The federal Health Insurance Portability and Accountability Act (HIPAA) of 1996 contains provisions that give you greater access to your health information - your medical record, your billing and insurance records, and any other information our center might collect from you to provide healthcare services to you or to receive payment for the healthcare services rendered. In essence, HIPAA provides you with greater control over how your health information is used and disclosed.
HIPAA also outlines the responsibilities that healthcare providers and insurance plans have to keep your health information confidential. For example, HIPAA requires we provide you with this Notice and that we follow its terms and the commitments we make in it.
InnerWisdom, Inc. is dedicated to maintaining the privacy of your health information. In conducting our business, we will create records regarding you and the treatment and services we provide to you.
These records are our property. However, as required by law, we will:

• Maintain the confidentiality of your health information.
  
• Provide you with this Notice of our legal duties and privacy practices concerning your health information.
  
• Follow the terms of our Notice of Privacy Practices in effect at the time.
  

In addition, unless it is specifically provided for by state or federal law, we may not use or disclose your health information without your written authorization. You may revoke your authorization at any time.

CHANGES TO THIS NOTICE
The terms of this Notice apply to all records containing your health information that are created or retained by us. We reserve the right to revise, change, or amend our Notice of Privacy Practices. Any revision or amendment to this Notice will be effective for all of the information that we already have about you, as well as any of your health information that we may receive, create, or maintain in the future. Our center will post a copy of our current Notice in our offices in a prominent location, and you may request a copy of our most current Notice during any visit to our center.

HOW WE MAY USE AND DISCLOSE YOUR MEDICAL INFORMATION
The following categories describe the different ways in which HIPAA allows InnerWisdom, Inc. to use and disclose your health information without your authorization. We have not provided an exhaustive list of every type of use or disclosure we are permitted to make. The different ways we are permitted to use and disclose your health information do fall within one of the following categories.

Treatment
Our center will use and disclose your health information as necessary for you to receive treatment. For example, we may draw blood to run some tests and use the results to help us reach a diagnosis, to provide further treatment to you, or to assist others in your treatment. Additionally, we may disclose your health information to others outside our center that may assist in your care, such as other healthcare providers, caregivers, or members of your family.

Payment
Our organization will use and disclose your health information in order to bill and collect payment for the services and items you receive from us. For example, we may contact your health insurer to confirm you are eligible for benefits and for what range of benefits. We may be asked by your insurer to provide specific details about the treatment you received so your insurer can determine whether the costs of your treatment are reimbursable. We also may use and disclose your health information to obtain payment from third parties that may be responsible for such costs, such as members of your family. Also, we may use your information to bill you directly for the services we provide during your treatment.

Health Care Operations
InnerWisdom, Inc. will use and disclose your health information internally to help ensure that you receive quality care and that we run efficiently and in compliance with state and federal laws. We may disclose your information to state surveyors to help us evaluate the quality of care we provide. Similarly, we may use your health information to conduct cost-management and planning activities to identify new services needed in the community. Whenever we use or disclose your health information for these purposes, we will, to the extent possible, delete any information that could be used to identify you such as your name, your address and telephone number, your Social Security Number, etc.

Appointment Reminders
Our center will use and disclose your health information to remind you that you have an appointment.

Alternative Treatments/Health-Related Benefits and Services
Our center will use and disclose your health information to inform you of treatment alternatives and/or health-related benefits and services that may be of interest to you.

Fundraising
Our center may use or disclose health information about you in order to contact you as part of a fundraising activity. In addition, we may disclose your health information to a business associate, or to a foundation related to our organization, which may contact you to raise money for our organization. However, in the course of such fundraising activities, we will use or disclose only (1) demographic information relating to you (such as your name, address, and phone number) and (2) the dates you received treatment or services from us. Should you not wish to be contacted regarding such fundraising activities, please contact Mitch Ames at (713) 592-9292.

Marketing
We may use your health information for marketing communications to you, but we will first obtain your authorization for any marketing activity that does not occur in a face-to-face meeting with you or does not involve a promotional gift our center provides to you. We will not sell your health information to anyone for use by that other person or entity, unless you specifically authorize us to do so.
Please be advised that HIPAA does not consider communications that are made for the purposes of treating you or managing your care as "marketing." For example, your physician is allowed to refer you to a specialist for a follow-up test or provide you with a free sample of a prescription drug without first obtaining your written authorization. Similarly, your physician is also allowed to direct you to or recommend alternative treatments, therapies, or settings of care. Finally, disease management, health promotion, preventive care, and wellness programs are not considered marketing. We may send you promotional materials that describe services or alternative treatments we offer, or materials providing information about new developments in healthcare or announcing health fairs or support groups.

