Notice of Privacy Practices

Your Information. Your Rights. Our Responsibilities.

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.  For more information, see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html or contact our Privacy Officer at (989) 736-9826.

Alcona Citizens for Health, Inc. takes your privacy very seriously and holds all information gathered during the course of your care in the strictest of confidence.

Your Rights

You have the right to:

  • Get a copy of your paper or electronic medical record
  • Correct your paper or electronic medical record
  • Request confidential communication
  • Ask us to limit the information we share
  • Get a list of those with whom we’ve shared your information
  • Get a copy of this privacy notice
  • Choose someone to act for you
  • File a complaint if you believe your privacy rights have been violated
    • More information on these rights and how to exercise them is to follow in this document

Your Choices

You have some choices in the way that we use and share information as we:

  • Tell family and friends about your condition
  • Provide mental health care
  • Share Substance Use or Behavioral Health Records (unless required by law)
    • More information on these choices and how to exercise them is to follow in this document

Our Uses and Disclosures

We may use and share your information as we:

  • Treat you
  • Run our organization
  • Bill for your services
  • Help with public health and safety issues
  • Do research
  • Comply with the law
  • Respond to organ and tissue donation requests
  • Work with a medical examiner or funeral director
  • Address workers’ compensation, law enforcement, and other government requests
  • Respond to lawsuits and legal actions
    • See pages 3 and 4 for more information on these choices and how to exercise them

Your Rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get an electronic or paper copy of your medical record

  • You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
  • We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your medical record

  • You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.
  • We may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communications

  • You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
  • We will say “yes” to all reasonable requests.

Ask us to limit what we use or share

  • You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
  • If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.

Get a list of those with whom we’ve shared information

  • You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask for PHI generally and three years prior to the date you ask for SUD treatment records, who we shared it with, and why.
  • We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free, but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice

You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you

  • If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
  • We will make sure the person has this authority and can act for you before we take any action.

File a complaint if you feel your rights are violated

  • You can complain if you feel we have violated your rights by contacting us using the information on page 1.
  • You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting hhs.gov/ocr/privacy/hipaa/complaints/.
  • We will not retaliate against you for filing a complaint.

Your Choices

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

  • Share information with your family, close friends, or others involved in your care
  • Share information in a disaster relief situation

If you are not able to tell us your preference, for example, if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In these cases, we never share your information unless you give us written permission:

Most sharing of psychotherapy notes

We will not sell your protected health information or use it for marketing purposes without your written authorization, except as permitted by law. You may revoke any authorization you give us for marketing at any time by submitting a written request.

Our Uses and Disclosures

How do we typically use or share your health information?
We typically use or share your health information in the following ways:

Treat you

We can use your health information and share it with other professionals who are treating you.

Example: A doctor treating you for an injury asks another doctor about your overall health condition.

Run our organization

We can use and share your health information to run our practice, improve your care, and contact you when necessary.

Example: We use your health information to manage your treatment and services.

Bill for your services

We can use and share your health information to bill and get payment from health plans or other entities.

Example: We give information about you to your health insurance plan so it will pay for your services.

Fundraising Activities

We do not use or disclose your protected health information for fundraising purposes. If this changes in the future, we will inform you of your right to opt out of receiving fundraising communications, and we will honor all opt-out requests. You will also receive clear and obvious notice in advance of any fundraising efforts, and you will have a choice as to whether to receive fundraising communications that use your SUD treatment records.

How else can we use or share your health information?

We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We must meet many legal conditions before we can share your information for these purposes. For more information, see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.

Help with public health and safety issues

We can share health information about you for certain situations such as:

  • Preventing disease
  • Helping with product recalls
  • Reporting adverse reactions to medications
  • Reporting suspected abuse, neglect, or domestic violence
  • Preventing or reducing a serious threat to anyone’s health or safety

Do research

In certain instances, we can use or share your information for health research.

Comply with the law

We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.

Artificial Intelligence (AI) Tools: We may utilize artificial intelligence (AI) tools to enhance the quality and efficiency of your care, including Substance Use Disorder (SUD) records protected under 42 CFR Part 2, to support care decisions. These AI tools assist in analyzing health data, supporting clinical decisions, and personalizing treatment plans. The use of AI aids our healthcare professionals but does not replace their expertise and judgment. All AI tools used in your care will apply strict security measures to protect your PHI in accordance with HIPAA regulations.

Respond to organ and tissue donation requests

We can share health information about you with organ procurement organizations.

Work with a medical examiner or funeral director

We can share health information with a coroner, medical examiner, or funeral director when an individual dies.

Address workers’ compensation, law enforcement, and other government requests

We can use or share health information about you:

  • For workers’ compensation claims
  • For law enforcement purposes or with a law enforcement official
  • With health oversight agencies for activities authorized by law
  • For special government functions such as military, national security, and presidential protective services

Respond to lawsuits and legal actions

We can share health information about you in response to a court or administrative order, or in response to a subpoena.

We may also use and disclose your protected health information in the following instances.  You have the opportunity to agree or object to the use or disclosure of all or part of your protected health information.  If you are not present or able to agree or object to the use or disclosure of the PHI, then your provider may, using professional judgment, determine whether the disclosure is in your best interest.  In this case, only PHI relevant to your health will be disclosed.

Registries

Unless you object, AHC may disclose PHI to registries, such as the Michigan Childhood Immunization Registry (MCIR).  If you do not wish to participate in a registry, send a written letter to AHC’s Privacy Officer.

