Notice of Privacy Practices

Privacy of Patient Health Information

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

I. Uses and Disclosures for Treatment, Payment, and Health Care Operations

As your provider, we may use or disclose your Protected Health Information (PHI) for treatment, payment, and health care operations purposes with your consent.

"PHI" refers to information in your health record that could identify you.

Treatment is when we provide, coordinate, or manage your care. For example, consulting with your family physician or another therapist.

Payment is when we use PHI to obtain reimbursement from your health insurer or to determine eligibility.

Health Care Operations are business-related activities such as quality assessment, audits, administrative services, case management, and coordination of care.

"Use" means activities within our office. "Disclosure" means providing access to information outside our office.

II. Uses and Disclosures Requiring Authorization

We will obtain written authorization before using or disclosing your PHI for purposes outside treatment, payment, or health care operations. This includes the release of Psychotherapy Notes, which receive extra protection.

You may revoke an authorization in writing at any time, except to the extent we have already relied on it or when law allows an insurer to contest a claim.

III. Uses and Disclosures Without Consent or Authorization

We may disclose PHI without your consent or authorization in the following circumstances:

Child Abuse or Neglect — If there is reasonable suspicion, we are required to report it.

Health Oversight — If subpoenaed or otherwise lawfully required by oversight agencies.

Court Proceedings — If ordered by a court, or if you are being evaluated for a court-related purpose.

Serious Threats — If you threaten serious harm to yourself or others, we may disclose information to prevent it.

Worker's Compensation — As required by law to comply with worker's compensation programs.

IV. Electronic Communications (Email, Telehealth, SMS)

Email

With your consent, we may use your email address for scheduling, billing, and other administrative purposes. Email is not always secure. We will avoid including detailed clinical information unless you request otherwise.

Telehealth

We may provide services using HIPAA-compliant telehealth platforms. These services are subject to the same privacy protections as in-person visits.

SMS Texting

What we collect: Your mobile number, your name, and limited scheduling or administrative information.

How we use it: Appointment reminders, confirmations, office updates, and administrative communication. We do not send detailed clinical information by text.

Who we share with: Only authorized staff at Make Your Turn. SMS consent is not shared with third parties.

Your rights: SMS participation is optional. You may revoke consent at any time in writing or by replying "STOP."

V. Social Media and Online Reviews

We do not engage with patients through social media platforms (e.g., Facebook, Instagram, Google reviews). For your privacy, staff will not acknowledge or respond to online reviews or comments. Please use official channels (phone, email, patient portal) for communication.

VI. Business Associates

We may use third-party service providers (such as billing software, telehealth platforms, or texting services). These vendors are Business Associates under HIPAA and are legally required to protect your PHI under Business Associate Agreements (BAAs).

VII. Marketing and Fundraising

We do not use or disclose your PHI for marketing or fundraising purposes without your written authorization.

VIII. Data Breach Notification

In the event of a breach of unsecured PHI, we will notify you promptly, as required by HIPAA and the HITECH Act.

IX. Patient Rights

You have the right to:

  • Request Restrictions on certain uses and disclosures (though we may not be required to agree).
  • Confidential Communications by alternative means (e.g., billing to another address).
  • Inspect and Copy your PHI in records we maintain.
  • Request Amendments to your PHI if you believe it is inaccurate.
  • Accounting of Disclosures of PHI.
  • Paper Copy of this notice at any time.

Some requests may involve reasonable fees.

X. Provider Duties

We are required by law to maintain the privacy of PHI and provide this notice of our legal duties. We reserve the right to change these policies and practices. If revised, we will provide you with an updated notice.

XI. Substance Use Disorder Records (42 CFR Part 2)

If applicable, your substance use disorder (SUD) records are protected by federal law under 42 C.F.R. Part 2. This law provides extra confidentiality protections and requires a separate patient consent for the use and disclosure of SUD counseling notes.

Each disclosure made with patient consent must include a copy of the consent or a clear explanation of the scope of the consent, accompanied by a written notice containing the language in 42 CFR Part 2.32(a).

Disclosure of these records requires your explicit written consent, except in limited circumstances such as:

  • Medical Emergencies — to the extent necessary to treat you
  • Reporting Crimes on Program Premises
  • Child Abuse Reporting — in connection with incidents of suspected child abuse or neglect to appropriate state or local authorities
  • Fundraising — we will provide you with an opportunity to decline to receive any fundraising communications prior to making such communications

You may revoke this consent at any time.

SUD records received from programs subject to Part 2, or testimony relaying the content of such records, shall not be used or disclosed in civil, criminal, administrative, or legislative proceedings against you unless based on your written consent, or a court order after notice and an opportunity to be heard is provided.

XII. Complaints

If you believe your privacy rights have been violated, you may file a complaint with us at:

Make Your Turn
1645 N. Dixie Hwy., Ste 2
Monroe, MI 48162
Phone: (734) 344-7432

You may also file a complaint with the U.S. Department of Health and Human Services. No retaliation will occur for filing a complaint.