Privacy Policy

This notice describes the practices of Northeast Kingdom Human Service (NKHS) and that of Any health care professional authorized to enter information into your health record.

Those who need to follow are:

• All divisions and programs of NKHS.

• Any volunteer we allow to help you while you are receiving services from NKHS.

• All employees, staff and other personnel.

All NKHS entities, sites and locations follow the terms of this notice. Staff members at these entities, sites and locations may share health information with each other for treatment, payment or operations purposes as described in this notice.

We understand that health information about you and your health is personal. We are committed to protecting your privacy and health information about you. We create a record of the care and services you receive at NKHS. We need this record to provide you with quality care and to comply with certain legal requirements.

This notice applies to all of the records of your care generated by NKHS, whether made by NKHS personnel or your personal doctor. Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your health information created in the doctor’s office or clinic.This notice will tell you about the ways in which we may use and disclose health information about you.

We also describe your rights and certain obligations we have regarding the use and disclosure of health information.We are required by law to:

• Make sure that health information that identifies you is kept private.

• Give you this notice of our legal duties and privacy practices with respect to health information about you.

• Follow the terms of the notice that is currently in effect.

• Notify you following a breach of your protected health information

• Comply with any State law that is more stringent or provides you greater rights than this notice.

The following categories describe different ways that we use and disclose health information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. For Treatment: We may use or disclose health information about you to provide you with treatment or services. This includes the potential sharing of information about you to doctors, nurses, clinicians, case managers, interns or other NKHS personnel, or to people outside of NKHS who are involved in your care.

For example, a clinician might be treating you for a mental health problem and need to talk with one of our psychiatrists or another clinician who has specialized training in a particular area of care. We may also disclose information about you to people outside NKHS who are involved in your health care.Electronic Exchange of Your Health Information: In some instances, we may transfer health information about you electronically to other health care providers who are providing you treatment or to the insurance plan providing payment for your treatment.

Your health information may also be made available through the Vermont Health Information Exchange (VHIE). The VHIE is a health information network operated by Vermont Information Technology Leaders (VITL), Inc. and your treating health care providers may only access your health information through the VHIE if you have provided specific written consent for their access, unless you are in need of emergency treatment. For information about the VITL, see www.vitl.net.

For Payment

We may use and disclose health information about you so that the treatment and services you receive at NKHS may be approved by, billed to, and payment collected from a third party such as an insurance company. For example, we may need to give your health plan information about counseling you received at NKHS so your health plan will pay us or reimburse you for a counseling session.

We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the service / treatment.For Health Care Operations:We may use and disclose health information about you for NKHS operations. These uses and disclosures are necessary to run NKHS and make sure that all individuals receiving services from us receive quality care. For example, we may use health information to review our treatment and services and to evaluate the performance of our staff in serving you.

We may also combine health information about many consumers to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, clinicians, case managers, interns and other NKHS personnel for review and learning purposes.We may also combine the health information we have with health information from other mental health agencies to compare how we are doing and see where we can make improvements in the services we offer.

We will remove information that identifies you from this set of health information so others may use it to study health care and health care delivery without learning who the specific consumers are.NKHS is a Vermont designated Community Mental Health Agency and is obligated under our contracts with various departments within the Vermont Agency of Human Services to provide certain services. As a result, these Departments may access health information related to these contracted services for the purpose of obtaining treatment for clients or making payment or for its health care operations. 

Appointment Reminders

We may use and disclose information to contact you as a reminder that you have an appointment.Alternative Treatment and Benefits and Services: We may use and disclose information about you in order to obtain and recommend to you other treatment options and available services as well as other health-related benefits or services.Fundraising Activities: Should the need arise where information about you or where your participation is desired for NKHS ‘ fundraising activities, NKHS would obtain your authorization. No information would be released for this purpose without your authorization.

Research

Under extremely limited circumstances, we may use and disclose health information for research purposes. For example, a research project may involve comparing the health and recovery of all consumers who received one medication to those who received another, for the same condition. All research projects are subject to a special approval process. This process evaluates a proposed research project and its use of health information, trying to balance the research needs with consumer’s need for privacy of their health information.

Before we use or disclose health information for research, the project will have been approved through this research approval process. We may, however, disclose health information about you to people preparing to conduct a research project; for example, to help them look for consumers with specific health needs, so long as the health information they review does not leave NKHS. We will always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at NKHS.

As Required by Law

We will disclose medical information about you when required to do so by federal, state or local law. In Vermont, this would include: victims of child abuse; the abuse, neglect or exploitation of vulnerable adults; or where a child under the age of sixteen is a victim of a crime; and firearm-related injuries. Under certain circumstances, the Departments within the Vermont Agency of Human Services who we contract with are mandated to access health information in order to carry out their responsibilities.

To Avert a Serious and Imminent Threat to Health or Safety

We may use and disclose health information about you when necessary to prevent a serious and imminent threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.

Special Situations

• Military and Veterans: If you are a member of the armed forces, we may release health information about you as required by military command authorities.

