Notice of Privacy Practices - Venture Together

Effective Date: October 25, 2023

Regulatory Reference: Privacy Rule — 45 CFR § 164.520

THIS NOTICE DESCRIBES HOW YOUR MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Venture Together, Inc. is required by law to provide you with this Notice so that you will understand how we may use or share information from your Designated Record Set. The Designated Record set includes financial and health information referred to in this Notice as “Protected Health Information” (“PHI*) or simply “Health Information. We are required to adhere tothe terms outlined ni this Notice. If you have any questions about this Notice, please contact:

Privacy Officer, Venture Together Compliance & QA Department 845-624-5407
compliance@campventure.org

UNDERSTANDING YOUR HEALTH RECORD AND INFORMATION

The Standards for Privacy of Individually Identifiable Health Information (“Privacy Rule“) protects all individually identifiable information held or transmitted by a covered entity or its business associate, in any form of media, whether electronic, paper, or oral.

Upon your admission to a Venture Together program, a record is made containing your health and financial information. Typically, this record contains information about your physical and mental health; demographics about you such as your Name, Social Security Number, address, date of birth, sex; services and/or treatment we provide and payment for such services. We may use and/or disclose this information to:

Plan your care and treatment;
Communicate with health professionals involved in your care;
Document the care and services you receive;
Educate health professionals;
Provide information to public health officials;
Evaluate and improve the care we provide;
Obtain payment for the care we provide.

This Notice applies to all of the records of your care generated by Venture Together.

This Notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.

Understanding what is in yourrecord and how your healthinformation is used helps you to:

Ensure it is accurate;
Better understand who may access your health information
Make more informed decisions when authorizing disclosure to others.

OUR OBLIGATIONS TO YOU

We are required by law to:

make sure that medical information that identities you is kept private except as otherwise provided by state or federal law;
give you this Notice of our legal duties and privacy practices with respect to medical information about you; and
follow the terms of the Notice that is currently in effect.

HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU

The following categories describe the ways that we use and disclose health information. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall into one of the categories.

1. To the individual. We may disclose your health information to you.

2. Treatment, Payment, Business Operations.

Treatment. We may use and disclose your health information within the Agency to provide treatment, services, receive payment, and business-related activities. A healthcare professional at our agency may share your health information with another healthcare professional inside our agency, or with a health care professional at another agency, to determine how to diagnose or treat you. Your healthcare professional may also share your health information with another agency or provider to whom you have been referred for further healthcare.
Payment. We may use your health information or share it with others so that we obtain payment for your healthcare services. For example, we may share information about you with your health insurance company in order to obtain reimbursement after we have provided services to you. In some cases, we may share information about you with your health insurance company to determine whether it will cover your services. We might also need to inform your health insurance company about your health condition in order to obtain pre-approval for your services, such as care provided at a residential treatment facility. Finally, we may share your health information with other providers and payers for their payment activities.
Business Operations. We may use your health information or share it with others in order to conduct our normal business operations. For example, we may use your health information to evaluate the performance of our staff in caring for you or to educate our staff on how to improve the care they provide for you. We may also share your health information with another company that performs business services for us, such as billing companies. If so, we will have a written contract to ensure that this company also protects the privacy of your health information. Finally, we may share your health information with other providers and payers for certain of their business operations if that other party also has or had a treatment or payment relationship with you, and in that event, we will only share information that pertains to that relationship.

3. Uses and Disclosures with Opportunity to Agree or Object.

We may obtain informal permission from you verbally or by circumstances that give you the opportunity to agree, acquiesce, or object to uses and disclosures of your health information. If you are incapacitated, in an emergency situation, or not available, we will make such uses and disclosures if, in the exercise of professional judgment, the use or disclosure is determined to be in your best interest. We may also rely on your informal permission to disclose to your family, relatives, or friends, or to other persons with whom you identify, health information directly relevant to their involvement in your care or payment for care.

4. Incidental Disclosures.

While we will take reasonable steps to safeguard the privacy of your health information, certain disclosures of your health information may occur during, or as an unavoidable result of, our otherwise permissible uses or disclosures of your health information. For example, during the course of a treatment session, another service recipient in the treatment area sees or overhears a discussion of your health information.

