Effective Date of this Notice-April 14, 2003

Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW PERSONAL HEALTH INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION PLEASE REVIEW THIS NOTICE CAREFULLY

OUR COMMITMENT TO YOUR PRIVACY:

The Reginald S. Lourie Center for Infants and Young Children is committed to preserving the confidentiality and privacy of all individuals served. We follow very strict rules from the United States and Maryland Governments about the use and disclosure of medical records/Protected Health Information. The Federal Health Insurance Portability and Accountability Act (HIPAA) establishes a foundation of Federal protection for Personal Health Information, carefully balanced to avoid creating unnecessary barriers to the delivery of quality health care. The rights and practices listed in this Notice of Privacy Practices come from the long history of confidentiality and client rights policies at the Lourie Center as well as the new Federal HIPAA requirements. Some of these laws are complicated; HIPAA regulations also mandate much of the information and some of the language in this Notice. Please ask your clinician to explain, clarify and/or discuss any part of this Notice. In addition, you may contact our Privacy Officer at any time.

UNDERSTANDING MEDICAL RECORDS and PROTECTED HEALTH INFORMATION (PHI):

As a Community Mental Health Center licensed by the State of Maryland, the Parent-Child Clinical Services Program is required to keep specific information about each client in a medical record. Our state-licensed Therapeutic Nursery Program keeps similar records. Typically, this record contains but is not limited to: registration forms/authorizations; identifying information (client name, sex, race, date of birth, etc.); presenting complaint; history of the problem; medical and legal information; assessment information including diagnosis; treatment plans and reviews; contact notes for each session (type of service provided, length of session, diagnosis and progress towards treatment goals); and a discharge summary. This information serves as a basis for planning care and treatment and serves as a means of communication among the many different professionals who may be involved in each client's care. Understanding what is in a medical record and how this is used helps you ensure its accuracy, better understand who, what, where, and why others may access the information it contains, and make a more informed decision when authorizing disclosures to others.

Our medical records are the physical property of the Lourie Center. However, the information contained within the record belongs to the client. If that client is a child, parents/guardians have the rights to access and disclosure described below. However, the child client has all rights to confidentiality. Some of those rights may not extend to adults/other children who are seen at the Program in conjunction with that child's assessment/treatment. For example, in a court of law we are only guaranteed client-therapist confidentiality with the designated client. In some cases, parents/guardians may be clients and have their own medical records. They would then have all rights described below.

The terms of this notice apply to all records containing Personal Health Information that was created or retained by the Lourie Center.

YOUR HEALTH INFORMATION RIGHTS:

1. You have the right to see your own record and/or your child's record and to obtain a copy of the Personal Health Information contained in your child's/your medical and billing records. Records are kept at least six years and/or at least until a child reaches the age of 18, whichever is longer.

" To access a medical record, you may contact the clinician that you are working with or the Director of the Parent-Child Clinical Services Program or the Director of the Therapeutic Nursery Program to obtain a Request to Inspect and Copy Protected Health Information form.

" Once this form is submitted, the Director of the Parent-Child Clinical Services Program or Therapeutic Nursery Program will review your request and will respond within two weeks.

" We may agree to allow you to fully or partially obtain and/or copy a record, agree to have you receive/copy a summary of the record or we may deny you access to the record. If access is denied, our Privacy Officer will provide you an explanation for the denial as well as a description of the review appeal process. This process sets up a review of the denial by another licensed healthcare professional that did not participate in the original denial.

" If access is accepted, a clinician and/or the Director of the Parent-Child Clinical Services Program will accompany you to a private area during your review of the record/summary of the record to explain/interpret what is in that record.

" There will be an administrative fee of $0.25 per page for the copying of all or parts of the record/summary of record.

2. If you disagree with the contents of the medical record, you may request an amendment to that record. To do this, you must submit a Request for Correction/Amendment of Protected Health Information form to the Director of the Parent-Child Clinical Services Program or the Director of the Therapeutic Nursery Program that states the amendment that you are requesting and the reasons for that amendment. You will receive a written response within 60 days.

" If we grant the amendment, we will notify you and place the amendment in the medical record. You may then request that we provide the amendment to others and/or to programs that you identify to us as having already received that medical record.

" If we believe the existing record is accurate and complete and/or if you are requesting amendments to parts of the record that we did not create, we will deny the amendment and give you specific reasons for the denial. You may then submit a statement of disagreement and we may submit a rebuttal. If you notify us in writing, we will attach your request for amendment and our denial to future disclosures of that part of the medical record. Also, if you continue to disagree, you may file a complaint with our Privacy Officer, the Director of the Parent-Child Clinical Services Program at the Reginald S. Lourie Center for Infants and Young Children and/or the Secretary of Health and Human Services, 1600 Fishers Lane, Rockville, Maryland 20852. There will be no retaliation for filing a complaint.

3. You also have the right to obtain an accounting of disclosures made to others and revoke your authorization to use or disclose information. If you wish to access this Disclosure Log of Protected Health Information you must submit a Request for an Accounting of Certain Disclosures of PHI for Non-TPO Purposes form to our Privacy Officer, the Director of the Parent-Child Clinical Services Program. There is no charge for the first request; however, there will be a $5.00 charge for each additional request within a 12-month period.

