Life Coaching By Phone and Confidentiality

Your privacy is legally protected in the life coaching relationship.  The conditions under which it is my legal responsibility to share certain information with others without your consent is clarified in the Informed Consent page under “forms”.  Briefly, these conditions are: if you are a danger to yourself or others, you report child or elder abuse, or if your records are subpoenaed by a court.  I have never had my records subpoenaed in 20 years of private practice. That is usually called for only in extreme cases such as suspected murder or terrorism. 

The telephonic life coaching may have some additional limits to confidentiality. For instance someone may find out your have sought counseling by viewing your phone records or your cell phone history.  The e-mails I typically send to recap the session may be accessed by someone given permission to use your computer.  I will send your recap by mail if you wish or not send it at all.  There is a place on the Informed Consent to check those communication modalities which are permitted by you. 

My computer is accessible only to me with a secure pass code.  My hard copy files are locked in a file drawer.  You have access to everything that is in your file (as guaranteed by HIPAA) at your request. The file contains the paperwork you fill out and send or e-mail me, including intake forms, homework sheets, assessments, and recaps that I generate. 

HIPAA Notice of Privacy Practices

The Federal Health Insurance Portability and Accountability Act (HIPAA) was passed in 1996. I am covered by HIPAA because I use electronic form to transmit health care information to you via the forms you send to me and the e-mail recap I send to you. Many parts of HIPAA do not apply if I am not communicating with your insurance company.  HIPAA requires that I give you this notice of my privacy practices.  It describes how your information may be used and disclosed and how you can obtain that information.  My Informed Consent states most of the important information that you need to know.

Legally I must safeguard your protected health information (PHI) which includes any information that could reasonably identify you as a client, including data about your health condition, the services I provide and the payment for those services.  Use of your PHI applies to the examining, analyzing, sharing, or utilizing of information within my practice and disclose refers to the transfer of that information to a third party outside my practice. 

Under HIPAA, I may use and disclose your PHI without your consent for the following reasons:

1. For treatment:  I may disclose your PHI to physicians, psychiatrists, psychologist and other licensed health care providers who are involved with your care. This will be to coordinate care. Unless you are unable to give it, I will always get your written permission for this disclosure.
2. For health care operations:  I may disclose your PHI for efficient operation of my practice.  For example, I may use it to evaluate my performance or to make sure I am in compliance with applicable laws. 
3. To obtain payment for treatment:  I may use or disclose your PHI to bill and collect payment for services I provide.  I have no knowledge about or control over what happens to your PHI once it has been release to an insurance company. If you choose to use your medical benefits, I am obligated to supply them with your PHI. 
4. When disclosure is required by federal, state, or local law.
5. If disclosure is compelled or permitted by the fact that you are in such a mental or emotional condition as to be dangerous to yourself or the person or property of others, and I determine that disclosure is necessary to prevent the threatened danger.
6. If disclosure is mandated by the child abuse/neglect reporting laws or the elder/dependent adult abuse reporting laws of your state:  If I have a reasonable suspicion that abuse or neglect has occurred, I must report. 
7. For Public Health activities:  For example in the prevention and control of disease, including communicable disease. 
8. If disclosure is required by the Arizona Board of Behavioral Health Examiners as a result of a complaint or investigation.
9. If a lawsuit is filed against me:  PHI may be disclosed as part of my defense in court.
10.  For Workers’ Compensation:  HIPAA privacy regulations do not apply to services provided under Workers’ Compensation Insurance.
11. Appointment reminders and health related benefits or services. I may use your PHI to provide appointment reminders or give you information about other treatment options.
12. If an arbitrator or arbitration panel compels disclosure when arbitration is lawfully requested by either party, pursuant to subpoena or any other provisions authorizing disclosure.
13. If disclosure is required or permitted to a health oversight agency for oversight activities authorized by law. 

Disclosures to family, friends, or others:
I may provide your PHI to a family member, friend or other individuals that you wish to be involved in your care or responsible for the payment of your health care.  You have the right to object in whole or part and I will reasonably comply.  Retroactive consent may be obtained in emergency situations. 

Written Authorization:  Even if you have signed an authorization to disclose your PHI, you may later revoke that authorization, in writing to stop any future disclosures.

Your rights concerning your PHI:

1. You have the right to see and get copies of your PHI.  The only copies in your file will be those forms you complete and the e-mail I send you recapping our session. Occasionally I will complete some forms assessments.  You may request your information in writing and I will respond within 30 days.  If I must deny your request, I will give you reasons for the denial in writine. 
2. You have the right to ask that I limit how I use and disclose you PHI.  I am not legally bound to comply but I will always consider your request and give you the limits in writing. 
3. You have the right to ask that your PHI be sent to you at an alternate address or by an alternate method. 
4. You are entitled to a list of the disclosures of your PHI that I have made.  This will not include disclosures that you have authorized, nor may it include disclosures made for the purpose of national security or to corrections or law enforcement.  I will respond to your request within 60 days of receiving it.  The list will include the date of the disclosure, to whom it was disclosed, a description of the information and the reason for the disclosure.
5. You have the right to amend your PHI.  If you believe there is an error in your PHI, you have the right to request that I correct information or add missing information.  Your request for this amendment just be made in writing and I will respond within 60 days. I may deny your request if I find that the PHI is complete and correct or may not be disclosed. My written denial must explain my reasons for the denial and explain your right to file a written objection.  If you do not file a written objection, you still have the right to ask that your request and my denial be attached to any future disclosures.  If I agree to make changes to your PHI, I will also advise all others who need to know that the changes have been made. 

How to complain about my privacy practices:

If you feel I have violated your privacy rights or if you object to a decision I have made about access to your PHI, you are entitled to file a complaint.  You may do so directly to me at the following address:  351 Farallon Dr., Lake Havasu City, AZ 86403 as I am the Privacy Officer for my practice.  Additionally, you may also file a complaint with the Secretary of the Department of Health and Human Services in the state of Arizona or send a written complaint to the Secretary of the Department of Health and Human Services at 200 Independence Avenue S.W. Washington D.C. 20201.  If you file a complaint, I will take no retaliatory caction against you. If you have questions about this notice, complaints or would like to know how to file a complaint, please contact me by e-mail or phone.

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