Please read carefully through the Privacy Practices and Office Policies. At the time of your appointment you will be asked to sign a form indicating that you have reviewed the policies.


Policies and Disclosures

Office Policies & General Information Agreement for Psychotherapy Services or Informed Consent for Psychotherapy

CONFIDENTIALITY: All information disclosed within sessions and the written records pertaining to those sessions are confidential and may not be revealed to any- one without your written permission except where disclosure is required by law.

WHEN DISCLOSURE IS REQUIRED OR MAY BE REQUIRED BY LAW: Some of the circumstances where disclosure is required or may be required by law are: where there is a reasonable suspicion of child, dependent, or elder abuse or neglect; where a client presents a danger to self, to others, to property, or is gravely disabled; or when a client's family members communicate to Karla Townsend LCMHC that the client presents a danger to others. Disclosure may also be required pursuant to a legal pro- ceeding by or against you. If you place your mental status at issue in litigation initiated by you, the defendant may have the right to obtain the psychotherapy records and/ or testimony by Karla Townsend LCMHC. In couple and family therapy, or when different family members are seen individually, even over a period of time, confidentiality and privilege do not apply between the couple or among family members, unless otherwise agreed upon. Karla Townsend LCMHC will use his/her clinical judgment when revealing such information. Karla Townsend LCMHC will not release records to any outside party unless she is authorized to do so by all adult parties who were part of the family therapy, couple therapy or other treatment that involved more than one adult client.

EMERGENCY: If there is an emergency during therapy, or in the future after termi- nation, where Karla Townsend LCMHC becomes concerned about your personal safety, the possibility of you injuring someone else, or about you receiving proper psychiatric care, she will do whatever she can within the limits of the law, to prevent you from in- juring yourself or others and to ensure that you receive the proper medical care. For this purpose, she may also contact the person whose name you have provided on the biographical sheet.

HEALTH INSURANCE & CONFIDENTIALITY OF RECORDS: Disclosure of confidential information may be required by your health insurance carrier or HMO/ PPO/MCO/EAP in order to process the claims. Only the minimum necessary infor- mation will be communicated to the carrier. Karla Townsend LPC has no control over, or knowledge of, what insurance companies do with the information she submits or who has access to this information.

LITIGATION: Sometimes patients become involved in litigation while they are in therapy or after therapy has been completed. Sometimes patients (or the opposing attorney, in a legal case) want the records disclosed to the legal system. Due to the nature of the psychotherapeutic process and the fact that it often involves making a full disclosure with regard to many matters, clients’ records are generally confidential and private in nature. Patients should know that very serious consequences can result from disclosing therapy records to the legal system. Such disclosures may negatively affect the outcome of custody disputes or other legal matters and may negatively affect the therapeutic relationship. If you or the opposing attorney are considering re- questing Karla Townsend’s disclosure of the records will do his/her best to discuss with you the risks and benefits of doing so. As noted in this document, you have the right to review your own psychotherapy records anytime. (See also relevant section above: "WHEN DISCLOSURE IS REQUIRED OR MAY BE REQUIRED BY LAW")

CONSULTATION: Karla Townsend LCMHC consults on occasion with other professionals regarding her clients; however, each client's identity remains completely anonymous and confidentiality is fully maintained.

E–MAILS, CELL PHONES, COMPUTERS, AND FAXES: It is very important to be aware that computers and unencrypted email, texts, and e-faxes communication (which are part of the clinical records) can be relatively easily accessed by unautho- rized people and hence can compromise the privacy and confidentiality of such com- munication. Emails, texts, and e-faxes, in particular, are vulnerable to such unautho- rized access due to the fact that servers or communication companies may have un- limited and direct access to all emails, texts and e-faxes that go through them. While data on Karla Townsend LCMHC’s laptop is encrypted, emails, texts and e-fax are not. It is always a possibility that e-faxes, texts, and email can be sent erroneously to the wrong address and computers. Karla Townsend LCMHC’s laptop is equipped with a fire- wall, a virus protection and a password, and she backs up all confidential information from her computer on a regular basis onto an encrypted server called Carbonite. Please notify Karla Townsend LCMHC if you decide to avoid or limit, in any way, the use of email, texts, cell phones calls, phone messages, or e-faxes. If you communicate confidential or private information via unencrypted email, texts or e-fax or via phone messages, Karla Townsend LCMHC will assume that you have made an informed decision, will view it as your agreement to take the risk that such communication may be intercepted, and she will honor your desire to communicate on such matters.

