NOTICE OF PRIVACY PRACTICES 

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

 Effective Date

This Notice is effective 11/1/2013, updated 9/1/2016, updated 12/18/2016

I. My Duties

The privacy and confidentiality of your health information is very important and GSC Counseling Services, LLC is committed to protecting it to the extent possible, consistent with law and ethical standards. Your health information includes records that GSC Counseling Services, LLC create and obtain in order to provide care to you. For example, it includes a record of your symptoms, examination and test results if applicable, diagnoses, summary of treatment and referrals. Bills, insurance claims and other payment information is also included in the record of your health information.

This Notice tells you about the different ways GSC Counseling Services, LLC may use and disclose your health information. It also describes your rights and my obligations. GSC Counseling Services, LLC is required to:

• maintain the privacy of your protected health information as required by law; 

• provide you with this Notice of my legal duties and privacy practices with respect to your health information that 
is collected and maintained; 

• follow the terms of my Notice that is currently in effect. 


II. Uses and Disclosures of Protected Health Information – Payment, Treatment and Health Care Operations Under federal law, GSC Counseling Services, LLC is permitted to use and disclose personal health information without authorization for treatment, payment and health care operations. However, state law or the ACA’s Code of Ethics may require GSC Counseling Services, LLC to obtain your express authorization before disclosing certain portions of your record and protected health information. GSC Counseling Services, LLC may also choose to require your release of information in certain circumstances. Treatment: For example, your therapist may discuss certain aspects of your counseling with your psychiatrist in order to provide the best treatment and medication for you. Likewise, your psychiatrist may discuss certain medication management issues with your therapist so your therapist can collaborate in treatment. Payment: If your health insurance company for payment, needs more information than what is printed on your receipt, GSC Counseling Services, LLC will provide only the minimum amount of information necessary for the insurance company to process the claim. This may include the diagnosis and explanation of care provided. 


III. Other Uses and Disclosures of Protected Health Information
Besides use and disclosure for treatment, payment and health care operations, GSC Counseling Services, LLC may use and disclose your personal health information without authorization for the following purposes.

• Abuse, Neglect or Domestic Violence: your therapist may disclose protected health information about you to a state or federal agency if he/she is required or permitted by law to report child or vulnerable adult abuse or neglect or domestic violence. When possible, and as consistent with my professional judgment in order to avoid harm to you or others, your therapist will inform you of the need to make such a disclosure. 

• Judicial or Administrative Proceedings: your therapist may disclose health information about you in the course of a judicial or administrative proceeding as required by law. For example, if a court orders your therapist to release information, your therapist must generally comply with the order. In some circumstances, your therapist may be required to turn over information in response to a subpoena. If GSC Counseling Services, LLC receives a subpoena for your records, your therapist will attempt to contact you and/or your attorney if that is feasible. Your attorney may be able to file a motion which will lead to a court order. 


Law Enforcement: If authorized or required by law, GSC Counseling Services, LLC may release health information to law enforcement officials. For example, your therapist may release information to help identify a suspect or fugitive or report a crime related to a medical emergency. 


Health Oversight Activities: GSC Counseling Services, LLC may disclose health information about you to governmental, licensing, auditing or health care accrediting agencies where authorized or required by law. For example, information may be released to the state counselor licensure board if a complaint is filed against your therapist. 


Appointment Reminders and other Health Services: Your therapist may contact you to remind you of appointments or to inform you of treatment alternatives or other options and services that may be of interest to you. 


Prevention of Serious Threat to Public Health or Safety: In accordance with law and ethics, your therapist may use and disclose health information about you to prevent or minimize the risk of a serious and imminent threat to your health and 
safety or to the health and safety of another person or the public. 


Minors: If you are an unemancipated minor under the law of the state of Pennsylvania, your therapist may, in certain circumstances, disclose health information about you to a parent, guardian or other authorized person, in accordance with law and ethics.


Parents: If you are the parent of an unemancipated minor, your therapist may disclose health information about your child to you in certain circumstances. For example, if your therapist must legally obtain your consent in order to treat your child, when you are acting as your child’s “personal representative” under law, your therapist may disclose health information about your child to you. In other circumstances, such as when your child is legally authorized to consent to treatment without a separate consent from you, and where the child does not request that you act as his/her “personal representative”, your therapist may not disclose health/mental health information about your child to you without your child’s authorization.


Personal Representative: If you are an adult or emancipated minor, your therapist may disclose health information about you to a “personal representative” authorized to act on your behalf in making health care decisions.


Research and Related Activities: GSC Counseling Services, LLC may disclose health information about you for research purposes in accordance with my legal and ethical obligations. Additionally, federal law allows us to create a “limited data set,” which does not include information such as your name, address, and Social Security number. This limited data set may be shared with those who have signed a contract promising to protect the privacy of the information and to use it only for research, health care oversight and health care operations.


Worker’s Compensation/ Employee Assistance Program: Your therapist may disclose health information about you for worker’s compensation or employee assistance program as authorized or required by law. These programs provide benefits for certain work-related illnesses and injuries or employee related mental health issues.


Required by Law: Your therapist may disclose information about you when required to do so by federal, state or other applicable law.

Authorization Required for Other Uses or Disclosures: Your therapist will obtain your written authorization for any other use or disclosure of your
protected health information. You have the right to revoke any authorization, in writing and in accordance with this Notice, to the extent that action has not been taken in reliance on the authorization. Psychotherapy notes are not among the records that you may, by law, review or copy, unless your therapist believes it is in your best interests to access them. Your therapist will be happy to discuss the issue of psychotherapy notes with you if you have any questions.

