HIPAA Notice of Privacy Practices Uses and Disclosures of Protected Health Information (PHI)
Effective Date: July 1st, 2025
Revision Date: February 28th, 2026
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW.
This Notice of Privacy Practices describes how we may use and disclose your protected health information (PHI) to carry out treatment, payment, or health care operations and for other purposes that are permitted or required by law. “Protected health information” is your information such as demographics, other health conditions, and health care services.
Treatment: We will use and disclose your PHI to provide, coordinate, or manage your health care and any related services, which includes the coordination or management of your health care with a third party.
Payment: Your PHI will be used as needed to obtain payment for your health care services.
Healthcare Operations: We may use or disclose, as needed, your PHI to support the business activities of your physician’s practice. These activities include, but are not limited to, quality assessment activities, employee review activities, training of medical students, licensing, and conducting or arranging for other business activities.
We may use or disclose your PHI in the following situations without your authorization:
Required by Law
Public Health issues as required by law
Communicable diseases
Health Oversight
Abuse or Neglect
FDA requirements
Legal Proceedings
Law Enforcement
Coroners, Funeral Directors, and Organ Donation
Research
Criminal Activity
Military Activities and National Security
Workers’ Compensation
Incarcerated persons
Required Uses and Disclosures
Under the law, we must disclose to you and when required by the Secretary of the Department of Health and Human Services to investigate or determine our compliance with the requirements of Section 164.500 will be made only with your consent, authorization, or opportunity to object unless required by law.
Your Rights
The following is a statement of your rights with respect to your PHI:
Inspect and Copy: Under federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding; and PHI that is subject to law that prohibits access to PHI.
Request a Restriction: Your request must state the specific restriction requested and to whom you want the restriction to apply. Your physician is not required to agree to a restriction that you may request. If the physician believes it is in your best interest to permit use and disclosure of your PHI, your PHI will not be restricted. You then have the right to use another healthcare professional.
Confidential Communications: You have the right to request to receive confidential communications from us by alternative means or at an alternative location.
Amend: You may have the right to have your physician amend your PHI.
Accounting of Disclosures: You have the right to receive an accounting of certain disclosures we have made, if any, of your PHI.
Change of Notice: We reserve the right to change the terms of this notice and will inform you by mail of any changes. You then have the right to object or withdraw as provided in this notice.
Complaints: You may complain to us or to the Secretary of Health and Human Services if you believe your privacy rights have been violated by us. We will not retaliate against you for filing a complaint. We are required by law to maintain the privacy of, and provide individuals with, this notice of our legal duties and privacy practices with respect to PHI. If you have any objections to this form, please ask to speak with our HIPAA Compliance Officer in person or by phone at our main phone number.
Contact Information:
Attn: HIPAA Privacy Officer – Jasmine Crenshaw, LISW-S
3100 W. Central Ave., Suite 150 Toledo, Ohio 43606
Phone: 419-326-5090
Email: info@atanabh.com
U.S. Department of Health and Human Services Office of Civil Rights
200 Independence Avenue, S.W., Washington, D.C. 20201
Toll-Free: 1-877-696-6775 or visiting https://www.hhs.gov/hipaa/filing-a-complaint/index.html
Confidentiality
Confidentiality & Limits of Confidentiality of Mental Health, Alcohol & Drug Abuse Client Records
The confidentiality of client records maintained by this program is protected by federal laws and regulations. The limits of confidentiality include that the program may not say to a person outside the program that a client attends the program or disclose any information identifying a client UNLESS:
The client consents in writing;
The disclosure is allowed by a court order; or
The disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation.
Disclosure for Healthcare Operations
Suspected child or elderly abuse or neglect from being reported under State law to appropriate State or local authorities.
Any information about a crime committed by a client either at the program or against any person who works for the program or about any threat to commit such a crime.
Any threats to self or to others.
Violation of the Federal laws and regulations by a program is a crime. Suspected violations may be reported to the appropriate authorities in accordance with Federal regulations. Federal laws and regulations do not protect any information about a crime committed by a client either at the program or against any person who works for the program or about any threat to commit such a crime. Federal laws and regulations do not protect any information about suspected child or elderly abuse or neglect from being reported under state law to appropriate state or local authorities.
I understand that my records are protected under Federal Confidentiality regulations (42 U.S.C. 290dd-3 and 42 U.S.C. 290ee-3 for Federal laws and 42 CFR Part 2 for Federal regulations) published August 10, 1987, and cannot be disclosed without my written consent unless otherwise provided in the regulations. I understand that my medical record may contain information concerning my psychiatric, psychological, drug, or alcohol abuse, HIV/Acquired Immune Deficiency Syndrome (AIDS), and/or related conditions.