• Workers’ Compensation: We may release health information about you as authorized for worker’s compensation or similar programs as authorized by Vermont law. These programs provide benefits for work-related injuries or illnesses.

• Public Health Risks: We may disclose health information about you for public health activities. These activities generally include the following:

• Prevent or control disease, injury or disability.

• Report deaths

• Report child abuse or neglect

• Report abuse, neglect or exploitation of vulnerable adults; any suspicion of abuse, neglect, or exploitation of the elderly (age 60 or older); or a disabled adult with a diagnosed physical or mental impairment.

• Report reactions to medications or problems with products

• Notify individuals of recalls of products they may be using

• Notify an individual who may have been exposed to a disease or may be at risk for contracting or spreading a communicable disease or condition

Health Oversight Activities

We may disclose health information to a health oversight agency, such as the Vermont Agency of Human Services Departments who we contract with, for activities authorized by law. These oversight activities include, but are not limited to, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Legal Proceedings and Disputes

If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court order.

Public Health Officials and Funeral Home Directors

We may release information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release health information to funeral directors thereby permitting them to carry out their duties.

Individuals in Custody

If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release health information about you to the correctional institution or law enforcement official pertaining to care provided while you are in custody.

This release would be necessary:

(1) for the institution to provide you with health care;

(2) to protect your health and safety or the health and safety of others; or

(3) for the safety and security of the correctional institution.

Any assistance (physical, communicative, etc.) you need to exercise your rights will be provided to you by NKHS.

You have the following rights regarding information we maintain about you:

Right to Review and Copy

You have the right to review and copy health information that may be used to make decisions about your care. This may include both health and billing records.To review and copy health information that may be used to make decisions about you, you must submit your request in writing to our Records Department. If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request. If you seek an electronic copy in a specific form or format of any portion of your electronic health record, and NKHS is unable to readily produce the copy in that form or format, we will work with you to provide an alternative form or format for the electronic copy.

We may deny or limit access to your request to inspect and copy in certain very limited circumstances. If you are denied or limited access to health information, you may request that the decision be reviewed. Another health care professional chosen by NKHS will review your request and the denial.

The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.

If you feel that the health information we have 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 or for NKHS.To request an amendment, your request must be made in writing and submitted to our Records Department. In addition, you must provide a reason that supports your request.

We may deny your request for an amendment if it is not in writing or does not include a reason to support that request.

In addition, we may deny your request if you ask us to amend information that:

• Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;

• Is not part of the designated record set kept by or for NKHS;

• Is not part of the information which you would be permitted to inspect and copy; or

• Was determined accurate or complete by NKHS.

You have the right to request an “accounting of disclosures.” This is a list of the disclosures we made of health information about you which were required by law and/or were not authorized by you.

To request this list or accounting of disclosures, you must submit your request in writing to our Records Department. Your request must state a time period, which may not be longer than six years. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment or health care operations. We are not required to agree to your request unless your request is to limit disclosures to a health plan for the purpose of carrying out payment or health care operations that are not otherwise required by law and you or someone on your behalf other than your health plan has paid for those services in full at the time the health services are provided. However, if we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.

You also have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for your care, like a family member. For example, you could ask that we not use or disclose information about a counseling session you received.

To request restrictions, you must make your request in writing to our Records Department. In your request, you must tell us:

(1) what information you want to limit;

(2) whether you want to limit our use, disclosure or both; and

(3) to whom you want the limits to apply, for example, disclosures to your spouse.

You have the right to request that we communicate with you about health matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to our Records Department. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

You have the right to a paper copy of this notice. You may ask us to give you a copy of the current notice at any time.

To obtain a paper copy of this notice, contact NKHS Privacy Officer at (802) 334-6744. Security of Health Information: We have in place appropriate safeguards to protect and secure the confidentiality of your health information. Due to the nature of community based human service practices, NKHS representatives may possess your health information outside of NKHS. In these cases, NKHS representatives will ensure the security and confidentiality of the information in a manner that meets NKHS policy, State and Federal Law.

A covered entity that maintains a web site which provides information about the covered entity’s customer services or benefits must prominently post its notice on the web site and make the notice available electronically through the web site.

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for health information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in all NKHS facilities. The notice will contain an effective date. Should we make a material change to this notice, we will, prior to the change taking effect, publish an announcement of the change at every NKHS facility.

If you believe your privacy rights have been violated, you may file a complaint with NKHS or with the Secretary of the Department of Health and Human Services. To file a complaint with NKHS, call (802) 334-6744 and ask to speak with our Privacy Officer. All complaints must be submitted in writing.Complaint forms are available at each location including the reception area at NKHS’ main offices. You will not be penalized for filing a complaint.The Secretary of the Department of Health and Human Services can be contacted through their regional office at Office of Civil Rights, U.S. Department of Health and Human Services, Government Center, J.F. Kennedy Federal Building – Room 1875, Boston, Massachusetts 02203, voice phone (800) 368 1019, fax(617) 565-3809, TDD (800) 537 7697.