JOINT NOTICE OF PRIVACY PRACTICES

Effective Date:  08/20/2024

THIS NOTICE IS PROVIDED TO YOU JOINTLY BY BASEPOINT PSYCHIATRY, PLLC, AND BASEPOINT ACADEMY, LLC, WHICH TOGETHER PARTICIPATE IN AN ORGANIZED HEALTH CARE ARRANGEMENT AS DEFINED AT 45 C.F.R. § 160.103 AND FURTHER DESCRIBED BELOW. THIS PRIVACY POLICY DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. 

If you have any questions about this Notice or need further information, please contact our Privacy Officer, Reynalyn Hall, at Reynalyn.Hall@basepointacademy.com. Written requests should be addressed to:

711 W. Broad Street, Forney, TX 75126

Attn: Privacy Officer

NOTICE OF ORGANIZED HEALTH CARE ARRANGEMENT:

To improve quality of care and reduce costs for patients of BasePoint Psychiatry, PLLC and BasePoint Academy, LLC, an Organized Health Care Arrangement (“OHCA”) has been formed by the two entities (collectively, “BasePoint”).  An OHCA is a relationship recognized by HIPAA privacy rules allowing both entities to share Protected Health Information (“PHI”) for quality improvement and population-based services.

This arrangement means that these entities may share your medical information with each other as needed for the purposes of payment and health care operations. The OHCA offers the following advantages: 

• Assists in the development of patient care programs;
• Provides aggregate data-based evidence to treat populations of patients;
• Helps identify at-risk patients;
• Reduces cost of care;
• Improves quality of care; and
• Allows care to be tailored to patient’s specific health situation.

If you have any questions regarding the OHCA or this Policy, please contact our Compliance Officer.

OUR PLEDGE REGARDING YOUR PROTECTED HEALTH INFORMTION:

The confidentiality of mental health and alcohol and drug abuse client records maintained by BasePoint is protected by the Health Insurance Portability and Accountability Act of 1996 set forth at 42 U.S.C. § 132d et seq. and the Privacy Standards and Security Standards promulgated thereunder; the Health Information Technology for Economic and Clinical Health Act, included in Division A, Title XIII, Subtitle D of The American Recovery and Reinvestment Act of 2009, as well as its implementing regulations at 45 C.F.R. Parts 160 & 164 (“HIPAA”).

Basepoint has adopted this Notice of Privacy Practices Policy (“Privacy Policy”) to comply with HIPAA. Basepoint hereby acknowledges its duty and responsibility to protect the privacy and security of Individually Identifiable Health Information (“IHI”), and PHI as defined by the HIPAA Regulations. We also acknowledge our duty and responsibility to support and facilitate the timely and unimpeded flow of health information for lawful and appropriate purposes.

The privacy of your PHI is important to us.  This Policy will tell you about the ways in which we may use and disclose your PHI.  This Policy describes your rights with respect to your PHI we collect and maintain and describes certain obligations we have regarding the use and disclosure of your PHI.

We are required by law to:

• Maintain the privacy of your PHI;
• Give you this notice describing our legal duties, privacy practices, and your rights regarding your PHI we collect and maintain; 
• Notify you if we discover a breach of any of your PHI that is not secured in accordance with federal guidelines; and
• Follow the terms of the Privacy Policy that is currently in effect.

WHO MUST FOLLOW THIS POLICY:

• All locations, departments and units of BasePoint (locations are available on our website at www.basepointacademy.com)
• All employees, staff and other office personnel
• Any volunteers or health care students, interns, residents or fellows

HOW WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION WITHOUT YOUR AUTHORIZATION:

HIPAA and HIPAA  Part 2 permit us to use and disclose information without your written authorization in limited circumstances. The following categories describe different ways that we may use and disclose your PHI without your authorization.  Certain disclosures of PHI may be made electronically.  

• For Treatment:  We may use your PHI to provide you with health care treatment or services.  We may disclose your PHI to other doctors, nurses, technicians, health students, or other personnel who are involved in taking care of you.  For example, another doctor treating you for one condition may need to know if you have another condition because it might impact their treatment approach.

• For Payment:  We may use and disclose your PHI so that the treatment and services you receive from us may be billed to and payment collected from you, an insurance company, or a third party.  For example, we may need to give your health plan information about your use of our services so that your health plan will pay us or reimburse you for the treatment.  We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
• For Health Care Operations:  We may use and disclose your PHI for operations of our practice.  For example, we may use health information to review our treatment and services, to evaluate the performance of our staff in caring for you, and for quality and cost reporting.