RECORDS AND YOUR RIGHT TO REVIEW THEM: Both the law and the stan- dards of Karla Townsend LPC profession require that she keep treatment records for at least 7 years. Unless otherwise agreed to be necessary, Karla Townsend LCMHC retains clinical records only as long as is mandated by North Carolina law. If you have concerns regarding the treatment records, please discuss them with Karla Townsend LCMHC. As a client, you have the right to review or receive a summary of your records at any time, except in limited legal or emergency circumstances or when Karla Townsend LCMHC assesses that releasing such information might be harmful in any way. In such a case, Karla Townsend LCMHC will provide the records to an appropriate and legitimate mental health professional of your choice. Considering all of the above exclusions, if it is still appropriate, and upon your request, Karla Townsend LCMHC will release information to any agency/person you specify unless Karla Townsend LCMHC assesses that releasing such information might be harmful in any way. When more than one client is involved in treatment, such as in cases of couple and family therapy, Karla Townsend LCMHC will release records only with signed authorizations from all the adults (or all those who legally can authorize such a release) involved in the treatment.

TELEPHONE & EMERGENCY PROCEDURES: If you need to contact Karla Townsend LCMHC between sessions, please leave a message at 336 905 0378 and your call will be returned as soon as possible. Karla Townsend LCMHC checks her messages a few times during the daytime only, unless she is out of town. If an emergency situation arises, indicate it clearly in your message and if you need to talk to someone right away call 911 or go to your nearest Emergency Care Facility.

***PAYMENTS & INSURANCE REIMBURSEMENT: Payment is required within 24 hours of receiving a Square Up invoice and may be re- imbursed using your credit card via the Square Up invoice, or by using your credit card or health savings card via the online medical services payment website Instamed, for which instructions will be provided, or by check made out to Karla Townsend PLLC. Insurance claims are submitted to those insurance companies with which we have a contract and for which we have authorization for your care. However, you need to be aware of the provisions of your insurance policy...this is a contract between you and your insurance carrier. Please be aware that you are ultimately responsible for the timely payment of your account including all balances not paid by your insurance company. A $30.00 fee will be charged for any returned check. We reserve the right to charge balances 30 days past due a 1.5% monthly service charge (18% per year) unless pri- or arrangements have been made with your therapist. For any account that is 90 days overdue, we reserve the right to send those accounts to collections in addition to adding a collections fee to the balance due.

Please be advised any unpaid balance for more than $150.00 may result in the inability to schedule any follow up appointments until the balance is zero.

Our sessions generally run 45 - 55 minutes in length. Our scheduled will not allow us to make up time if you arrive late. If you are late and have not called, your therapist will wait 15 minutes and then assume you are not coming. We require a 24 hour notice if you cannot keep your scheduled appointment. You may be charged the full contracted billing rate for a 60 minute session per your insurance for any appointments cancelled or broken without 24 hours advance notice. Please remember that anything electronically communicated, such as electronically filed claims, email, voicemail, fax or cell phone cannot be guaranteed confidentiality.

Please communicate with me if you need to make special payment arrangements. If you have any questions about this information or any uncertainty regarding our policy, please feel free to contact me, Karla Townsend MA LCMHC NCC at 336 905 0378.

MEDIATION & ARBITRATION: All disputes arising out of, or in relation to, this agreement to provide psychotherapy services shall preferably first be referred to mediation before the initiation of arbitration or litigation. The mediator shall be a neutral third party chosen by agreement of Karla Townsend LCMHC and the client(s). The cost of such mediation, if any, shall be split equally, unless otherwise agreed upon. In the event that mediation is unsuccessful or not an agreed-upon option, any unresolved controversy related to this agreement should preferably be submitted to and settled by binding arbitration, in accordance with the rules of the American Arbitration Association which are in effect at the time the request for arbitration is filed. Please, note that neither mediation nor arbitration is mandatory. In the event that your account is over- due (unpaid) and there is no agreement on a payment plan, Karla Townsend LCMHC can use legal means (court, collection agency, etc.) to seek payment. If there is arbitration, the prevailing party in arbitration or collection proceedings shall be entitled to recover a reasonable sum as and for attorney's fees. In the case of arbitration, the arbi- trator will determine that sum. In the case of a court case, the court will determine the sum.

