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Notice of Privacy Practices

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

I. MY PLEDGE REGARDING PROTECTED HEALTH INFORMATION

I understand that health and relationship information about you and your therapy is personal. I am committed to protecting this information. I create a shared clinical record of the care and services you and your partner receive. I need this record to provide you with quality care and to comply with certain legal requirements.

This notice applies to all records of your care generated by this relationship therapy practice. It describes the ways in which I may use and disclose your protected health information (PHI), your rights regarding the PHI I maintain, and my legal obligations.

I am required by law to:

  • Make sure that PHI that identifies you and your partner is kept private.
  • Give you this notice of my legal duties and privacy practices with respect to your PHI.
  • 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. The new Notice will be available upon request, in my office, and on my website.

II. HOW I MAY USE AND DISCLOSE HEALTH AND RELATIONSHIP INFORMATION ABOUT YOU

Federal privacy regulations allow health care providers who have a direct treatment relationship with a couple to use or disclose PHI without written authorization to carry out treatment, payment, or health care operations.

  • For Treatment: I may use and disclose your PHI to coordinate and manage your relationship therapy. For example, if I consult with another licensed health care provider about your relationship dynamics, we are permitted to share clinical information to assist in your care. In these consultations, no identifying information (such as names) is disclosed. Disclosures for treatment purposes are not limited to the "minimum necessary" standard because clinicians require comprehensive context to provide quality care.
  • For Payment: I may use and disclose your PHI so that the services provided to you may be billed and payment collected. This authorization applies to standard methods of payment and collection, including the rebuttal of potential credit card disputes.
  • For Health Care Operations: I may use and disclose your PHI to run my practice and ensure you receive quality care.

IMPORTANT LIMITATION ON THIRD-PARTY COORDINATION: Because I treat couples exclusively, there is no coordination regarding your care with any third parties (such as individual therapists, physicians, or attorneys) unless both partners in the relationship request the release of information and sign a joint Authorization for Release of Information (ROI).

  • Lawsuits and Disputes: If you are involved in a lawsuit or court proceeding and a request is made for information concerning your relationship assessment and treatment, such information is protected by therapist-patient privilege. Because you are treated within a couple unit,  I cannot provide any information or release records without written authorization from both partners, or a direct judicial order (an order signed by a judge). An attorney-issued subpoena is not sufficient to release your records without joint written consent or a judicial order. 
  • Role Limitation: I cannot serve in both a therapeutic and an evaluative role. I do not provide custody evaluations, expert opinions, or evaluative information for court proceedings.

III. CERTAIN USES AND DISCLOSURES THAT DO NOT REQUIRE YOUR CONSENT OR AUTHORIZATION

Subject to certain legal limitations, I can use and disclose your PHI without your authorization for the following reasons:

  • To the Secretary of Health and Human Services: To investigate my compliance with HIPAA.

  • Judicial and Administrative Proceedings:  In response to a direct judicial order (an order signed by a judge), though my clinical and legal preference is to obtain a signed authorization from both partners before doing so. 

  • Law Enforcement: To report crimes occurring on my premises.

  • Legal Defense: To defend myself in legal proceedings instituted by members of the treatment unit.

  • Coroners or Medical Examiners: When such individuals are performing duties authorized by law.

  • Appointment Reminders and Communications: To contact you to remind you of an upcoming appointment, or to notify you of treatment alternatives or health-related services that may be of interest to you.

  • Business Associates: I utilize third-party entities (Business Associates) to perform billing, electronic record-keeping, and communication services. Business Associates must sign a Business Associate Agreement (BAA) pledging to safeguard your PHI. I currently maintain BAAs with:

    • SimplePractice (electronic health record, client portal, and telehealth platform)
    • Office Ally (insurance clearinghouse, if applicable)
    • reMarkable (digital note-taking tablet)
    • Gottman Connect (online relationship assessment platform)
    • RingRx (HIPAA-compliant phone, fax, and messaging)

  • Abuse, Neglect, and Public Safety (Mandated Reporting): I am legally obligated to breach confidentiality and disclose PHI to appropriate authorities in the following circumstances:

    • Child Abuse: If I have reasonable cause to believe a child under 18 is suffering physical, sexual, or emotional abuse or neglect, I must file a report with the Department of Children and Families.
    • Elder/Elderly or Vulnerable Adult Abuse: If I have reasonable cause to believe an elderly or disabled/handicapped person is suffering from abuse, neglect, or exploitation, I must file a report with the appropriate state protective agency.
    • Threat of Harm to Others: If a client communicates an immediate threat of serious physical violence against an identifiable victim, I am required to take protective actions. This may include notifying the potential victim, contacting the police, or seeking hospitalization.
    • Threat of Harm to Self: If a client threatens to harm themselves, I am obligated to take protective actions, which may include seeking voluntary or involuntary hospitalization, or contacting emergency contacts/family members who can assist in providing safety.

IV. CERTAIN USES AND DISCLOSURES REQUIRE YOU TO HAVE THE OPPORTUNITY TO OBJECT

  • Disclosures to Family, Friends, or Others: I may provide your PHI to a family member, friend, or other person you explicitly identify as involved in your care or payment for your care, provided you do not object. In emergency situations, consent may be obtained retroactively.

V. YOUR RIGHTS WITH RESPECT TO YOUR PHI

  • The Right to Request Limits on Uses and Disclosures: You have the right to ask me not to use or disclose certain PHI for treatment, payment, or operations. I am not required to agree to your request if I believe it would compromise your care or my ability to collect fees.
  • The Right to Request Restrictions for Out-of-Pocket Payments: You have the right to restrict disclosures of your PHI to health plans if the services were paid for entirely out-of-pocket.
  • The Right to Choose How I Send PHI to You: You have the right to request that I contact you in a specific way (e.g., a specific phone number or email address), and I will accommodate all reasonable requests.
  • The Right to See and Get Copies of Your Record:
    • The Shared Record Standard: Because couples therapy involves a shared treatment unit, you share a single clinical record. To protect the privacy of both parties, both partners must consent in writing to the release of this shared record.
    • Gottman Assessment Exception: Individual scoring and raw data from the Gottman Connect assessment are kept confidential between the clinician and each respective partner, as agreed upon prior to testing. Only the combined, integrated Gottman Feedback Report will be eligible for release to either partner.
    • Clinical Summaries: Because raw clinical records can be easily misinterpreted, I recommend reviewing them together in session. If you request a copy of your record, I will provide it or a clinical summary within 30 days of receiving a written request signed by both partners. A reasonable, cost-based administrative fee may apply.
  • The Right to Get a List of the Disclosures I Have Made: You have the right to request an accounting of disclosures of your PHI made in the last six years for purposes other than treatment, payment, or operations. I will respond within 60 days. One request per year is free; subsequent requests may incur a reasonable, cost-based fee.
  • The Right to Correct or Update Your PHI: If you believe there is an error in your record, you may request an amendment in writing. I may deny your request, but I will provide a written explanation within 60 days.
  • The Right to Get a Paper or Electronic Copy of this Notice: You have the right to receive a paper or electronic copy of this notice at any time.
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