Group Confidentiality
To reinforce the feelings of closeness and willingness to share with others your feelings, thoughts, and consequences of your dependency, confidentiality is a must in group therapy. Use this as your golden rule: What is said in group, stays in group. To break this rule violates the trust of the total group and the effectiveness of group therapy is lost.
Guidelines
1. Group issues are not discussed with others outside your group.
2. Do not discuss group issues with your roommate unless he/she is in your group.
3. Do not discuss at any outside meetings or places where others may overhear you.
Your group providers have the same responsibilities for group confidentiality as you, with the exception that your providers share group issues and your participation in the group process with other staff members. This is a vital part of the staff team's approach to assist you in your recovery. The staff values your confidentiality so highly that anyone who breaks confidentiality - whether to another client of Atana Behavioral Health, LLC or to family, significant others, etc. may be subject to discharge from this program.
Confidentiality Policy
The following information is provided to assist you in your counseling experience at Atana Behavioral Health, LLC.
Counseling and treatment is a personal and confidential relationship between a clinician and an individual, group, or family.
We work from a team approach at Atana Behavioral Health, LLC. Therefore, there may be times when it is necessary for us to consult with other professional staff either individually or at our clinical team meetings in an effort to provide you with the highest consideration and quality. Our clinicians are all professionally licensed graduate student interns or clinicians working toward certification.
No information will be released from Atana Behavioral Health, LLC regarding counseling or consultation sessions without your expressed written consent. If you wish for information to be released to anyone, it will be necessary for you to complete a Release of Information form stipulating the professional to whom the information is being sent. The law stipulates that in the event of imminent danger to yourself or others, we must breach confidentiality. We must also act in accordance with any applicable state laws regarding mandatory disclosure of child, elder, or other abuse.
Professional Ethics
We adhere to the following professional Codes of Ethics:
American Counseling Association
National Association of Alcoholism and Drug Abuse Counselors
National Association of Social Workers
American Medical Association
Sexual intimacy with a patient is never appropriate. Atana Behavioral Health, LLC provides this information as required by the State of Ohio.
42 CFR part 2
This agency is considered a 42 CFR part 2 program and complies with all substance abuse confidentiality regulations in addition to other privacy laws, such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
Part 2 Programs are prohibited from disclosing any information that would identify a person as having or having had a SUD unless that person provides written consent, except in specific circumstances. Limited disclosure without a consent can only be made under the following circumstances.
The disclosure is made to medical personnel in a medical emergency [42 CFR § 2.51]
Child Abuse reporting [42 CFR § 2.12(c)(6)]
Crimes on program premises or against program personnel [42 CFR § 2.12(c)(5)]
Court ordered disclosures when procedures and criteria are met [42 CFR §§ 2.61-2.67]
When disclosures are made under the following circumstances the recipient is prohibited from redisclosing the information without consent, except under the following restricted circumstances:
Research: Researchers who receive patient identifying information are prohibited from redisclosing the patient-identifying information to anyone except back to the program [42 CFR § 2.52(b)].
Audits and Evaluations: Part 2 permits disclosures to persons and organizations authorized to conduct audits and evaluation activities, but imposes limitations by requiring any person or organization conducting the audit or evaluation to agree in writing that it will redisclose patient identifying information only (1) back to the program, or (2) pursuant to a court order to investigate or prosecute the program (not a patient), or (3) to a government agency that is overseeing a Medicare or Medicaid audit or evaluation [42 CFR § 2.53(c)(d)].
Qualified Service Organization Agreements (QSOAs): Part 2 requires the QSO to agree in writing that in receiving, storing, processing, or otherwise dealing with any information from the program about patients, it is fully bound by Part 2, it will resist, in judicial proceedings if necessary, any efforts to obtain access to information pertaining to patients except as permitted by Part 2, and will use appropriate safeguards to prevent the unauthorized use or disclosure of the protected information [42 CFR § 2.11]. In addition, QSOAs may allow disclosure in certain circumstances.
Authorizing Court Orders: When information is disclosed pursuant to an authorizing court order, Part 2 requires that steps be taken to protect patient confidentiality. In a civil case, Part 2 requires that the court order authorizing a disclosure include measures necessary to limit disclosure for the patient’s protection, which could include sealing from public scrutiny the record of any proceeding for which disclosure of a patient’s record has been ordered [42 CFR § 2.64(e)(3)]. In a criminal case, such an order must limit disclosure to those law enforcement and prosecutorial officials who are responsible for or are conducting the investigation or prosecution and must limit their use of the record to cases involving extremely serious crimes or suspected crimes. For additional information regarding the contents of court orders authorizing disclosure, see 42 CFR § 2.65(e).