THE PROCESS OF THERAPY/EVALUATION AND SCOPE OF PRACTICE: Participation in therapy can result in a number of benefits to you, including improving interpersonal relationships and resolution of the specific concerns that led you to seek therapy. Working toward these benefits, however, requires effort on your part. Psychotherapy requires your very active involvement, honesty, and openness in order to change your thoughts, feelings, and/or behavior. Karla Townsend LCMHC will ask for your feedback and views on your therapy, its progress, and other aspects of the therapy and will expect you to respond openly and honestly. Sometimes more than one approach can be helpful in dealing with a certain situation. During evaluation or therapy, remembering or talking about unpleasant events, feelings, or thoughts can result in you experiencing considerable discomfort or strong feelings. Karla Townsend LCMHC may challenge some of your assumptions or perceptions or propose different ways of looking at, thinking about, or handling situations. Attempting to resolve issues that brought you to therapy in the first place, such as personal or interpersonal relation- ships, may result in changes that were not originally intended. Psychotherapy may result in decisions about changing behaviors, employment, substance use, schooling, housing, or relationships. Sometimes a decision that is positive for one family member is viewed quite negatively by another family member. Change will sometimes be easy and swift, but more often it will be slow and even frustrating. There is no guarantee that psychotherapy will yield positive or intended results. During the course of therapy, Karla Townsend LCMHC is likely to draw on various psychological approaches according, in part, to the problem that is being treated and her assessment of what will best benefit you. These approaches include, but are not limited to, behavioral, cognitive- behavioral, cognitive, psychodynamic, existential, system/family, developmental (adult, child, family), humanistic or psycho-educational. Karla Townsend LCMHC provides neither custody evaluation recommendation nor medication or prescription recommendation nor legal advice, as these activities do not fall within his/her scope of practice.

TREATMENT PLANS: Within a reasonable period of time after the initiation of treatment, Karla Townsend LCMHC will discuss with you his/her working understanding of the problem, treatment plan, therapeutic objectives, and his/her view of the possible outcomes of treatment. If you have any unanswered questions about any of the procedures used in the course of your therapy, their possible risks, Karla Townsend's expertise in employing them, or about the treatment plan, please ask and you will be answered fully. You also have the right to ask about other treatments for your condition and their risks and benefits.

TERMINATION: If at any point during psychotherapy Karla Townsend LCMHC either assesses that she is not effective in helping you reach the therapeutic goals or perceived you as non-compliant or non-responsive, and if you are available and/or it is possible and appropriate to do, she will discuss with you the termination of treatment and conduct pre-termination counseling. In such a case, if appropriate and/or neces- sary, she would give you a couple of referrals that may be of help to you. If you request it and authorize it in writing, Karla Townsend LPC will talk to the psychotherapist of your choice in order to help with the transition. If at any time you want another professional’s opinion or wish to consult with another therapist, Karla Townsend LCMHC will give you a couple of referrals that you may want to contact, and if she has your written consent, she will provide her or him with the essential information need- ed. You have the right to terminate therapy and communication at any time. If you choose to do so, upon your request and if appropriate and possible, Karla Townsend LCMHC will provide you with names of other qualified professionals whose services you might prefer.

SOCIAL NETWORKING AND INTERNET SEARCHES: I do not accept friend requests from current or former clients on social networking sites, such as Facebook. I believe that adding clients as friends on these sites and/or communicating via such sites can compromise their privacy and confidentiality. For this same reason, I request that clients not communicate with me via any interactive or social networking web sites.

AUDIO OR VIDEO RECORDING: Unless otherwise agreed to by all parties before- hand, there shall be no audio or video recording of therapy sessions, phone calls, or any other services provided by Karla Townsend LCMHC.

***CANCELLATION/MISSED APPOINTMENTS; A minimum of 24 hours notice is required for re-scheduling or canceling an appointment. If an appointment is cancelled and/or rescheduled with less than 24 hours notice the equivalent of the contracted rate for a 60 minute appointment may be charged. If one is more than 15 minutes late to an appointment, that appointment may be considered a No Show/Late Cx.

If more than one appointment is late cancelled or no showed, this office may not reschedule.

In the event future appointments are not scheduled due to repeated late cancellations or no shows assistance will be provided upon request to other providers.

HIPAA NOTICE OF PRIVACY PRACTICES

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

II. IT IS MY LEGAL DUTY TO SAFEGUARD YOUR PROTECTED

HEALTH INFORMATION (PHI).