Medication History

Unless you object, we may collect information about your medication history through your pharmacy and health insurer. This includes specific consent to release sensitive health information, including, but not limited to, medication related to mental health conditions, sexually transmitted diseases, substance abuse, and HIV/AIDS. If you do not wish to participate, please send a written letter to the Health Information Manager.

Appointment Reminders and Messages

Unless you object, AHC may leave appointment reminder messages and send text messages to the telephone number that you have provided.  If you do not want reminders or voicemails left on your telephone, send a written letter to the Privacy Officer.

Others Involved in Your Healthcare

Unless you object, we may disclose to a member of your family, a relative, a close friend or any other person you identify, your protected health information that directly relates to that person’s involvement in your healthcare.  If you are unable or object to such a disclosure, we may disclose such information as necessary if we determine that is in your best interest based on our professional judgment.  We may use or disclose protected health information to notify or assist in notifying a family member, legal representative or any other person that is responsible for your care of your location or general condition.  Finally, we may use or disclose your protected health information to an authorized public entity to assist in disaster relief efforts and to coordinate uses and disclosures to family or other individuals involved in your healthcare.

Emergencies

We may use or disclose your protected health information in an emergency treatment situation.  If this happens, your provider shall try to obtain your consent as soon as reasonably practicable after the treatment is delivered.  If your provider or another provider in the practice is required by law to treat you and the provider has attempted to obtain your consent, he or she may still use or disclose your protected health information to treat you.

Special Protections for Substance Use Disorder Information (42 CFR Part 2)

Some services provided involve the diagnosis, treatment, or referral for treatment of substance use disorders (SUDs). Records related to these services, including any billing information, emails, voicemails and texts may be protected by a federal confidentiality law called 42 CFR Part 2 (“Part 2”).

Part 2 provides additional privacy protections for SUD records beyond those required by HIPAA.

How We May Use and Disclose Substance Use Disorder Information

With Your Written Consent

In most cases, we may only use or disclose your Part 2-protected information if you sign a written consent. Your consent must include:

  • Your name;
  • The name of the persons authorized to make the requested use or disclosure;
  • The name or category of who will receive the information;
  • Each purpose of the requested use or disclosure;
  • A description of the information to be used or disclosed that identifies the information in a specific and meaningful fashion;
  • Your right to revoke the consent in writing;
  • An expiration date or event;
  • Your signature, or the signature of a minor’s personal representative, and the date signed; and
  • If the consent provides for the use and disclosure of records for treatment, payment or health care operations, the potential for the records used or disclosed pursuant to the consent to be subject to redisclosure by the recipient and no longer protected by Part 2.

Under federal law, you may authorize us once to use or disclose your SUD information for treatment, payment, and health care operations (TPO), similar to HIPAA. This consent remains valid until you revoke it in writing.

You may revoke your consent at any time, except to the extent we have already relied on it.

SUD Counseling Notes

Certain counseling notes that analyze or summarize a counseling session and are kept separate from the rest of your medical record receive additional protection and generally require separate consent for disclosure.

Uses and Disclosures Without Your Consent

Federal law permits limited uses or disclosures of Part 2 information without your consent, including:

  • Medical emergencies
  • Qualified Service Organizations (QSOs) that provide services such as billing, data processing, or care coordination
  • Management, audits, financial audits and program evaluations
  • Research, with required approvals and safeguards
  • Disclosures of de-identified SUD records for public health purposes, including reports of child abuse or neglect, as required by law
  • Court orders that meet Part 2 requirements (a subpoena alone is not sufficient), including:
    • Criminally investigating or prosecuting a patient; or
    • Crimes committed by the patient on program premises or against staff.

We will not use broad treatment, payment, or operations permissions for SUD records unless allowed by federal law and authorized by you.

Redisclosure of Substance Use Disorder Information

When Part 2-protected information is disclosed to a HIPAA-covered entity or business associate under a valid consent for treatment, payment, or health care operations, the recipient may further use or disclose the information as permitted by HIPAA, except where federal law continues to prohibit its use.

Restrictions on Use for Legal or Law Enforcement Actions

Your SUD records cannot be used to investigate or prosecute you for a crime or to bring legal action against you without your written consent or a court order that meets strict federal standards.

Breach Notification

We follow the HIPAA Breach Notification Rule for Part 2 records. If your Part 2-protected information is impermissibly used or disclosed and constitutes a breach, we will notify you as required by law.

Your Rights

You have the right to:

  • Receive confidential treatment of your SUD information
  • Access and obtain copies of your records, with limited exceptions
  • Request restrictions on certain uses or disclosures
  • Revoke your consent at any time
  • Receive an accounting of certain disclosures
  • File a privacy complaint without fear of retaliation

We will not discriminate against you for exercising your privacy rights or for choosing not to authorize certain disclosures.

Other:  Please note that in some instances, information that is permissibly disclosed pursuant to the Privacy Rule may be redisclosed and no longer protected by HIPAA.

Our Responsibilities

  • We are required by law to maintain the privacy and security of your protected health information.
  • We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
  • We must follow the duties and privacy practices described in this notice and give you a copy of it.
  • We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information, see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with:

  • Contact AHC’s Privacy Officer
  • The U.S. Department of Health and Human Services (HHS)
  • Substance Abuse and Mental Health Services Administration (SAMHSA), Part 2 Privacy Complaints – https://www.samhsa.gov/part-2-privacy

Filing a complaint will not result in retaliation or affect the care you receive.

Changes to the Terms of this Notice

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our web site.

Other Instructions for Notice