Privacy Rights | Authentic Self

Notice of Privacy Practices

Authentic Self Therapeutic Services, LLC

This notice describes how health information may be used and disclosed and how you (a client) can have access to this information. Under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), you have certain rights regarding the use and disclosure of your protected health information (PHI).

MY PLEDGE REGARDING HEALTH INFORMATION: Your trust is extremely important to me. Maintaining the privacy of your PHI is my commitment. Your confidential medical record file is the sole property of Hope Doucet, LMSW, and ASTS, LLC. I create a record of the care and services you receive from me. I keep this record to provide you with quality care and to comply with certain legal requirements. This notice will inform you how I may use and disclose your PHI. I describe your rights to the health information I keep about you and describe certain obligations I have regarding the use and disclosure of your PHI. I am required by law to: Make sure that PHI is kept private, give you this notice of my legal duties and privacy practices with respect to PHI, and follow the terms of the notice that is currently in effect. I can change the terms of this notice and such changes will apply to all information I have about you. This notice will be available upon request, in my office, and on my website. Confidentiality of your medical record is protected by federal laws and regulation. Your medical record is kept for seven years after termination of services after which it will be destroyed.

HOW I MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU: The following categories give examples of how I may use and disclose health information. Subject to certain limitations in the law I can use and disclose your PHI without your authorization for the following reasons: when disclosure is required by state or federal law and the use or disclosure complies with and is limited to the relevant requirements of such law. Not every use or disclosure will be listed for brevity.

Emergencies: I have a reason to believe that there is serious and imminent danger or the threat of danger to you or another person upon which I may contact your emergency contact, your health care provider, an emergency or crisis service line, or 911*.
Abuse and/or Neglect: I suspect a minor is subject to abuse and/or neglect as defined in the Michigan Child Protection Law upon which I will file a CPS report and may contact 911.
Billing: I must submit PHI to your insurance company for remission of payment for delivery of mental health services. I work with a medical biller for submission of claims. She will have access to some of your PHI necessary for remission of insurance claims.
Court-ordered: A law suit is filed or a court orders the release of your medical records
Health oversight: For audits and investigations

Whenever possible, if confidentiality must be breached due to any of the described scenarios, I will use my clinical discretion and may facilitate a discussion with you prior to disclosure so that the best strategy for all concerned can be determined.

Records and Record Keeping: I use a HIPAA-compliant EMR software, TherapyNotes, to store, keep, and maintain your medical record. TherapyNotes has several safety features to protect your personal information including advanced encryption techniques to make your personal information difficult to decode, firewalls to prevent unauthorized access, and a team of professionals monitoring the system for suspicious activity. TherapyNotes keeps records of all log-ins and actions within the system. Should you need access to your medical record, you must provide this request in writing. I will follow laws and guidelines for the disclosure of your medical record in accordance with the Michigan Mental Health Code, the Health Care Information Act of 1992, and Section 45 CR § 164.524 of the federal HIPAA Privacy Rule. These laws do not require me to disclose psychotherapy notes.

Under the provision of HIPAA your PHI is kept in two separate sets of records.

Your Clinical Record includes information about your reasons for seeking treatment, your diagnosis, your treatment plan, treatment reviews and summaries, progress notes for each visit, your medical and social history, your history of previous mental health treatment, records received from other providers, reports of colleague consultations, your billing records, reports or letters that have been sent to anyone about you including reports to your insurance carrier, your therapist-client services agreements, any authorizations which you have signed, and a form accounting for any disclosures made about you either with your authorization or as otherwise required by law.

Counseling Psychotherapy Notes may include the contents of our conversations, my analysis of those conversations, informal notes that I make to myself during our meetings, and reminders to myself of matters that I wish to pursue with you at a later date. These notes may also contain sensitive information that you reveal to me that is not required to be in your clinical record. These psychotherapy notes are kept separate from your clinical record. Psychotherapy Notes are not available to you and normally are not sent to anyone else, including your insurance companies. In the unusual event that I am ordered by law to disclose psychotherapy notes, your written, signed authorization would be required.

YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI: The right to request limits on uses and disclosures of your PHI. You have the right to ask me not to use or disclose certain PHI for treatment, payment, or health care operations purposes. I am not required to agree to your request, and I may say “no” if I believe it would affect your health care. You have the right to ask me to contact you in a specific way (for example, home, text message, or office phone) or to send mail to a different address, and I will agree to all reasonable requests. The right to see and get copies of Your PHI. Other than “psychotherapy notes” you have the right to get an electronic or paper copy of your medical record and other information that I have about you. Upon your request I will provide you with a copy of your record, or a summary of it, if you agree to receive a summary, within 30 days of receiving your written request. I may charge a reasonable, cost-based fee for doing so. The right to get a list of the disclosures I have made: you have the right to request a list of instances in which I have disclosed your PHI for purposes other than treatment, payment, or health care operations or for which you provided me with an authorization. I will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list I will give you will include disclosures made in the last seven years unless you request a shorter time. I will provide the list to you at no charge, but if you make more than one request in the same year, I will charge you a reasonable cost-based fee for each additional request. The right to correct or update your PHI: If you believe that there is a mistake in your PHI or that a piece of important information is missing from your PHI, you have the right to request that I correct the existing information or add the missing information. I may say “no” to your request, but I will tell you why in writing within 60 days of receiving your request. The right to get a paper or electronic copy of this notice: You have the right get a paper copy of this notice, and you have the right to get a copy of this notice by e-mail.

*Please note that it is not typical in my practice to suggest 911 contact in response to mental health needs.

Please see the "Resources" blog posting for a list of mental health crisis resources.

This notice went into effect on May 31st, 2022 and was updated on October 16th, 2022.