By law I am required to insure that your PHI is kept private. The PHI constitutes information created or noted by me that can be used to identify you. It contains data about your past, present, or future health or condition, the provision of health care services to you, or the payment for such health care. I am required to provide you with this Notice about my privacy procedures. This Notice must explain when, why, and how I would use and/or disclose your PHI. Use of PHI means when I share, apply, uti- lize, examine, or analyze information within my practice; PHI is disclosed when I release, transfer, give, or otherwise reveal it to a third party outside my practice. With some exceptions, I may not use or disclose more of your PHI than is necessary to accomplish the purpose for which the use or disclo- sure is made; however, I am always legally required to follow the privacy practices described in this Notice.

Please note that I reserve the right to change the terms of this Notice and my privacy policies at any time as permitted by law. Any changes will apply to PHI already on file with me. Before I make any important changes to my policies, I will immediately change this Notice and post a new copy of it in my office and on my website. You may also request a copy of this Notice from me, or you can view a copy of it in my office or on my website, which is located at karlatownsend.com

III. HOW I WILL USE AND DISCLOSE YOUR PHI.

I will use and disclose your PHI for many different reasons. Some of the uses or disclosures will re- quire your prior written authorization; others, however, will not. Below you will find the different categories of my uses and disclosures, with some examples.

A. Uses and Disclosures Related to Treatment, Payment, or Health Care Operations Do Not Require Your Prior Written Consent. I may use and disclose your PHI without your consent for the following rea- sons:

1. For treatment. I can use your PHI within my practice to provide you with mental health treatment, including discussing or sharing your PHI with my trainees and interns. I may disclose your PHI to physicians, psychiatrists, psychologists, and other licensed health care providers who provide you with health care services or are otherwise involved in your care. Example: If a psychiatrist is treating you, I may disclose your PHI to her/him in order to coordinate your care.

2. For health care operations. I may disclose your PHI to facilitate the efficient and correct opera- tion of my practice. Examples: Quality control - I might use your PHI in the evaluation of the quality of health care services that you have received or to evaluate the performance of the health care pro- fessionals who provided you with these services. I may also provide your PHI to my attorneys, accoun- tants, consultants, and others to make sure that I am in compliance with applicable laws.

3. To obtain payment for treatment. I may use and disclose your PHI to bill and collect payment for the treatment and services I provided you. Example: I might send your PHI to your insurance company or health plan in order to get payment for the health care services that I have provided to you. I could also provide your PHI to business associates, such as billing companies, claims processing companies, and others that process health care claims for my office.

4. Other disclosures. Examples: Your consent isn't required if you need emergency treatment pro- vided that I attempt to get your consent after treatment is rendered. In the event that I try to get your consent but you are unable to communicate with me (for example, if you are unconscious or in severe pain) but I think that you would consent to such treatment if you could, I may disclose your PHI.

B. Certain Other Uses and Disclosures Do Not Require Your Con- sent. I may use and/or disclose your PHI without your consent or au- thorization for the following reasons:

When disclosure is required by federal, state, or local law; judicial, board, or administrative pro- ceedings; or, law enforcement. Example: I may make a disclosure to the appropriate officials when a law requires me to report information to government agencies, law enforcement personnel and/or in an administrative proceeding.

If disclosure is compelled by a party to a proceeding before a court of an administrative agency pur- suant to its lawful authority.

If disclosure is required by a search warrant lawfully issued to a governmental law enforcement agency.

If disclosure is compelled by the patient or the patient's representative pursuant to North Carolina Health and Safety Codes or to corresponding federal statutes of regulations, such as the Privacy Rule that requires this Notice.

To avoid harm. I may provide PHI to law enforcement personnel or persons able to prevent or mitigate a serious threat to the health or safety of a person or the public (i.e., adverse reaction to meds).

If disclosure is compelled or permitted by the fact that you are in such mental or emotional condi- tion as to be dangerous to yourself or the person or property of others, and if I determine that dis- closure is necessary to prevent the threatened danger.

If disclosure is mandated by the North Carolina Child Abuse and Neglect Reporting law. For example, if I have a reasonable suspicion of child abuse or neglect.

If disclosure is mandated by the North Carolina Elder/Dependent Adult Abuse Reporting law. For ex- ample, if I have a reasonable suspicion of elder abuse or dependent adult abuse.

If disclosure is compelled or permitted by the fact that you tell me of a serious/imminent threat of physical violence by you against a reasonably identifiable victim or victims.

