental health services in an off-site location. I understand that telehealth may result in certain risks that are less likely to occur with in-person services, such as technology failure, need for specialized electronic security systems, and less visibility of non-verbal cues. Telehealth can also provide benefits not present with in-person services, such as creating greater flexibility for when and where services may be provided.