IV. Your Rights Regarding Health Information

You have certain rights regarding health information that is created and maintained about you. These rights include:

• Right to Request Restrictions-You have the right to request restrictions on certain uses and disclosures of protected health information about you. You also have the right to request a limit on the medical information disclosed about you to someone who is involved in your care or the payment for your care. If you ask to disclose information to another party, you may request that limited the information disclosed. However, GSC Counseling Associates, LLC is not required to agree to a restriction you request. To request restrictions, you must make your request in writing, and tell me: 1) what information you want to limit; 2) whether you want to limit my use, disclosure or both; and 3) to whom you want the limits to apply.
• Right to Receive Confidential Communications by Alternative Means and at Alternative Locations — You have the right to request and receive confidential communications of PHI by alternative means and at alternative locations. (For example, you may not want a family member to know that you are seeing a therapist. Upon your request, your therapist will send your bills to another address. You may also request that your therapist contact you only at work, or that your therapist does not leave voice mail messages.) To request alternative communication, you must make your request in writing, specifying how or where you wish to be contacted.
• Right to an Accounting of Disclosures – You generally have the right to receive an accounting of disclosures of PHI for which you have neither provided consent nor authorization. On your written request, your therapist will discuss with you the details of the accounting process
• Right to Inspect and Copy – In most cases, you have the right to inspect and copy your medical and billing records. To do this, you must submit your request in writing. If you request a copy of the information, GSC Counseling Associates, LLC may charge a fee for costs of copying and mailing.  An initial review of your records will be conducted with your therapist in order to explain any portion of information contained in your notes. 
• Right to Amend – If you feel that protected health information is incorrect or incomplete, you may ask me to amend the information. To request an amendment, your request must be made in writing, and submitted to your therapist. In addition, you must provide a reason that supports your request. GSC Counseling Associates, LLC may deny your request if you ask to amend information that: 1) was not created by GSC Counseling Associates, LLC; 2) is not part of the medical information kept by GSC Counseling Associates, LLC; 3) is not part of the information which you would be permitted to inspect and copy; 4) is accurate and complete.

• Right to Receive a Paper Copy of this Notice. You have the right to request a paper copy of this Notice at any time, even if you have agreed to receive it electronically. 
In order to make any requests or exercise any rights set forth above, you must submit your request in writing to: Danille Bowman, LCSW 
1800 East Market Street, York, PA 17402.

You may also contact Danille Bowman by phone or e-mail during normal office hours. Further contact information is set forth in Section V, immediately below this section. 717-547-0307 or dbowman@gsccounseling secure.com

V. Questions or Complaints

If you believe that your privacy rights have been violated, you may file a written complaint and address it to Danille Bowman, LCSW (listed in section VI above). If that does not satisfy your concern, you may complain to the Secretary of Health and Human Services (HHS). Instructions for filing a complaint with the appropriate office for your region can be found at http://www.hhs.gov/civil-rights/filing-a-complaint/complaint-process/index.html Alternatively, you may call 1-800-368-1019 and request instructions for filing a complaint. There will be no retaliation for filing a complaint.

VI. Future Changes to this Notice and My Privacy Practices

GSC Counseling Services, LLC reserve the right to amend the terms of my privacy practices and policies and this Notice. If this Notice is revised, the changed terms will apply to all health information about you, including information obtained before the effective date of the revised Notice. Any materially revised Notice will be distributed to all clients, posted in our waiting area and posted on our website.

CLIENT RIGHTS AND RESPONSIBILITIES

As a client of GSC Counseling, you have the following rights:

• To be treated with dignity and respect at all times. You will not be subjected to harsh or unusual treatment or be 
deprived of any civil rights while a client at GSC Counseling Services; 

• To expect that a licensee has met the minimal qualifications of training and experience required by state law; 

• To examine public records maintained by the Board and to have the Board confirm credentials of a license. 

• To obtain a copy of the Code of Ethics; 

• To report complaints to the Pennsylvania State Board of Social Workers, Marriage and Family Therapists and Professional Counselors; 

• To be informed of the cost of professional services before receiving the services; 

• To be assured of privacy and confidentiality while receiving services as defined by rule and law, including the following exceptions: 

• Reporting suspected child abuse; 

• Reporting imminent danger to client or others; 

• Reporting information required in court proceedings or by client’s insurance company, or other relevant agencies; 

• Providing information concerning licensee case consultation or supervision; and
• Defending claims brought by client against licensee; 


• To be free from being the object of discrimination on the basis of race, religion, gender, or other unlawful category while receiving services. 


As a client of GSC COUNSELING SERVICES, LLC, you have the following responsibilities:

• To provide accurate and complete information concerning your present complaints, present/past medical/personal history, and other matters relating to your current condition and life circumstances.
• To make it known to the therapist whether he/she comprehends clearly the course of treatment and what is 
expected from him/her. 

• To read all handouts: Policies & Procedures, Client Notice of Privacy Practices, Client Rights and Responsibilities, and Client Release of Information Forms. 

• To keep appointments and notifying the therapist at least 24 hours in advance if you are unable to make your appointment. 

• To adhere to treatment recommendations. While entering into therapy is voluntary, during the course of your care, your therapist will make recommendations that are specific to your presenting problem and circumstance. While there are benefits to following these recommendations, choosing not to adhere to them could result in consequences. Those consequences will be discussed in greater detail during the session. 

• To pay all fees incurred for treatment services at the time of service. 


As a client of GSC Counseling Services, I acknowledge that I have been given the Privacy Notice required by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) that prescribes legal duties and privacy practices to protect the privacy of my individually identifiable health information, by GSC Counseling Services.  I also acknowledge that my therapist verbally explained the HIPAA laws and my client rights.