For public health activities. Example: In the event of your death, if a disclosure is permitted or com- pelled, I may need to give the county coroner information about you.

For health oversight activities. Example: I may be required to provide information to assist the gov- ernment in the course of an investigation or inspection of a health care organization or provider.

For specific government functions. Examples: I may disclose PHI of military personnel and veterans under certain circumstances. Also, I may disclose PHI in the interests of national security, such as pro- tecting the President of the United States or assisting with intelligence operations.

For research purposes. In certain circumstances, I may provide PHI in order to conduct medical re- search.

For Workers' Compensation purposes. I may provide PHI in order to comply with Workers' Compensation laws.

Appointment reminders and health related benefits or services. Examples: I may use PHI to provide appointment reminders. I may use PHI to give you information about alternative treatment options, or other health care services or benefits I offer.

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If an arbitrator or arbitration panel compels disclosure, when arbitration is lawfully requested by ei- ther party, pursuant to subpoena duces tectum (e.g., a subpoena for mental health records) or any other provision authorizing disclosure in a proceeding before an arbitrator or arbitration panel.

If disclosure is required or permitted to a health oversight agency for oversight activities authorized by law. Example: When compelled by U.S. Secretary of Health and Human Services to investigate or assess my compliance with HIPAA regulations.

If disclosure is otherwise specifically required by law.

C. Certain Uses and Disclosures Require You to Have the Opportunity to Object.

1. Disclosures to family, friends, or others. I may provide your PHI to a family member, friend, or other individual who you indicate is involved in your care or responsible for the payment for your health care, unless you object in whole or in part. Retroactive consent may be obtained in emer- gency situations.

D. Other Uses and Disclosures Require Your Prior Written Autho-

rization. In any other situation not described in Sections IIIA, IIIB, and IIIC above, I will request your written authorization before using or disclosing any of your PHI. Even if you have signed an au- thorization to disclose your PHI, you may later revoke that authorization, in writing, to stop any fu- ture uses and disclosures (assuming that I haven't taken any action subsequent to the original autho- rization) of your PHI by me.

IV. WHAT RIGHTS YOU HAVE REGARDING YOUR PHI

These are your rights with respect to your PHI:

A. The Right to See and Get Copies of Your PHI. In general, you have the right to see your PHI that is in my possession, or to get copies of it; however, you must request it in writing. If I do not have your PHI, but I know who does, I will advise you how you can get it. You will receive a response from me within 30 days of my receiving your written request. Under certain circumstances, I may feel I must deny your request, but if I do, I will give you, in writing, the reasons for the denial. I will also explain your right to have my denial reviewed.

If you ask for copies of your PHI, I will charge you not more than $.25 per page. I may see fit to pro- vide you with a summary or explanation of the PHI, but only if you agree to it, as well as to the cost, in advance.

B. The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask that I limit how I use and disclose your PHI. While I will consider your request, I am not legally bound to agree. If I do agree to your request, I will put those limits in writing and abide by them except in emergency situations. You do not have the right to limit the uses and disclosures that I am legally re- quired or permitted to make.

C. The Right to Choose How I Send Your PHI to You. It is your right to ask that your PHI be sent to you at an alternate address (for example, sending information to your work address rather than your home address) or by an alternate method (for example, via email instead of by regular mail). I am obliged to agree to your request providing that I can give you the PHI, in the format you requested, without undue inconvenience. I may not require an explanation from you as to the basis of your re- quest as a condition of providing communications on a confidential basis.

D. The Right to Get a List of the Disclosures I Have Made. You are entitled to a list of disclosures of your PHI that I have made. The list will not include uses or disclosures to which you have already con- sented, i.e., those for treatment, payment, or health care operations, sent directly to you, or to your family; neither will the list include disclosures made for national security purposes, to corrections or

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law enforcement personnel, or disclosures made before April 15, 2003. After April 15, 2003, disclo- sure records will be held for six years.

I will respond to your request for an accounting of disclosures within 60 days of receiving your re- quest. The list I give you will include disclosures made in the previous six years unless you indicate a shorter period. The list will include the date of the disclosure, to whom PHI was disclosed (including their address, if known), a description of the information disclosed, and the reason for the disclosure. I will provide the list to you at no cost, unless you make more than one request in the same year, in which case I will charge you a reasonable sum based on a set fee for each additional request.