5. Public Interest and Benefit Activities.

We may use and disclose your health information without your authorization or permission, for national priority purposes, under specific conditions or limitations.

These purposes include:

1. Required By Law. We may use and disclose your health information as required by law (including by statute, regulation, or court order).

2. Public Health Activities. We may disclose your health information to:

a. Public health authorities authorized by law to collect or receive such information for preventing or controlling disease, injury, or disability and to public health or other government authorities authorized to receive reports of child abuse and neglect.

b. We may disclose your health information to a person or company that is required by the Food and Drug Administration to: (1) report or track product defects or problems; (2) repair, replace, or recall defective or dangerous products; or (3) monitor the performance of a product after it has been approved for use by the general public.

c. Individuals who may have contracted or been exposed to a communicable disease when notification is authorized by law.

d. Employers regarding employees, when requested by employers, for information concerning a work-related illness or injury in the workplace related to medical surveillance, because such information is needed by the employer to comply with the Occupational Safety and Health Administration (OSHA) or similar state law.

3. Victims of Abuse, Neglect or Domestic Violence. In certain circumstances, we may disclose health information to appropriate government authorities regarding victims of abuse, neglect, or domestic violence.

4. Health Oversight Activities. We may disclose your health information to government agencies authorized to conduct audits, investigations, and inspections of our facility. These government agencies monitor the operation of the health care system, government benefit programs such as Medicare and Medicaid, and compliance with government regulatory programs and civil rights laws.

5. Judicial and Administrative Proceedings. We may disclose your health information in a judicial or administrative proceeding if the request for information is through an order from a court or administrative tribunal. Such information may also be disclosed in response to a subpoena or other lawful process if certain assurances regarding notice to the individual or a protective order are provided.

6. Law Enforcement Purposes. We may disclose your health information to law enforcement officials for the following reasons:

as required by law (including court orders, court-ordered warrants, subpoenas) and administrative requests.
to identify or locate a suspect, fugitive, material witness, or missing person.
in response to a law enforcement official’s request for information about a victim or suspected victim of a crime.
to alert law enforcement of your death if we suspect that criminal activity was involved in the cause.
when the agency believes your personal health-related information is evidence of a crime that occurred on the agency’s premises.
by a covered health care provider in a medical emergency not occurring on the agency’s premises, when necessary to inform law enforcement about the commission and nature of a crime, the location of the crime or crime victims, and the perpetrator of the crime.

7. Decedents. We may disclose health information to funeral directors as needed, and to coroners or medical examiners to identify a deceased person, determine the cause of death, and perform other functions as authorized by law.

8 Cadaveric Organ, Eye, or Tissue Donation. In the unfortunate event of your death, we may use or disclose your health information to facilitate the donation and transplantation of cadaveric organs, eyes, and tissue.

9. Research. We will request that you sign a written authorization before using your protected health information or disclosing it to others for research purposes.

10. Serious Threat to health or safety. We may disclose your health information when necessary to prevent or lessen a serious or imminent threat to you or the public. In such cases, we will only share your information with someone able to help prevent or lessen the threat. We may also disclose your health information to law enforcement if the information is needed to identify or apprehend an escapee or violent criminal.

11. Workers’ Compensation. We may disclose your health information as authorized by, and to comply with, workers’ compensation laws and other similar programs providing benefits for work-related injuries or illnesses.

OTHER AUTHORIZED USES and DISCLOSURES

Authorization. Other uses and disclosures of health information not covered by this Notice or the laws that apply to venture together will be made only with your written authorization. If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care and services that we provided to you.

Fundraising. Venture Together may use or disclose protected health information for fundraising purposes. If you receive a fundraising request from Venture Together, or on our behalf, you may opt out of future fundraising communications. To opt out of fundraising communications, you may either call the Privacy Officer at 845-624-5407 or email your request to compliance@campventure.org.

Psychotherapy Notes. Venture Together must receive written authorization from you to use or disclose psychotherapy notes with the following exceptions:

Notes that originated at Venture Together may be used by the agency to provide treatment and services.
We may use or disclose psychotherapy notes for our own training, and to defend the agency in legal proceedings brought by you, for HHS to investigate or determine the agency’s compliance with the Privacy Rules, to avert serious and imminent threat to public health or safety, to a health oversight agency for lawful oversight of the originator of the psychotherapy notes, for the lawful activities of a coroner or medical examiner has required by law.

