Notice of Privacy Practices
This notice describes how information about you may be used and disclosed and how you can get access to this information. Please review it carefully.
Our Obligation to Protect Your Personal Information
You will be giving us personal information about yourself and your counseling needs in the course of receiving services at the Counseling & Wellness Center (CWC). The privacy of your health information is very important to us and to you, and we have in place many policies that protect your health information. The federal Health Insurance Portability and Accountability Act (HIPAA) requires that we protect your personal information, that we give you a written description or notice of these privacy policies, and that we abide by our policies. Please read the following information carefully. You will be asked to sign an acknowledgement that you received this notice. We will be happy to answer any questions you may have. You may have a copy of this notice and a copy is posted at the CWC and on our web site www.alaskapacific.edu/apucwc.
Personal Information includes your name, Social Security Number, address, telephone number, account number, employment, medical history, medical and counseling records, insurance claims information, etc.
Release of Information for Treatment and Operations
The CWC will keep a record of information you provide in the course of seeking and receiving treatment, and we will share that information as necessary for the purposes of providing treatment or carrying on the operations of the CWC without further notice to you.
- Treatment purposes – We will share your personal information and history for purposes of providing the most appropriate treatment for you For instance, the counselor you see may discuss your problems or symptoms with another counselor or one of our supervisors in the course of making plans to help you. In every case, however, our staff will only share the information that is minimally necessary to get the help that is needed for you.
- Operations of the CWC – We will enter your personal information in a health record and in a secure scheduling system to allow us to operate in an efficient way. Safeguards are in place so that the staff members involved in the operations of the CWC have access to the minimum necessary information when carrying out their responsibilities.
Mandatory Release of Protected Health Information – releases that are required by state and federal law
The staff at the Counseling Center are required to release your protected information in the following circumstances without getting your permission. When we deal with conflicting state and federal laws, we will abide by the more restrictive law.
- Court Order – If a judge orders us to release your personal information, we will comply with the judge’s order and release the information requested. If we receive a subpoena without a signed authorization from you, we will resist the subpoena and request a review by a judge.
- Imminent danger to yourself or others – If you provide information to our staff indicating that you may be in imminent danger of seriously harming yourself or that you intend or are likely to seriously harm other persons, we will release the minimum information necessary to protect you and other persons from harm. This may include contacting the police to have you examined for involuntary commitment or warning the persons you are threatening to harm.
- Abuse of a child or abuse of a dependent adult – All counseling staff are required by Alaska law to notify authorities if we have reason to suspect physical, emotional or sexual abuse or neglect of children, elders or disabled persons.
- Law Enforcement Purposes – We will comply with state and federal laws that mandate release of protected health information. In cases of national security, the USA PATRIOT Act (Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act, October 25, 2001) requires release of information. Under the USA PATRIOT Act, we may be barred from telling you that we have released any information about you.
- Oversight of this federal law, the Health Insurance Portability and Accountability Act (HIPAA) – If requested, we will release your personal health information to the Secretary of the Department of Health and Human Services for purposes of monitoring the Counseling Center’s compliance with this federal law.
Additional uses of Protected Health Information
- Use of telephone – If you give us a telephone number, we may call you and leave a message on your answering machine to remind you of an upcoming appointment unless you tell us not to leave messages.Use of email – We do not communicate with you by email with regard to your personal care unless you ask us to communicate information via email or you initiate the email communication. We do not provide counseling services using electronic communication.
Release of Protected Health Information with Authorization
All other releases of protected information will be made only with your written authorization. The following are examples of situations where you might want to authorize release of your protected information. A potential employer, such as an airline or a police department, might require a history in the course of considering you for employment. An insurance company might require protected information in the course of evaluating your application for life insurance coverage. Or you might want to authorize us to communicate with your parents. In these situations, we will release only the information you authorize us to release. You will need to indicate in writing the person needing the information and the type of information from your record. The authorization for release of information will be in effect for a limited length of time, and you can revoke the authorization at any time. If you revoke your authorization, we may still rely on it for any services provided prior to your revocation.
