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 obtain access to this information.
Please review this information carefully.
The Purpose of this Notice
Compass Innovative Behavior Strategies, LLC (Compass) is required by law to maintain the privacy of your personal health information. We are now required by the federal Health Insurance Portability and Accountability Act (HIPAA), Public Law 104-191, and HIPAA regulations, 45 CFR Part 160 and 164, to provide you with this Notice of our privacy practices, our legal duties, and your rights concerning your health information. This Notice will take effect on April 10, 2017 and will remain in effect until it is replaced. Compass must abide by all terms of this Notice as long as it is in effect. Compass reserves the right to revise or change this Notice at any time. Any such revision will affect information we already have about you and any information we receive in the future. If there is any significant change in our privacy practices, this Notice will be changed and the new Notice will be mailed to you. This Notice is available upon request, in our office, and on our website. You do not have to call or do anything in response to this Notice. If you do have any questions about this Notice, please direct your questions to:
Compass Innovative Behavior Strategies, LLC
℅HIPAA Compliance Officer 3 Robinson Road, Unit B-1
Bow, New Hampshire 03304
For more information see:
Compass typically uses or discloses your health information for the following purposes:
We may use or disclose your health information to provide, coordinate, or manage your health care treatment between health care providers. For example, this may include the coordination of treatment by your healthcare provider with a third party, consultation between healthcare providers relating to you, or referral for your health care from one healthcare provider to another.
We may use or disclose your health information to determine and remit proper payment for health care treatment or services you receive, or to receive payment for health care treatment provided to you at Compass or any other treatment location. For example, your health information may be used to determine eligibility for services, billing, claims management, and collection activities.
For Health Care Operations:
We may use or disclose health information about you for operational purposes. For example, your health information may be used to conduct quality assessment and improvement activities, to conduct fraud and abuse detection programs, and for business planning and development. It may also be used for professional review of health care professionals, auditing services, claims adjudication, underwriting and general administrative purposes of Compass.
Other Possible Uses and Disclosures:
Compass must meet any requirements by law before we can use or disclose your information for these purposes:
Disclosures Required by Law:
We may use or disclose information about you when we are required to do so by law. Compass may disclose your health information to comply with a court order, an administrative order, a subpoena, a discovery request or other lawful process, report information related to victims of abuse or neglect, or to a law enforcement official for a law enforcement purpose.
Your health information may be used or disclosed for public health activities such as assisting public health authorities or other legal authorities to prevent or control disease, injury, or disability.
Health Oversight Activities:
Compass may use or disclose your health information for oversight activities authorized by law, including audits, civil, administrative or criminal investigations, or other activities necessary for appropriate oversight.
Compass may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.
Compass may use your personal health information for research purposes when a privacy board, that has reviewed the research proposal and established protocols to ensure the privacy of your health information, has approved the research.
Health and Safety:
Your health information may be disclosed to avert a serious threat to the health or safety of you or any other person pursuant to applicable law.
Your health information may be used or disclosed to carry out specialized government functions, such as protection of public officials, for national security, to correctional institutions, or to another agency administering a public benefits program.
Your health information may be used or disclosed in order to comply with the laws and regulations related to Worker’s Compensation.
Your health information may be disclosed to funeral directors or coroners to enable them to carry out their lawful duties.
Any Other Use and Disclosure:
Any use or disclosure of your personal health information other than referenced above, including psychotherapy notes, will require Compass to obtain your written authorization. You have the right to revoke any such authorization.
You have the following rights regarding the medical information we maintain about you:
Right to Inspect and Copy:
You have the right to inspect and copy medical information Compass maintains about you. To inspect and copy your medical information, please submit your request in writing to the HIPAA Compliance Officer at the address on the cover of this Notice. If you request a copy of this information, paper or electronic, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to inspect and copy in certain limited circumstances.
Right to Amend:
If you feel that the health information we maintain about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by Compass. Your request for an amendment must be submitted in writing to the HIPAA Compliance Officer at the address on the cover of this Notice.
We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:
Was not created by Compass, unless the person or entity that created the information is no longer available to make the amendment;
Is not part of the medical information kept by or for Compass;
Is not part of the information which you would be permitted to inspect and copy; or
Is accurate and complete.
Right to an Accounting of Disclosures:
You have the right to request an “accounting of disclosures”, if any such disclosure was made for any purpose other than treatment, payment, health care operations or certain other authorized disclosures.
To request an accounting of disclosures, you must submit your request in writing to the HIPAA Compliance Officer at the address on the cover of this Notice. Your request must state a time period, which may not be longer than six years and may not include dates before November 12, 2014.
Right to Request Restrictions:
You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, such as a family member or friend.
We are not required to agree to your request for restrictions. To request restrictions, you must submit your request in writing to the HIPAA Compliance Officer at the address on the cover of this Notice. In your request, you must tell us:
What information you want to limit;
Whether you want to limit our use, disclosure or both; and
To whom you want the limits to apply, for example, disclosures to your spouse.
Right to Request Confidential Communications:
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 can ask that we only contact you at home, at work, by mail, or by email.
To request confidential communication, you must submit your request in writing to the HIPAA Compliance Officer listed on the cover of this Notice. Where possible, we will accommodate all reasonable requests.
We are required by law to maintain the privacy and security of your protected health information.
Right to be notified of a Breach of Your Information:
You have the right to be notified following a breach of unsecured Protected Health Information that affects you.
Right to a Paper or Electronic Copy of This Notice:
You have the right to a paper copy of this Notice, even if you have agreed to receive this Notice electronically. You may obtain a copy of this Notice at our website at:
How to File a Complaint:
If you feel we have violated your rights you can notify us of your complaint in writing to the HIPAA Compliance Officer at the address on the cover of this Notice. Additionally, you can further file a complaint via the following methods:
U.S. Department of Health and Human Services Office for Civil Rights
200 Independence Avenue SW
Washington, DC 20201
You will not be penalized or retaliated against for filing a complaint.
Changes to the Terms of this Notice
Compass reserves the right to revise or change this Notice at any time. Any such revision will affect information we already have about you and any information we receive in the future. If there is any significant change in our privacy practices, this Notice will be changed and the new Notice will be mailed to you. This Notice is available upon request, in our office, and on our website.
Compass Innovative Behavior Strategies, LLC
℅HIPAA Compliance Officer
3 Robinson Road, Unit B-1
Bow, New Hampshire 03304