YOUR RIGHTS REGARDING HEALTH INFORMATION ABOUT YOU

Although your health record is the property of Venture Together, the information belongs to you. You have the following rights regarding your health information:

1. Right to Inspect and Copy

With some exceptions, you have the right to review and copy your health information. Your request in writing to:

Venture Together, Inc.

Compliance & QA Department
25 Smith Street, Suite 510
Nanuet, NY 10934

2. Right to Amend

If you feel that health information in your record is incorrect or incomplete, you may ask us to amend the information. You have this right for as long as the information is kept by or for the agency. You must submit your request in writing to:

Venture Together, Inc.
Compliance & QA Department
25 Smith Street, Suite 310
Nanuet, NY 10954

In addition, you must provide a reason for your request. 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 Venture Together unless the person or entity that created the information is no longer available to make the amendment.
Is not part of the health information kept by or for Venture Together.
Is accurate and complete.

3. Right to an Accounting of Disclosures

You have the right to request an “accounting of disclosures.” This is a list of certain disclosures we made of your health information, other than those made for the purposes such as treatment, payment, or business operations. You must submit your request in writing to:

Venture Together, Inc.
Compliance & QA Department
25 Smith Street, Suite 510
Nanuet, NY 10954

Your request must state a time period which may not be longer than six years from the date the request is submitted. Your request should indicate in what form you want the list (for example, on paper or electronically). The first list you request within a twelve-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 before any costs are incurred.

4. Right to Request Restrictions

You have the right to request a restriction or limitation on the health information we use or disclose about you. For example, you may request that we limit the health information we disclose to someone who is involved in your care or the payment for your care. You could ask that we not use or disclose information about a surgery you had to a family member or friend.

We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment.

You must submit your request in writing to:

Venture Together, Inc.
Compliance & QA Department
25 Smith Street, Suite 510
Nanuet, NY 10954

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.
3. To whom you want the limits to apply, for example, disclosures to a family member or friend.

5. Right to Request Alternate Communications

You have the right to request that we communicate with you about medical matters in a confidential manner or at a specific location. For example, you may ask that we only contact you via mail to a post office box. You must submit your request in writing to:

Venture Together, Inc.
Compliance & QA Department
25 Smith Street, Suite 510
Nanuet, NY 10954

We will not ask you the reason for your request. Your request must specify how or where you wish to be contacted. We will accommodate all reasonable requests.

6. Right to a Paper Copy of This Notice

You have the right to a paper copy of this Notice of Privacy Practices even if you have agreed to receive the Notice electronically. You may ask us to give you a copy of this Notice at any time.

You may obtain a copy of this notice on our website: www.venturetogetherny.org. For a paper copy, please contact your program director.

CHANGES TO THIS NOTICE: We reserve the right to change this notice, with the revisions becoming effective for both existing health information and any received in the future. The current notice will be posted in the facility and on the website, specifying the effective date on the first page in the top right-hand corner. If material changes occur, the notice will include an effective date for the revisions, and copies can be obtained by contacting the program director.

COMPLAINTS: If you believe your privacy rights have been violated, you can file a complaint with Venture Together or the United States Department of Health and Human Services (HHS). To file a complaint with Venture Together, contact:

Chief Compliance Officer
Venture Together, Inc.
25 Smith Street, Suite 310
Nanuet, NY 10954
Phone: 843-624-3407
Confidential Compliance Hotline: 845-624-4039
Email: compliance@campventure.org

Venture Together, Inc. prohibits any retaliation, intimidation, and/or retribution for filing a complaint.

To file a complaint with the Department of HHS, mail or email your complaint to:

Centralized Case Management Operations
U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Room 509F HHH Bldg.
Washington, D.C. 20201
Email: OCRMail@hhs.gov
OCR Complaint Portal: https://ocrportal.hhs.gov/

Phone: U.S. Department of Health and Human Services, Office for Civil Rights toll-free at 1-800-368-1019, TDD: 1-800-537-7697

NOTE: This notice is available in other languages upon request.