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Privacy Policy

It is the policy of Harmony Place to comply with the HIPAA Privacy Rule’s requirements to inform
patients of our privacy practices as it relates to their personal health information. This notice is
intended to explain privacy issues and concerns, and to explain to patients how to exercise their

A. Below is Harmony Place’s Notice of Privacy Practices for Protected Health Information.
B. This policy shall be made available to anyone who asks for it, in addition to being
publicly posted on the Harmony Place website.

PLEASE REVIEW IT CAREFULLY. This Notice Of Privacy Practices is provided to you
under the Health Insurance Portability and Accountability Act and its implementing regulations
(HIPAA) and applies to all records received and created about your physical and mental
condition and treatment, and about billing and payment for such treatment (together, referred to
as “PHI”), that may be maintained, used, and/or disclosed by all HARMONY PLACE INC
workforce members, volunteers, medical staff, and contractors. Let’s discuss Organized Health
Care Arrangements.

Effective Date

This Notice is effective as of October 30, 2014. HARMONY PLACE INC reserves the right to
revise this Notice. If revisions are material, we will promptly revise and distribute a revised
Notice by mail, e-mail (if you have agreed to electronic notice), hand delivery, or by posting on
our website, as required by law. A copy of the current Notice will be made available to you
when you initially register with HARMONY PLACE INC for treatment or services, upon your
request, and on subsequent visits if the Notice has been revised. In addition, the Notice will be
posted at the registration desk.

HARMONY PLACE INC Commitment to Privacy

The privacy protections described in this Notice reflect HARMONY PLACE INC’s
commitment to protecting your privacy and to complying with HIPAA and related federal and
state privacy and security laws (collectively hereafter Privacy Laws), which require
HARMONY PLACE INC to maintain the privacy and security of your PHI; to provide you
with this Notice; to notify you of any unauthorized disclosure, use or other breach of unsecured
PHI; and to abide by the terms of this Notice.

Permitted Uses and Disclosures

The following describes and provides examples of how HARMONY PLACE INC may use and
disclose your PHI without your authorization. Any use or disclosure that does not fall within
one of the following categories requires your written authorization, and your authorization may
be revoked by you at any time. State and/or federal laws may also place restrictions on the
manner in which specific types of PHI may be used and/or to whom such medical information
may be disclosed, such as certain drug and alcohol information, HIV information, alcohol and
substance abuse treatment, mental health treatment, and genetic information. In those instances
where the use and/or disclosure of this PHI is specifically restricted, we will seek appropriate
authorization from you, your legal representative or a valid court order before using or
disclosing this information, unless required in a medical emergency or, in the case of drug or
alcohol abuse programs, the disclosure is authorized by applicable state and federal laws and
regulations governing drug or alcohol abuse. If a use or disclosure of health information
described in this Notice is prohibited or materially limited by state law, it is our intent to meet
the requirements of the more stringent law.


HARMONY PLACE INC may receive PHI from and share PHI with health care
providers involved in your treatment before, during, and after your stay with HARMONY
PLACE INC. For example, HARMONY PLACE INC may provide physicians and therapists
with access to your medical records in connection with providing you with care, or to a
pharmacist in connection with requesting a prescription to identify potential interactions or
allergies. In the event of your incapacity or an emergency, HARMONY PLACE INC may also
disclose your medical information based on our professional judgment of whether the disclosure
would be in your best interests.


HARMONY PLACE INC will use your PHI for purposes of obtaining payment for
your care. For example, HARMONY PLACE INC will provide information about the services
that will be or were provided to you so that your insurance company or health plan may pay us
or reimburse you. HARMONY PLACE INC may also provide information regarding sources of
payment to practitioners outside of HARMONY PLACE INC who are involved in your care to
enable them to obtain payment.

Health Care Operations.

HARMONY PLACE INC may use or disclose PHI in connection with
managing and operating the organization. For example, HARMONY PLACE INC may use
and/or share your PHI in connection with providing you with appointment reminders; evaluating HARMONY PLACE INC performance and the quality of care provided; averting a
serious threat to health or safety; legal services and audit functions, including fraud and abuse
detection, compliance programs, and due diligence activities; licensing and accreditation;
business planning and development; in determining what additional services we should offer,
what services are no longer needed, and whether certain new treatments are effective; and in
certain circumstances where you have not otherwise objected, in making reports to the public or
private entities authorized by law or charter to assist in disaster relief efforts (such as the Red
Cross) to notify a family member or personal representative of your location or general
condition. We may also disclose your health information to business associates with whom we
contract to provide services where such business associates agree to appropriately safeguard
your PHI.


HARMONY PLACE INC may use and share PHI for research projects, if approved
by a special process that balances the research needs with patients’ need for privacy of their
PHI. For example, research could include comparing the health and recovery of all patients who
have the same condition, but were treated with different medications. However, in preparing to
start a research project, HARMONY PLACE INC may share PHI with researchers without
authorization or approval, as long as the PHI does not leave HARMONY PLACE INC. For
example, PHI may be shared with researchers at HARMONY PLACE INC to identify patients
who may want to participate in a research study.

