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HIPAA Privacy Practices

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW PERSONAL MEDICAL INFORMATION MAY BE USED AND DISCLOSED AND HOW ACCESS TO THIS INFORMATION CAN BE OBTAINED. PLEASE REVIEW IT CAREFULLY.

This notice is to explain the rules around the privacy of personal medical/health records and our legal duties on how to protect the privacy of the medical/health records that BGTM creates or receives. Generally, BGTM is required by law to ensure that medical/health information that identifies an individual is kept private. BGTM is required by law to follow the terms of the notice that are the most current.

This notice will explain:
. how BGTM may use and disclose medical/health information,
. BGTM's obligations related to the use and disclosure of medical/health information and
. an individual's rights related to any medical/health information that BGTM possess.

This notice applies to the medical/health records that are generated in or by this organization. The terms "medical" and "medical/health" in this Notice means information about any physical or mental condition for which BGTM provides services, or which arise while BGTM is providing services. For example, this may include psychological tests, psychiatric assessments or medical or social assessments.

BGTM may obtain, but BGTM is not required to consent for the use or disclosure of protected health information for treatment, payment or health care operations. BGTM is required to obtain authorization for the use or disclosure of information for other specific purposes or reasons. BGTM has listed some of the types of uses or disclosures below. Not every possible use or disclosure is covered, but all of the ways that BGTM is allowed to use and disclose information will fall into one of the categories.

If therefore, any questions about the content of this Notice of Privacy Practices, or if there is a need to contact someone at the organization about any of the information contained in this Notice of Privacy Practices, contact is:

Privacy Officer
c/o BGTM
P.O. Box 189
St. James, MO 65559
573-265-3251

In addition to BGTM departments, employees, staff and other organization personnel, the following people will also follow the practices described in this Notice of Privacy Practices:

. Any health care professional who is authorized to enter information in a medical/health record;
. Any member of a volunteer group that is permitted to assist in BGTM program/services
. All providers that BGTM organizations contract with to provide services

The class of entities that make up continuum of care and services are:
. any federal/state-operated departments;
. any administrative agents and contract providers located within federal/state-operated departments; and
. contract providers of BGTM

In addition, individuals and providers who are BGTM's Continuum of Care and Services may share medical information with each other about BGTM clients they serve in common for the purpose of treatment, payment or health care operations as those terms are described later in this Notice of Privacy Practices. These other individuals and providers who are in BGTM's Continuum of Care and Services are included throughout this document whenever we use the term "BGTM."

HOW BGTM MAY USE AND DISCLOSE MEDICAL INFORMATION

The following categories describe different ways that BGTM uses and discloses medical/health information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways BGTM is permitted to use and disclose information will fall within one of the categories.

Use and Disclosure of Medical Information

BGTM can use or disclose medical information regarding treatment, payment for services, or for organization operations, and BGTM will make a good faith effort to have clients acknowledge their copy of the Notice of Privacy Practices.

Treatment- BGTM may use medical information to provide treatment or services. BGTM may disclose medical information to qualified mental health professionals, or to qualified counselors; or technicians, medical students or residents, or other organization personnel, volunteers or interns who are involved in providing services at BGTM, or interpreters needed in order to make treatment accessible. For example, BGTM
treatment team members will internally discuss medical/health information in order to develop and carry out a plan for services. Different departments of the organization also may share medical/health information in order to coordinate the different things needed, such as prescriptions, medical tests, special dietary needs, respite care, personal assistance, day programs, etc. BGTM may disclose medical/health information to people outside the organization who may be involved in medical care after clients are disenrolled, such as contractors BGTM uses to provide services that are part of aftercare, but only the minimum necessary amount of information will be used or disclosed to carry this out.

Payment- BGTM may use and disclose medical/health information so that the treatment and services received at the organization may be billed to and payment may be collected from the responsible party, an insurance company or a third party through BGTM. For example, BGTM may need to provide insurance plan information about
psychiatric treatment or habilitation services received at the organization so your insurance plan, or any applicable Medicaid or Medicare funds, will pay BGTM for the services. BGTM may tell insurance plans or other payers about a service received in order to obtain prior approval or to determine whether the service is covered. In addition, in order to correctly determine ability to pay for services, BGTM may disclose personal health information to the Social Security Administration, the Division of Employment Security, or the Department of Social Services.

Health Care Operations- BGTM may use and disclose medical/health information for organizational operations. These uses and disclosures are necessary to run the organization and make sure that all BGTM clients receive quality care. For example, BGTM may use medical/health information for quality improvement to review our treatment and services and to evaluate the performance of BGTM staff. BGTM may combine medical information about many clients to decide what additional services BGTM should offer, what services are not needed, and whether certain new treatments are effective. BGTM may disclose information to doctors, nurses, technicians, medical students and residents, and other organization personnel as listed above for review and learning purposes. BGTM may combine the medical/health information with medical/health information from other facilities to improve performance. It may also be necessary to obtain or exchange information with the Department of Elementary and Secondary Education, the Department of Social Services, Vocational Rehabilitation, the Office of State Courts Administrator, or other state agencies or interagency initiatives. Or BGTM may remove personal health identifiers from this set of medical information so others may use it to study health care and health care delivery without learning the identity of specific clients. This may be in the form of providing information to the BGTM Board of Directors or Regional Board of Trustees.

