HIPAA Notice of Privacy Practices

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

1. Our Pledge

Bogner Health LLC (“we,” “our,” or “us”) is committed to protecting the privacy of your protected health information (“PHI”) in accordance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health Act (“HITECH”), and Michigan privacy law. We will use and disclose PHI only as described in this Notice or as permitted by law.

2. Uses and Disclosures Without Your Authorization

2.1 Treatment

We may use and disclose your PHI to provide, coordinate, or manage your healthcare and any related services, including consultations with other providers, laboratories, pharmacies, and care managers.

2.2 Payment

Although Bogner Health LLC is a cash-pay practice and does not bill insurance, we may use and disclose your PHI to obtain payment for services, including for our billing, collection activities, and — at your request — to provide you with itemized superbills you may submit to your insurer (we make no representation that any insurer will pay).

2.3 Healthcare Operations

We may use and disclose your PHI for our healthcare operations, including quality assessment, credentialing, training, audits, legal services, and general administrative activities.

2.4 Other Permitted or Required Disclosures

We may also use or disclose your PHI without your authorization in the following circumstances, to the extent permitted or required by law:

• Required by federal, state, or local law (including mandatory reporting of certain communicable diseases, suspected child or elder abuse, and gunshot or stab wounds);
• Public health activities and oversight (e.g., FDA reporting of adverse events for products we administer);
• Court orders, subpoenas, or other lawful judicial or administrative process;
• Law enforcement purposes when permitted by law;
• To avert a serious threat to health or safety;
• Workers’ compensation programs as authorized by law;
• Coroners, medical examiners, and funeral directors;
• Organ and tissue donation organizations;
• Research, but only when an Institutional Review Board has approved the research and established protocols to protect privacy;
• Specialized government functions (military, national security, protective services);
• Business associates who perform services on our behalf under written agreements that require them to protect your PHI.

3. Uses and Disclosures Requiring Your Written Authorization

Most uses and disclosures NOT described in Section 2 require your written authorization, including:

• Most uses and disclosures of psychotherapy notes (where applicable);
• Marketing communications (other than face-to-face communications or promotional gifts of nominal value);
• Sales of PHI;
• Disclosures to family members, employers, schools, attorneys, financial advisors, life-insurance carriers, or other third parties not otherwise permitted above.

You may revoke any authorization in writing at any time, except to the extent we have already acted in reliance on it.

4. Your Rights

Under HIPAA, you have the following rights regarding your PHI:

• Right to Inspect and Copy: You may request access to your PHI in our designated record set. We may charge a reasonable, cost-based fee.
• Right to Amend: You may request that we amend PHI you believe is incorrect or incomplete. We may deny the request under limited circumstances and will provide our reason in writing.
• Right to an Accounting of Disclosures: You may request a list of certain disclosures we have made of your PHI in the six (6) years prior to your request.
• Right to Request Restrictions: You may request that we restrict certain uses and disclosures of your PHI. We are not required to agree, except for disclosures to a health plan for items or services you have paid for in full out of pocket.
• Right to Request Confidential Communications: You may request that we communicate with you in a particular way or at a particular location (e.g., calling only your cell phone or sending mail to a P.O. box).
• Right to a Paper Copy of This Notice: You may request a paper copy at any time, even if you have agreed to receive it electronically.
• Right to Notification of Breach: We will notify you in writing if a breach of your unsecured PHI occurs.
• Right to Complain: You may file a complaint with us or with the U.S. Department of Health and Human Services, Office for Civil Rights. You will not be retaliated against for filing a complaint.

5. Communication Preferences

We may communicate with you by telephone, secure portal messaging, email, text message, or U.S. mail, using the contact information you provide. Email and text are not fully secure forms of communication, and you accept this risk by providing such contact information unless you submit a written request for an alternative.

6. Changes to This Notice

We reserve the right to change this Notice at any time. The revised Notice will be effective for all PHI we maintain at that time. Updated copies will be available at our office and on our website (drbognerhealth.com).

7. Contact and Complaints

Privacy Officer: Magda Yaklin, RN
Bogner Health LLC • 43313 Woodward Ave, #1105, Bloomfield Hills, MI 48302
Email: [email protected] • Fax: 866-465-1916
Web: www.drbognerhealth.com
U.S. Department of Health and Human Services, Office for Civil Rights: www.hhs.gov/ocr/privacy/hipaa/complaints/