Business Associates
Individuals and entities not employed by our center but who perform certain functions for us or provide services on our behalf, occasionally require the use of health information in our possession or require the disclosure of health information from us. However, we have contracts with all of our business associates, and these contracts prohibit them from using or disclosing the health information for reasons other than those specified in the contract. Your health information might be used by, created by, stored at, or disclosed to a business associate, but only for the limited purposes required for the business associate to function on our behalf.

Disclosures to Those Involved in Your Healthcare
Unless you object, we may disclose your health information to a family member, relative, close friend, or any other person that you identify who has involvement in your care or with payment related to your care. We will, however, disclose only that health information that is directly related to the person's involvement. If you are unable to agree or object to a disclosure, we will use our professional judgment to determine whether the health information should be disclosed to these individuals.

OTHER PERMITTED USES AND DISCLOSURES

As Required by Law
InnerWisdom, Inc. will use or disclose health information about you when required to do so by applicable state or federal law. For example, a physician is required to report individuals who receive treatment for gunshot wounds to the state. If you receive treatment for a gunshot wound, we will provide your health information to the appropriate state agency.

For Public Health Activities
Our organization may disclose your health information for various public health activities. For example, we will disclose your health information to notify a person about potential exposure to a communicable disease or a potential risk for spreading or contracting a disease or condition. Similarly, we will disclose your health information to report reactions to drugs, problems with products or devices, or to notify you if a device you have has been recalled. In addition, we may, in certain limited situations, disclose your health information to your employer if it relates to workplace injury or illness or medical surveillance.

Victims of Abuse, Neglect, or Domestic Violence
We will disclose your health information to the appropriate government authority if we believe you are a victim of abuse, neglect, or domestic violence. If such a disclosure is made, you will be informed your physician thinks informing you places you at risk of serious harm or is otherwise not in your best interest. For example, InnerWisdom, Inc. must notify Adult Protective Services if an elderly person appears to have been a victim of neglect.

For Health Oversight Activities
Our center may disclose your health information to a health oversight agency for activities authorized by law. Oversight activities can include, for example, investigations, inspections, audits, surveys, or licensure and disciplinary actions, and may be conducted by either governmental or public agencies and authorities.

For Lawsuits and Similar Proceedings
Our center will use and disclose your health information in response to a court or administrative order if you are involved in a lawsuit or similar proceeding. We also may disclose your health information in response to a subpoena or other lawful process by another party involved in the dispute, but only if (1) we know the other party has informed you of its request and you have not objected to them receiving the information, (2) you have authorized use to release the information, or (3) we have made an effort to inform you of the request or to obtain an order protecting the information the party has requested.

To Law Enforcement
We will release your health information to law enforcement officials if they ask for it, but only if (1) the information sought is relevant and material to a legitimate law enforcement inquiry, (2) the request for your information is specific and limited in scope, and 3) the request comes in the form of a warrant, subpoena, or summons issued by a court. Most importantly, the information we release to law enforcement officials is limited to your contact information. For example, we might provide the law enforcement officer with your current address if you were a victim of a crime and the law enforcement officer needed the information to fill in his/her report of that crime.

To Coroners, Medical Examiners, and Funeral Directors
Our center may release health information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or to determine the cause of death. We may also release health information about patients of a hospital to funeral directors as necessary to carry out their duties.

For Organ and Tissue Donation Purposes
We may disclose your health information to organizations that handle organ and tissue procurement, banking, or transplantation. For example, we might provide your health information to an organ donation center if the information were needed to include you on a list of individuals awaiting an organ for transplant, or if you are listed as an organ donor.

To Avert a Serious Threat to Health or Safety
Our center may use and disclose your health information when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.

For Specialized Government Functions
Our center may disclose your health information if you are a member of U.S. or foreign military forces (including veterans) and if required to do so by the appropriate military command authorities. In addition, our center may disclose your health information to federal officials for intelligence and national security activities authorized by law, such as for protecting the President, other officials, or foreign heads of state, or to conduct intelligence operations or investigations.

Workers' Compensation
Our center will release your health information to comply with laws relating to workers' compensation and similar programs.

YOUR RIGHTS REGARDING YOUR MEDICAL INFORMATION

Under HIPAA, you have several specific rights regarding the health information we maintain about you. Some of these rights require you to contact InnerWisdom, Inc. in writing in order to exercise them.
* If you are required to contact InnerWisdom, Inc. in writing, please submit your written request to the privacy officer listed on the last page of this document.

Right to Request Restrictions
You have the right to ask that we limit how we use and disclose your health information. Additionally, you have the right to request that we limit any disclosures we make of your health information to only those individuals who are involved in your care or for payment for your care.
We are not required to agree to your request; although we will accommodate reasonable requests. Further, if we do agree to your request, we are bound by our agreement with you except when otherwise required by law, in case of an emergency, or when the information we need to use or disclose is necessary to treat you.
* Requests for restrictions must be submitted in writing to the privacy officer listed on the last page of this document.
Your request must describe in a clear and concise fashion: (1) the information you wish restricted; (2) whether you are requesting to limit our center's use, disclosure or both; and (3) to whom or how you want the limits to apply.