Uses and Disclosures of Medical/Health Information That Do Not Require Consent or Authorization:

BGTM can use or disclose health information without consent or authorization when:
. there is an emergency or when required by law to treat you,
. when BGTM is required by law to use or disclose certain information, or
. when there are substantial communication barriers to obtaining consent.

BGTM can also use or disclose health information without consent or authorization for:

Appointment Reminders
Medical information may be used as a reminder for appointments for treatment or other services.

Treatment Alternatives and Health-Related Benefits and Services
Medical information may be used or disclosed to recommend possible treatment options or alternatives or health-related benefits or services.

Individuals Involved in Disaster Relief
Should a disaster occur, BGTM may disclose medical information to any agency assisting in a disaster relief effort so that clients can be notified about any condition,
status and location.

Research
BGTM may use and disclose medical/health information for research purposes when approved by BGTM's internal review process.

As Required By Law
BGTM will disclose medical/health information when required to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety
BGTM may use and disclose medical/health information when necessary to prevent a serious threat to the health and safety of clients, the public, or any other person.
However, any such disclosure would only be to someone able to help prevent the threat.

SPECIAL SITUATIONS

Public Health Risks
BGTM may disclose medical/health information for public health activities. These
activities generally include the following: to prevent or control disease, injury or disability; to report births and deaths; to report child abuse or neglect; to report reactions to medications or problems with products; to notify people of recalls of products they may be using; to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; to notify the appropriate government
authority if we believe a consumer has been the victim of abuse, neglect or domestic violence. BGTM will only make this disclosure if client agrees or when required or authorized by law.

Lawsuits and Disputes
BGTM may disclose medical/health information in response to a court or administrative order.

Law Enforcement
BGTM may release medical/health information if asked to do so by a law enforcement official. BGTM may also release limited medical/health information to law enforcement in the following situations: (1) about a client who may be a victim of a crime if, under certain limited circumstances, BGTM is unable to obtain agreement; (2) about a death BGTM believes to be the result of criminal conduct; (3) about criminal conduct at the organization; (4) about a client who commits or threatens to commit a crime on the premises or against program staff (in which case BGTM may release the client's name, address, and last known whereabouts); (5) in emergency circumstances, to report a crime, the location of the crime or victims, and the identity, description
and/or location of the person who committed the crime. However, if the material is protected by 42 CFR Part 2 (a federal law protecting the confidentiality of drug and
alcohol abuse treatment records), a court order is required.

RIGHTS REGARDING MEDICAL/HEALTH INFORMATION
Client rights regarding medical information:

Right to Inspect and Copy
Clients have the right to inspect and copy medical/health information with the
exception of psychotherapy notes and information compiled in anticipation of litigation. A written request is required to inspect and copy medical/health information.
This request is submitted to the Privacy Officer or designee. BGTM will charge a fee for the costs of copying, mailing or other supplies associated with the request. BGTM may deny requests to inspect and copy in certain limited circumstances. If client is denied access to medical/health information, a review may be requested. An executive staff person of BGTM will review the request and the denial.

Right to Request an Amendment
If the medical/health information is thought to be incorrect or incomplete, a request to amend the information may be submitted. Requests for an amendment must be made in writing and submitted to the Privacy Officer or designee.

Right to an Accounting of Disclosures
To request an accounting of disclosures, a written request must be submitted to the Privacy Officer or designee. The request must state a time period, which may not go back more than six years and cannot include dates before April 14, 2003.

Right to Request Restrictions
To request a restriction on the use or disclosure of medical/health information for treatment, payment or health care operations, submit the request in writing to the Privacy Officer or designee. The request must include: (1) what information to limit; (2) whether the limitation is for our use, disclosure or both; and (3) to whom the limits are to be applied. Although BGTM is not required to agree to the request , if BGTM agrees, BGTM will comply with the request unless the information is needed to provide emergency treatment.

If you wish to exercise any of these rights, please contact:

BGTM Privacy Officer
P.O. Box 189
St. James, MO 65559


CHANGES TO THIS NOTICE
BGTM reserves the right to change this notice.

COMPLAINTS
To file a complaint with BGTM, contact Privacy Officer or Designee, at the following address.
BGTM Privacy Officer
P.O. Box 189
St. James, MO 65559

If you believe your privacy rights have been violated,
. A grievance with the Office of Civil Rights by calling 866-OCR-PRIV (866.627.7748), or 886.788.4989 TTY.

All complaints must be submitted in writing. You will not be penalized for filing a complaint.

OTHER USES OR DISCLOSURES OF MEDICAL/HEALTH INFORMATION
Uses or disclosures not covered in this Notice of Privacy Practices will not be made without written authorization. If BGTM is provided with written authorization to use or disclose information, parties can change their mind and revoke the authorization at any time, as long as it is in writing . If authorization is revoked, BGTM will no longer use or disclose the information. However, BGTM will not be able to take back any disclosures that BGTM has made pursuant to previous authorization.

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