Privacy Practices

This notice describes how protected health information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Your Privacy is Important

Pathway Homes, Inc. (Pathways) understands your privacy is important.

We are required by law to maintain the privacy of protected health information (PHI) and to provide you with notice of our legal duties and privacy practices with respect to PHI. We are also required to abide by the terms of this notice. If at any time you believe your privacy rights have been violated, you may verbally or in writing contact the individuals and/or
organizations listed at the end of this notice.

You will not suffer any change in service or retaliation for filing a complaint.
When you receive services from us, Pathways keeps a service record. Typically, this record includes your assessment, service plan, progress notes, diagnosis, services received, and plan for future care or services. Pathways may also use third party entities (Business Associates) to store or transmit electronic PHI.

Your Federally defined rights under 45 C.F.R. Parts 160 and 164 (HIPAA Privacy Standards),and under The Commonwealth of Virginia’s Administrative Code, Title 12,Sections 35-115-80 and 35-115-90 (Human Rights).

There are several rights concerning your PHI that we want you to be aware of:
You have the right to inspect or request copies of your service records either in hard copy or in electronic form. This process will be kept confidential. However, this right is not absolute. In certain situations, such as if access would cause harm, we can deny access. Although not required, you are encouraged to make this request in writing to your Counselor or his or her supervisor. If denied access, you will receive a timely written notice of the decision and reason. A copy of this request and written reply becomes part of your record.
You have the right to request amendment of your service records if you believe information in the records is inaccurate or incomplete. You must make this request in writing to your Counselor or his or her supervisor. We may deny the request but you will be provided with a written explanation of the denial.
You have a right to receive an accounting of Pathways’ disclosures of your protected health information that were not for the purpose of treatment, payment or health care operations, or that were not otherwise authorized by you. You also have the right to be given the names of anyone, other than employees of the agency, who received information about you.
You have the right to request a restriction with regards to how Pathways uses or discloses your PHI. This request will be given serious consideration by Pathways and you will be informed promptly whether we will be able to honor the requested restriction and still offer effective services, receive payment and maintain health care operations. Legally we are not required to agree to any restrictions you request, but if we do agree, we are bound by that agreement except under emergency situations.
You have the right to request that we communicate with you about medical matters, or services you receive, in a certain way or a certain format. Such requests must be made in writing to your Counselor or his/her supervisor. We will agree to all reasonable requests.
You have the right to obtain a paper copy of this Notice of Privacy Practices at any time upon request.

Use and Disclosure of Your Information

Upon initiating services with Pathway Homes, you are allowing us to use and disclose necessary information about you within the agency and with Business Associates in order to provide services, receive payment for services provided, and conduct our day to day health care operations.
Examples:

• We may contact you for fundraising efforts, but you may tell us not to contact you again.
• In order to effectively provide services, your Counselor may consult with various service providers within Pathways. During those consultations protected health information about you may be shared.
• In order to receive payment for services provided, your PHI may be sent to those entities responsible for payment, and a monthly bill may also be sent to the Responsible Party identified on the financial form.
• In day-to-day health care operations, trained staff may handle your service record in order to assemble the record, or to file documentation. We also maintain electronic medical records and enter certain data elements into our computers that process rent and program fees, and for statistical reporting on demographics and outcomes. We may also share limited data required for contract reporting purposes. As part of our continuous quality improvement efforts to provide the most effective services, your record may be reviewed by professional staff to assure accuracy, completeness and timeliness of documentation. Records may also be reviewed during licensing audits, accreditation surveys, and by government funding sources.

Enhancing Your Healthcare

Some Pathways programs provide appointment reminders by phone or letter to enhance your overall health care and may contact you to provide:

• Information about treatment or service alternatives.
• Information about health-related benefits and services that may be of interest to you.

Individuals Involved in Payment for Your Care

Unless you object, we may provide medical information about you to a family or friend who is involved in your care. Pathways may also give information to someone who helps pay for your care.

Specific Circumstances for Disclosure

Pathways is also allowed by federal and state law in certain circumstances to disclose specific health information about you.
These specific circumstances are:

• As required by law (ex: reports required for public health purposes, such as reporting certain contagious diseases).
• Judicial and Administrative proceedings (ex: Order from a court or administrative tribunal, or legal counsel to the agency, or Inspector General).
• Law Enforcement purposes (ex: limited information requested about suspects, fugitives, material witnesses, missing persons, criminal conduct on premises).
• Children or incapacitated adults who are victims of abuse, neglect or exploitation.
• Specialized Government functions.
• Military Services (ex: in response to appropriate military command to assure the proper execution of the military mission).
• National Security and Intelligence activities (ex: in relation to protective services of the President of the United States).
• State Department (ex: medical suitability for the purpose of security clearance).
• Correctional Facilities (ex: to correctional facility about an inmate).
• Workers Compensation to facilitate processing and payment.
• Coroners and Medical Examiners for identification of a deceased person or to determine cause of death
• To the Federal Department of Health and Human Services in connection with an investigation of us for compliance with federal regulations.

Other Uses and Disclosures of Your Information by Authorization Only

We are required to get your authorization to use or disclose your protected health information for any reason other than for treatment/services, payment, or health care operations, and those specific circumstances outlined previously. We use an Authorization to Exchange form that specifically states what information will be given to whom, for what purpose, and is signed by you or your legal representative. You have the ability to revoke the signed authorization at any time, by informing your Counselor, except to the extent that we have already acted on the authorization.

Changes to Privacy Practices

Pathways reserves the right to change its privacy policy and any of its privacy practices at any time, as allowed by federal and state law and to make the change effective for all protected health information that we maintain. A revised Notice of Privacy Practices will be posted at all service sites, and will be available upon request by mailing or calling a Pathways representative or electronically on Pathways’ website.
For additional information concerning our Privacy Practices or the federal and state laws pertaining to privacy or to file a complaint, please contact one of the following:

Your primary counselor
Your primary counselor’s Immediate Supervisor
Sr. Vice President of Clinical Services
10201 Fairfax Boulevard, Suite 200
Fairfax, VA 22030
(703) 876-0390
TTY: (800) 828-1140

Pathways Privacy Officer
Chief Operating Officer
10201 Fairfax Boulevard, Suite 200
Fairfax, VA 22030
(703) 876-0390

State Human Rights Regional Advocate
Northern Virginia Training Center
9901 Braddock Road
Fairfax, VA 22032
(703) 323-2098

Office for Civil Rights
U.S. Department of Health and Human Services
150 S. Independence Mall West
Suite 372, Public Ledger Building
Philadelphia, PA 19106-9111
Main Line (800) 368-1019
FAX (215) 861-4431
TDD (800) 537-7697

Note to TTY Users: If direct dial number is not provided, please use the Virginia Relay Center (711) to contact any of the offices above.