Required and Other Permitted Uses and Disclosures

HARMONY PLACE INC may make certain disclosures of your PHI as and when required or
otherwise authorized by law, and will limit the use or disclosure to the amount of PHI necessary
to comply with and/or serve the purposes of the relevant federal, state, or local laws or
ordinances, or the legitimate needs of responsible, authorized agencies in fulfilling their
purposes, including, for example:

 to the United States Department of Health and Human Services as part of an investigation or
determination of compliance with relevant laws;
 to a state agency for activities such as audits and inspections;
 to law enforcement as part of an investigation or to a government authority authorized by law to
receive reports of abuse, neglect, or domestic violence;
 to a court or administrative law judge or other tribunal for judicial or administrative proceedings
and/or as required by court or administrative orders, subpoenas, and/or other lawful process
unless the state has more restrictive laws;1
 to a public health authority which is permitted by law to collect or receive such information for
the purpose of preventing or controlling disease, injury, vital events such as death, child abuse
or neglect; of conducting public health surveillance, investigation and/or intervention; and
reporting adverse reactions to medications or problems with regulated products;
 to a health oversight agency for oversight activities authorized by law, such as audits,
investigations, and inspections.
 to a law enforcement official for a law enforcement/emergency purpose as required by law, in compliance with a court order from a court of competent jurisdiction granted after the application
showing good cause for the issuance of the order, or to investigate a crime occurring on our
 to coroners, medical examiners, or funeral directors consistent with applicable law to carry out
their duties.
 to organ or tissue procurement organizations to facilitate the donation of organs, eyes, or tissues
after your death; and
 for specialized governmental functions, such as national security, and intelligence activities, and for
the provision of protective services to the President to the extent required by Federal and State
 to you or your legal representative. Some state laws concerning minors permit or require
disclosure of PHI to parents, guardians, and persons acting in a similar legal status. FRN will
act consistently with the law of the state where the treatment is provided and will make
disclosures in accordance with such laws.
Under the laws of the state of California, records are produced in response to a court order
issued by a court of competent jurisdiction pursuant to a full and fair show cause hearing.
Uses and Disclosures to Which You May Agree or Object
HARMONY PLACE INC will inform you in advance of certain uses and disclosures and if you
agree or express no objection, may disclose your PHI, for example:
 relevant PHI may be disclosed to a family member, friend or any other person you identify for
that person to be involved in or support your health care or payment related to your health care
or to notify a family member, your personal representative, or other person responsible for your
care of your location, general condition, or death unless doing so is inconsistent with any prior
expressed preference you make to us.
 HARMONY PLACE INC may send PHI via email, text message or through a reasonably
requested method or medium to you, other persons you designate, and to those involved in the
delivery of your health care. You should know that if PHI is transmitted outside of HARMONY
PLACE INC by e-mail or text message, there is some level of risk that the information in the
email/text could be read by a third party.

Uses and Disclosures to Which You Must Agree in Writing

Marketing and Sale of PHI. We will not use your PHI for marketing purposes and will not sell
your PHI without your written authorization unless permitted or required by state and federal
law. Marketing includes communications with you about someone else’s product or service
about which we are paid to communicate with you other than refill reminders, face-to-face
communications, and promotional gifts of nominal value. We will not sell your PHI unless
permitted by law. For example, if we sold a facility to someone else regulated by HIPAA, that
new operator may receive medical records.
Psychotherapy Notes. In recognition of the special confidentiality of psychotherapy notes
recorded by a mental health provider in a counseling session, HIPAA permits us to separatethese notes from the rest of your medical record. When we do, we will not use or disclose your
psychotherapy notes without your written authorization except for use by the originator for
treatment, to defend ourselves in a legal action or proceeding you bring, to someone reasonably
able to prevent or lessen a serious and imminent threat to the health or safety of a person or the
public consistent with legal and professional standards if we believe it is necessary to prevent or
lessen that serious and imminent threat, for our own supervised mental health training
programs, or as otherwise permitted or required by state and federal law. Psychotherapy notes
do not include medication prescription and monitoring, counseling session start and stop times,
the modalities and frequencies of treatment furnished, results of clinical tests, or any summary
of diagnosis, functional status, treatment plan, symptoms, prognosis or progress to date.

Uses and Disclosure of Your PHI Not Covered By This Notice Or By Law.

Uses and disclosures of your PHI not covered by this Notice or applicable law may be made only with
your written authorization, which you may revoke as described below.