USE AND DISCLOSURE OF PROTECTED HEALTH INFORMATION:

1. You may authorize the Lourie Center to disclose specific Protected Health Information to a specific person/agency. Authorization for Release of Information forms will be routinely presented during the assessment period. In addition these forms may be obtained from the clinician that you are working with or from the Intake Worker. Subsequently, you may revoke this authorization in writing at any time.

2. HIPPA confidentiality provisions may not cover some of the programs at the Lourie Center. This means that other program records are not kept with our medical records and may not be kept confidential in the same way as a medical record. Therefore the staff members that provide our mental health services will not discuss the contents of a medical record nor share medical record information with staff members from other programs without a signed authorization.

3. We are required by law to disclose Protected Health Information in certain circumstances-to report abuse and neglect and to warn about dangerous behavior.

4. There are some instances in which assessment/treatment services are part of a strictly forensic evaluation. In those cases you will receive notification in writing concerning the limits of confidentiality.

5. We are authorized to use/disclose Protected Health Information without your consent when we use that information for treatment, payment or the health care operations of the program:

" We will use medical record information for treatment. For example, information provided by parents, teachers or other professionals might be recorded in a medical record and used to determine the best course of treatment. This information may be shared with other clinicians at the Lourie Center for purposes of supervision, collaboration and consultation.

" We will use medical record information for payment. For example a bill may be sent to you or an insurance carrier. This bill will contain information related to diagnosis and services provided on a particular date. We may also, on occasion, be required to submit additional information regarding client progress in treatment to an insurance carrier in order to obtain payment for services rendered.

" We will use medical record information for regular health operations. For example, clinical supervisors/program administrators may use information medical record to assess the quality of care and treatment outcomes. This information will then be used in an effort to continually improve the quality and effectiveness of the services provided by the Lourie Center.

" In addition, we may disclose Protected Health Information to another health care provider that a client is also receiving service from for health care fraud and abuse detection or compliance.

6. You have the right to request restrictions on the use and disclosure of medical record information for treatment, payment or regular health operations by submitting a Request For Limitations and Restrictions on Protected Health Information form to the Director of the Parent-Child Clinical Services Program or Director of the Therapeutic Nursery Program. We will carefully consider your request and inform you in writing of our decision to either abide by your request, partially abide by your request or deny your request.

7. Accreditation and licensing bodies such as the Maryland Department of Health and Mental Hygiene will review the information in the medical records to determine the effectiveness of the services provided by the Lourie Center and the Program's compliance with state regulations.

8. We may disclose information in a medical record in response to a valid subpoena. You will be notified if such a subpoena has been received by this agency and the extent to which it has been acted upon.

9. We may use information contained in medical records as part of public information and awareness activities and/or resource development activities conducted by the Lourie Center. If any information is used, client-identifying information such as your or your child's name will not be used.

10. We may use aggregate medical information on such things as outcomes, types of services/treatment modalities used and progress made, when requested by various governmental agencies or foundations funding the Programs. Again, any information that can be used to identify you or your child such as names, addresses and descriptions will not be used when transmitting this information.

11. We may also disclose information in order to contact you, for example to make appointments, to check with you about how your child and/or you are doing, and/or to evaluate the services that we provide to your child and/or you. You will be given an option on the registration form to specify how, where and when you may wish to be contacted and what restrictions you might require in the method of contact. You may also chose if you wish to be contacted for public information and awareness, resource development and/or research activities conducted by the Lourie Center.

OUR RESPONSIBILITIES:

It has always been the policy of the Reginald S. Lourie Center for Infants and Young Children to maintain and protect the privacy of all individuals served to the extent possible.

1. It is our policy to limit disclosures of and requests for Protected Health Information for payment and health care operations to the minimum necessary.

2. We limit which members of our workforce may have access to Protected Health Information for treatment, payment and health care operations, based on those who need access to the information to perform their job functions.

3. All medical record/Protected Health Information are kept in secure locations and only those employees or clinicians who need access to those records for treatment, payment or health care operations, have access to the medical records unless you sign an authorization.

4. It is our responsibility and intent to abide by the terms outlined in this notice with respect to the information we collect and maintain. Over time, we may change this Notice of Privacy Practices. If we make changes we will post the updated version in our reception area, on our web site at www.louriecenter.com and attempt to provide you with an updated copy.

FOR MORE INFORMATION OR TO REPORT A PROBLEM:

If you have questions and would like additional information regarding the practices of the Reginald S. Lourie Center for Infants and Young Children, you may contact the Director of the Parent-Child Clinical Services Program, at 301-984-4444, extension 103. If you believe your privacy rights have been violated, you can initiate the Client Grievance Procedure outlined by the Reginald S. Lourie Center or you may contact our Privacy Officer, the Director of the Parent Child Clinical Services Program at the above telephone number. If you are dissatisfied with the outcome of the grievance process, you can file a compliant with the Secretary of Health and Human Services, 1600 Fishers Lane, Rockville, Maryland 20852. Under federal law, an individual must file a complaint within 180-days of knowledge or perceived knowledge that the act or omission occurred.

There will be no retaliation for filing a compliant.

ACKNOWLEDGEMENT FORM:

I acknowledge that I have received a copy of this Notice of Privacy Practices. I have been given an opportunity to read and review these practices and ask any questions I may have regarding the practices of the Reginald S. Lourie Center for Infants and Young Children. I hereby consent to the use and disclosure of Protected Health Information to carry out treatment, payment and healthcare operations of the Lourie Center.