Your rights under HIPAA
You have a number of rights under the Health Insurance Portability and Accountability Act (HIPAA) as follows:
- Changes or restrictions in our policies – You may ask us to modify or restrict how we release your protected information. We have the right to agree or disagree. If we agree to the restriction, we are bound to abide by that agreement. If we disagree, you have the right to pursue treatment here under our existing policies or elsewhere as you choose. If you insist on a restriction to which we do not agree, then we can decline to offer treatment to you.
- Confidential communication – You have the right to request that we communicate with you about your services by alternative means or at an alternative location. For example, you may request that we communicate with you only in writing or only through a particular mailing address. We are not obligated to agree to all requests for restriction.
- Inspection and copying of counseling records – We maintain a higher level of restriction regarding review and release of counseling or psychotherapy records than is required by law. In the case of counseling and psychotherapy records and notes, including the results of psychological testing, your counselor will make a determination about release of your records after reviewing the records with you in person. You may have a copy of these records and notes by providing us with a signed authorization only after that review. If your counselor is not reasonably available (e.g. retired or on extended leave), the Director of the Center will review the records with you and make a determination regarding release.
- Re-release or re-disclosure of protected health information – The Center will not release information, reports or other documents we have received from another health care provider or agency.
- Amendments, changes and additions to records – You may request that we correct our records if you believe we have incorrect information. We will not make changes to records if we believe our record is accurate and complete as is and we will not make changes to records we have received from other health care providers. We will correct our records or write an addendum to our records in cases where we believe the record is inaccurate. In cases where you disagree with what is in our record, we will make a note in the record indicating the area of disagreement.
- Accounting for disclosures – The Center will keep a record of all disclosures of your protected information to the degree that the information was disclosed without your knowledge or authorization or outside the limits of permitted disclosures contained in this Notice of Privacy Practices.
- Copy of Notice of Privacy Practices – You have a right to a printed copy of this Notice of Privacy Practices now or at any time in the future even if you initially reviewed this Notice electronically. This Notice of Privacy Practices is also
available on our APU web site at www.alaskapacific.edu/apucwc.
- Acknowledgement – You will be asked to sign an acknowledgement form indicating that you were offered a copy of the Notice of Privacy Practices. If you do not sign the acknowledgement form, one of our staff members will sign it indicating that you were informed of our Notice of Privacy Practices and offered a copy of the document.
- APU Counseling & Wellness Center & Clery Act Reporting
It is the policy of the CWC to maintain client confidentiality. The Clery Act is a report to the Federal government detailing crimes within the university’s areas of responsibility. The Clery Act does not allow a counselor to breach confidentiality; however it is possible, and beneficial to the greater campus population, that accurate information is disseminated regarding criminal activity in a way that does not violate client confidentiality. As such, CWC staff and interns will work with the Dean of Students by providing a report of non-identifying information, including:
- where the crime occurred;
- the type of crime;
- to whom the crime was reported; and
- when the crime was reported.
Our obligation to abide by this Notice of Privacy Practices
We are required to abide by this printed Notice of Privacy Practices. We reserve the right to change our Notice of Privacy Practices and to issue a revised Notice of Privacy Practices. If we make material changes to our privacy practices, we will post the changes in our office in the place where we routinely post our Notice of Privacy Practices. We will also provide a notice to all clients in writing the next time they come to the Center for services. The written notice will describe the change in Privacy Policies.
Any complaint with regard to our handling of your protected health information or any complaint regarding any other matter regarding your care at the Center for Health and Counseling should be directed to:
Counseling & Wellness Center, Alaska Pacific University
4101 University Drive
Anchorage, AK 99508
If you make a complaint, the Center will not retaliate.
Complaints may also be directed to the Secretary of the Department of Health and Human Services in Washington, D.C.
APUCC NOPP, 9/29/10