E. The Right to Amend Your PHI. If you believe that there is some error in your PHI or that important information has been omitted, it is your right to request that I correct the existing information or add the missing information. Your request and the reason for the request must be made in writing. You will receive a response within 60 days of my receipt of your request. I may deny your request, in writ- ing, if I find that: the PHI is (a) correct and complete, (b) forbidden to be disclosed, (c) not part of my records, or (d) written by someone other than me. My denial must be in writing and must state the reasons for the denial. It must also explain your right to file a written statement objecting to the de- nial. 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 of your PHI. If I approve your request, I will make the change(s) to your PHI. Additionally, I will tell you that the changes have been made, and I will advise all others who need to know about the change(s) to your PHI.

F. The Right to Get This Notice by Email. You have the right to get this notice by email. You have the right to request a paper copy of it, as well.

V. HOW TO COMPLAIN ABOUT MY PRIVACY PRACTICES

If, in your opinion, I may have violated your privacy rights, or if you object to a decision I made about access to your PHI, you are entitled to file a complaint with the person listed in Section VI below. You may also 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 about my privacy practices, I will take no retaliatory action against you.

VI. PERSON TO CONTACT FOR INFORMATION ABOUT THIS NOTICE OR TO COMPLAIN ABOUT MY PRI- VACY PRACTICES

If you have any questions about this notice or any complaints about my privacy practices, or would like to know how to file a complaint with the Secretary of the Department of Health and Human Ser- vices, please contact me at: Karla Townsend MA LPC NCC CCMHC 336.905.0378.

VII. NOTIFICATIONS OF BREACHES

In the case of a breach, Karla Townsend MA LCMHC NCC requires to notify each affected individual whose unsecured PHI has been compromised. Even if such a breach was caused by a business as- sociate, Karla Townsend MA LCMHC NCC is ultimately responsible for providing the notification directly or via the business associate. If the breach involves more than 500 persons, OCR must be no- tified in accordance with instructions posted on its website. Karla Townsend MA LCMHC NCC bears the ultimate burden of proof to demonstrate that all notifications were given or that the im- permissible use or disclosure of PHI did not constitute a breach and must maintain supporting docu- mentation, including documentation pertaining to the risk assessment.

VIII PHI AFTER DEATH

Generally, PHI excludes any health information of a person who has been deceased for more than 50 years after the date of death. Karla Townsend MA LPC NCC CCMHC may disclose deceased individuals' PHI to non-family members, as well as family members, who were involved in the care or payment for healthcare of the decedent prior to death; however, the disclosure must be limited to PHI relevant to such care or payment and cannot be inconsistent with any prior expressed preference of the deceased individual.

IX. Individuals' Right to Restrict Disclosures; Right of Access

To implement the 2013 HITECH Act, the Privacy Rule is amended. Karla Townsend MA LPC NCC CCMHC is required to restrict the disclosure of PHI about you, the patient, to a health plan, upon re- quest, if the disclosure is for the purpose of carrying out payment or healthcare operations and is not otherwise required by law. The PHI must pertain solely to a healthcare item or service for which you have paid the covered entity in full. (OCR clarifies that the adopted provisions do not require that covered healthcare providers create separate medical records or otherwise segregate PHI subject to a restrict healthcare item or service; rather, providers need to employ a method to flag or note restric- tions of PHI to ensure that such PHI is not inadvertently sent or made accessible to a health plan.)

The 2013 Amendments also adopt the proposal in the interim rule requiring Karla Townsend MA LCMHC NCC to provide you, the patient, a copy of PHI if you, the patient, requests it in electronic form. The electronic format must be provided to you if it is readily producible. OCR clarifies that Karla Townsend MA LCMHC NCC must provide you only with an electronic copy of their PHI, not direct access to their electronic health record systems. The 2013 Amendments also give you the right to direct Karla Townsend MA LCMHC NCC to transmit an electronic copy of PHI to an entity or person designated by you. Furthermore, the amendments restrict the fees that Karla Townsend MA LCMHC NCC may charge you for handling and reproduction of PHI, which must be reasonable, cost- based and identify separately the labor for copying PHI (if any). Finally, the 2013 Amendments modify the timeliness requirement for right of access, from up to 90 days currently permitted to 30 days, with a one-time extension of 30 additional days.

X. NPP

Karla Townsend MA LCMHC NCC NPP must contain a statement indicating that most uses and disclosures of psychotherapy notes, marketing disclosures and sale of PHI do require prior authorization by you, and you have the right to be notified in case of a breach of unsecured PHI