Right to Receive Confidential Communications
You have the right to request the manner in which, and where we should communicate with you regarding your health information. For instance, you may direct us to contact you by mail rather than by telephone, or at work rather than at your home. You also have the right to ask us to send your health information to you at a location other than the one we have on file for you. For example, you might want us to send your health information to a post office box instead of your home address.
* In order to receive a confidential communication or to have communications sent to a different location, you must submit your request in writing to the privacy officer listed on the last page of this document.
Your request must specify the requested method of contact and/or the location, as appropriate. You are not required to give a reason for your request. InnerWisdom, Inc. will accommodate all reasonable requests.

Right to Inspect and Copy
You have the right to inspect and obtain a copy of the health information about you that we use and/or store, including your medical records and insurance and billing records. However, the right to inspect and obtain a copy of the health information about you does not include any psychotherapy notes.
* If you want to inspect or obtain a copy of your health information, you must submit your request in writing to the privacy officer listed on the last page of this document.
InnerWisdom, Inc. charges a fee that covers the costs we incur to make the copies, send or mail the health information to you, and any labor and supplies required. We will inform you of the estimated cost associated with your request before we make copies for you in case you want to withdraw or limit your request.
In only a few, limited circumstances, InnerWisdom, Inc. will deny a patient's request. If we deny you access to your health information or a copy of your health information, you may request a review of the denial, which will be performed by a healthcare provider chosen by us who was not involved in the initial decision.

Right to Request Amendments
You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for InnerWisdom, Inc..
* Your request for amendment(s) must be made in writing and submitted to the privacy officer listed on the last page of this document.
In your request, you must specify the reason(s) you believe your information is incorrect or incomplete. Failure to submit your request in writing and/or failing to include the proper documentation will result in a denial. In addition, your request will be denied if you ask us to amend information that is.

• accurate and complete;
  
• not part of the health information kept by or for InnerWisdom, Inc.;
  
• not part of the health information which you would be permitted to inspect and copy; or
  
• not created by InnerWisdom, Inc., unless the individual or entity that created the information is not available to amend the information and InnerWisdom, Inc. has all the information required to evaluate and respond to your request.
  

Right to Receive an Accounting of Disclosures
You have the right to request an accounting of disclosures of your health information that have been made by InnerWisdom, Inc.. The accounting of disclosures will not include: (1) disclosures that are made in the course of providing treatment to you; (2) disclosures that are made for purposes of obtaining payment for the services rendered to you; (3) disclosures that are made for purposes of operating our center; and (4) any disclosures you previously authorized InnerWisdom, Inc. to make.

* In order to obtain an accounting of disclosures, you must submit your request in writing to the privacy officer listed on the last page of this document.

Your request must include a specific period of time that may not be longer than six (6) years prior to the date of the request, and the specific period of time may not include dates prior to April 14, 2003.

The first accounting of disclosures you request in a twelve (12) month period will be provided free of charge. There will be a charge for any additional accountings of disclosures requested within the same (12) month period. InnerWisdom, Inc. will notify you of the costs associated with any additional requests made by you. That way, you may withdraw or limit your request prior to incurring any costs.

Right to a Paper Copy of This Notice
You are entitled to receive a paper copy of this Notice of Privacy Practices the first time you come to InnerWisdom, Inc. for treatment. However, you may ask for and we will provide you with a copy of this Notice at any time. Please direct you request for a copy of this Notice to Mitch Ames, Privacy Officer at (713) 592-9292.

Right to File a Complaint
If you believe InnerWisdom, Inc. has misused or improperly disclosed your health information, you may file a complaint with our center by contacting Mitch Ames, our Privacy Officer at (713) 592-9292. Alternatively, you may file a complaint with the Secretary of the Department of Health and Human Services.
All complaints must be submitted in writing, either to InnerWisdom, Inc. or to the Department of Health and Human Services. Complaints to InnerWisdom, Inc. should be sent to:

You will not be penalized for filing a complaint.
Right to Provide an Authorization for Other Uses and Disclosures
Our center will obtain your written authorization for uses and disclosures that are not identified by this Notice, or are not permitted by law. Any authorization you provide to us regarding the use and disclosure of your health information may be revoked at any time, by you, in writing. After you revoke your authorization, we will no longer use or disclose your health information for the reasons described in the authorization. Of course, we are unable to take back any disclosures that we have already made with your permission.

CONTACT
* If you have any questions about how InnerWisdom, Inc. will use or disclose your health information, or if you require further information about this Notice of Privacy Practices, please contact: