Isaly Counseling Associates

HIPAA Privacy Policy
April 14, 2003

I..     Policy Statement
It is the policy of Isaly Counseling Associates (ICA) to inform individuals about Isaly Counseling Associates privacy practices as they relate to health information that may be stored in any ICA file or depository, or stored electronically or that exists in any recording device or in any clinical or research data base, hereafter collectively referred to as the "health record" to safeguard health information in ICA's possession, and, to the extent practicable, to protect the communication of health information, including oral information, from intentional or unintentional use or disclosure.  It is further ICA's policy to accommodate, to the extent practicable, the requests of individuals regarding the place, time, and method of communicating to them their own health information.

II.     Policy Purpose
The purpose of this policy is to assure that all individuals are provided with adequate notice of ICA's privacy practices and that ICA employees treat health information to which they have access and the communication of that health information, whether in oral, written or electronic form, with confidentiality within ICA as well as when communicating health information to individuals outside ICA, including to the individuals themselves.

III.    Policy Standards
Consumers, including those who are participants in treatment-oriented research and from whom protected health information will be obtained will be provided the Notice of Privacy Practices and a good faith effort made to receive an acknowledgement of such receipt prior to the date of the first service delivery.  ICA will not knowingly use or disclose health information in a manner inconsistent with its privacy notice, except to the extent that emergency patient care would be compromised.  ICA reserves the right to amend the Notice of Privacy Practices as deemed necessary or advisable and, tot he extent and in a manner practicable, will inform patients of material changes to the notice.  This Notice of Privacy Practices constitutes an official privacy policy of ICA and may not be amended, or otherwise altered, without the approval of an ICA authorized official.

Health information that is communicated in any form is to be treated as confidential and in a manner that reasonably protects the communication from being intentionally or unintentionally overheard or intercepted by those who do not have a need or right to know the information.

ICA recognizes that in the counseling setting, communications must occur freely and quickly and there can be no assurance of absolute privacy.  It is also recognized that the physical layout of the counseling area impacts the degree of confidentiality that may be achieved.  However, it is the responsibility of each Provider to implement procedures to achieve a reasonable degree of confidentiality within their respective areas and to establish operating policies and procedures that reasonably protect the confidentiality of oral, written and electronic communications.

Written communications that include identifiable health information, medical charts, files, electronic storage devices, fax machines, and other electronic equipment over which protected health information may be received or transmitted are to be maintained in secure sites and/or away from public access. Computer screens containing protected health information are to be inaccessible to public view.  Computers that store protected health information are to be secured before being left unattended.

Protected health information stored in computers is to be password protected.  Passwords are individual specific and are not to be shared by or accessible to more than one individual.

To the extent practicable, ICA will accommodate the written request of an individual to have their health information communicated to them at a time, place, and in a manner of their choosing.  If the request is impractical or impossible for ICA to accommodate, this will be clearly communicated to the individual requesting the accommodation.

ICA will recognize personal representatives authorized by our consumers, by the courts, or by state law for purposes of communicating health information.  Personal representatives may be parents or legal guardians or minor children or persons who are legally authorized or specifically identified by the patient themselves, such as a close friend or family member to act on behalf of the patient, ICA may, without prior authorization of the consumer, and where necessary due to emergency or other professionally sound reason, communicate health information with persons directly involved in the care of a consumer.  ICA may also refuse to provide information to personal representatives, or to the consumer themselves, where it is detrimental to or otherwise not in the best interest of the consumer, may endanger or breach the confidentiality of the third party or is precluded by statute.

Violation of this policy or negligence on behalf of any ICA staff member resulting in or having the potential to result in the unauthorized  release of identifiable health information may result in disciplinary action up to and including termination of employment.

For questions about this Privacy Notice please contact:
Isaly Counseling Associates
4721 McKnight Road
Suite 218 S
Pittsburgh, PA  15237

Published - April 14, 2003