Your Rights Regarding PHI

As a HARMONY PLACE INC patient, you have the following rights with regard to your PHI.
Right to Request Restrictions. You have the right to request limits on the use or disclosure of
your PHI for treatment, payment, and/or healthcare operations. You also have the right to
request a limit on PHI we disclose to someone who is involved in your care or the payment of
your care, such as a family member or friend. For example, you may ask that we not disclose
information about a treatment you have received. To request restrictions, the request must be
made in writing to the Privacy Officer as set forth below. In your request you must tell us (1)
what information you want restricted; (2) whether you want to restrict our use, disclosure, or
both; (3) to whom you want the restriction to apply; and (4) the expiration date of the
restriction(s). We are not required to agree to your request except in limited circumstances
where you, or someone on your behalf, paid out of pocket and in full for the items or services
and have requested that we not disclose your PHI to a health plan unless the disclosure is
required by law. If we do agree, we will comply with your restrictions unless the information is
needed to provide emergency treatment.
Right to Make Requests Regarding Method Or Means of Communicating PHI. You have the
right to request that we communicate with you about medical matters in a certain way or at a
certain location. For example, you may ask that we only contact you at work or by mail. Your
request must specify how or where you wish to be contacted. We will accommodate reasonable
requests made in writing to the Privacy Officer as set forth below. Right to Inspect and Copy
PHI. You have the right to inspect and/or receive a copy of PHI contained in a designated
record set for as long as we maintain it, except for psychotherapy notes, information compiled
in reasonable anticipation of, or for use in, a civil, criminal or administrative action or
proceeding, or PHI that may not be disclosed under the Clinical Laboratory Improvements
Amendments of 1988. A designated record set contains medical and billing records and any
other records that HARMONY PLACE INC uses to make decisions about your care or payment for your care. While HIPAA does not require us to provide you with access to psychotherapy
notes, we may allow you such access upon written request if HARMONY PLACE INC decides,
based on a clinical assessment, that doing so may not be harmful to you. We do not disclose
actual test questions or raw data of psychological tests that are protected by copyright laws. You
have the right to receive an electronic copy of any of your designated record set that is
maintained in an electronic format (known as an electronic medical record or an electronic
health record), and to request that the copy be given to you or transmitted to another individual
or entity. We may charge a reasonable, cost-based fee in accordance with applicable state and
federal law for copying and mailing your records, including portable media such as a CD or
DVD if you so request. We may deny your request in certain limited circumstances. If your
request is denied, you may request that your denial be reviewed. Such reviews will be
performed by an independent licensed healthcare professional chosen by our Privacy Officer.
We will comply with the outcome of the review.
Right to Amend. If you believe that the information we have about you is incorrect or
incomplete, you may request an amendment to your PHI in a designated record set. You may
submit a request for amendment in writing to the Privacy Officer, with a reason you wish to
make the amendment. While we accept requests for amendment, we are not required to agree to
them. We may deny your request if you ask us to amend information that was not created by us,
is not part of your designated record set, or if the information is determined to be accurate and
complete as it is. If we deny your request, we will provide you with a written denial and you
will be given the opportunity to submit a written statement disagreeing with the denial. We will
include this information in your medical record. If we grant your request, we will inform you in
a timely fashion, make the amendment, and provide appropriate notification. Right to Revoke
your Authorization. If you provide us with authorization to use or disclose your PHI, you may
revoke that authorization, in writing, at any time, and we will honor your request(s), except as
required, prohibited, or permitted by law. Such revocation will not apply to any action that
HARMONY PLACE INC took in reliance on your authorization prior to the revocation’s
receipt. Right to Breach Notification. In certain instances, you have the right to be notified if
we, or one of our Business Associates, discover an inappropriate use or disclosure of your PHI.
Notice of any such use or disclosure will be made in accordance with state and federal
Right to Accounting of Disclosures. You have the right to request an accounting of
disclosures.? This is a list of disclosures that we have made of your PHI. We are not required to
list certain disclosures, including (1) disclosures made for treatment, payment, and health care
operations purposes, (2) disclosures made with your authorization, (3) disclosures made to
create a limited data set, (4) disclosures made directly to you, (5) disclosures permitted or
required by the Federal HIPAA Privacy Rule, and/or (6) disclosures occurring prior to April 14,
2003. You must submit your request in writing to our Privacy Officer. Your request must state a
time period that may not be longer than 6 years before your request. Your request should
indicate in what form you would like the accounting (for example, on paper or by e-mail). The
first accounting you request within any 12-month period will be free. For additional requests,we may charge you for the reasonable costs of providing the accounting. We will notify you of
the costs involved and you may choose to withdraw or modify your request before any costs are
Right to a Paper Copy of this Notice. You have a right to a paper copy of this Notice, even if
you agreed to receive it electronically. Please contact us as directed below to obtain this Notice
in written form.
Right to Foreign Language Version. If you have difficulty reading or understanding English,
you may request a copy of this Notice in another language.
Personal Collection and Us
Third parties, including Facebook, may use cookies, web beacons, and other storage
technologies to collect or receive information from your websites and elsewhere on the Internet
and use that information to provide measurement services and target ads. You may opt out of
this collection and use of information for ad targeting at any time by

Contact Information for Privacy Officer
If you would like more information about our privacy practices or have questions or concerns
about this Notice, please contact the following:
Attn: Privacy Officer

If you believe your privacy rights have been violated, you may file a complaint, in writing, to either of the above or you may contact the U.S. Department of Health and Human Services (HHS). You will not be penalized or retaliated against in any way for making a complaint.