• For Research:  We may disclose your PHI for the purpose of research. Your PHI may be used or disclosed without your consent or authorization if an institutional Review Board approves a waiver of authorization for disclosure.
• As Required by Law:  We may disclose your PHI when required to do so by federal, state, or local law.
• To Avert a Serious Threat to Health or Safety:  We may use and disclose your PHI when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.
• Military and Veterans:  If you are a member of the armed forces or separated/discharged from military services, we may release your PHI as required by military command authorities or the Department of Veterans Affairs as may be applicable.  We may also release health information about foreign military personnel to the appropriate foreign military authorities.
• Workers’ Compensation:  We may release your PHI as authorized by, and in compliance with, laws related to workers’ compensation and similar programs established by law that provide benefits for work-related illnesses and injuries without regard to fault.
• Public Health Activities:  Except where restricted by state law, we may disclose your PHI 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, neglect or exploitation;
  • to report reactions to medications or problems with products;
  • to notify people of recalls of products they may be using;
  • to notify person or organization required to receive information on FDA-regulated products; and 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.
• Immunizations:  We may disclose information related to your immunizations to schools and other public institutions as required by law. 
• Health Oversight Activities:  We may disclose your PHI to a health oversight agency for activities authorized by law.  These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
• Lawsuits and Disputes:  If you are involved in a lawsuit or a dispute, we may disclose your PHI in response to a court or administrative order.  We may also disclose your PHI in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.
• Law Enforcement:  We may disclose your PHI to law enforcement officials for law enforcement purposes including the following:
  • in reporting certain injuries, as required by law, gunshot wounds, burns, injuries to perpetrators of crime;
  • in response to a court order, subpoena, warrant, summons or similar process;
  • to identify or locate a suspect, fugitive, material witness, or missing person;
  • about the victim of a crime, if the victim agrees to disclose or under certain limited circumstances, we are unable to obtain the person’s agreement;
  • about a death we believe may be the result of criminal conduct; 
  • about criminal conduct at our facility; and 
  • in emergency circumstances to report a crime; the location of the crime or victims; or the identity, description, or location of the person who committed the crime.
• Organ and Tissue Donation:  We may disclose your PHI to organizations involved in the procurement, banking, or transplantation of cadaveric organs, eyes or tissue, for the purpose of facilitating organ and tissue donation where applicable.
• Abuse, Neglect and Domestic Violence:  We may disclose your PHI to an appropriate governmental authority if we reasonably believe that you may be a victim of abuse, neglect, or domestic violence.  We will only make this disclosure if you agree or when required or authorized by law.
• Coroners, Health Examiners and Funeral Directors:  We may disclose your PHI to a coroner or health examiner.  This may be necessary, for example, to identify a deceased person or determine the cause of death.  We may also disclose your PHI to funeral directors as necessary to carry out their duties.
• National Security and Intelligence Activities:  We may disclose your PHI to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law, or for the purpose of providing protective services to the President or foreign heads of state.
• Inmates:  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose your PHI to the correctional institution or law enforcement official.  This release would be necessary (a) for the institution to provide you with health care; (b) to protect your health and safety or the health and safety of others; or (c) for the safety and security of the correctional institution.

EXAMPLES OF OTHER PERMISSIBLE OR REQUIRED DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION WITHOUT YOUR AUTHORIZATION:

• Business Associates:  Some of our activities are provided on our behalf through contracts with vendors referred to as business associates.  Examples of when we may use a business associate include electronic health records vendor, coding and claims submission performed by a third-party billing company, consulting and quality assurance activities provided by an outside consultant, billing and coding audits performed by an outside auditor, and other legal and consulting services provided in response to billing and reimbursement issues which may arise from time to time.  When we enter into contracts to obtain these services, we may need to disclose your PHI to our business associate so that the associate may perform the job which we have requested.  To protect your PHI, however, we require our business associate to appropriately safeguard your information.
• Emergency/Disaster Relief Notification:  We may use or disclose your PHI to notify or assist in notifying a family member, personal representative, close personal friend, or other person responsible for your care of your location and general condition.  We will not disclose your PHI to your family members, personal representative, or close personal friends as described in this paragraph if you object to such disclosure.  Please notify our Privacy Officer if you object to such disclosures.
• Communication with Relatives, Caregivers, Guardians, and Close Friends:  Your PHI may be disclosed to a family member, other relative, a close friend, guardian or other person you identify, who is involved in your care or helps pay for your care. If information is shared with them, it would be limited to what BasePoint or your provider believes is directly relevant to that person’s involvement with your care or payment related to your care.
• Unlawful Conduct:  Federal law allows for the release of your PHI to appropriate health oversight agencies, public health authorities or attorneys, provided that a work force member or business associate believes in good faith that we have engaged in unlawful conduct or otherwise violated professional or clinical standards and are potentially endangering one or more patients, workers or the public.
• Appointment or Care Reminders:  We may use or disclose your PHI to provide refill reminders, appointment reminders, information regarding your course of treatment, case management or care coordination, to describe a health-related products or services that we provide, or to contact you in regard to treatment alternatives.

USES AND DISCLOSURES REQUIRING YOUR WRITEN AUTHORIZATION:

• Psychotherapy Notes: We must obtain a specific authorization from you to use or disclose psychotherapy notes unless it is for treatment, payment or health care operations or is required by law, permitted by health oversight activities, to a coroner or medical examiner, or to prevent a serious threat to health or safety.
• Marketing: Your written authorization must be obtained prior to using your PHI to send you any marketing materials.  BPA and its providers may communicate with you in face-to-face encounters about products and services related to your course of treatment, case management or care coordination, alternative treatments, therapies, providers, and care settings without your authorization.  BPA can provide you with marketing materials during a face-to-face encounter and/or may provide you with a promotional gift of nominal value without your written authorization. 
• PHI Usage: BPA and our health Professionals will not disclose your PHI without your authorization in exchange for direct or indirect payment except in limited circumstances permitted by law.  These circumstances include public health activities; research; treatment of the individual; sale, transfer, merger, or consolidation of the organization; services provided by a business associate, pursuant to a business associate agreement; providing an individual with a copy of their PHI; and other purposes deemed necessary and appropriate by the U.S. Department of Health and Human Services (HHS).
• Mental Health: We may disclose a medical/dental record developed in connection with the provision of mental health services if the disclosure is limited to information in the record relevant to the purpose of the disclosure.  If the disclosure is not limited to the purpose of the disclosure, we must obtain an authorization.
• We must obtain an authorization for all other uses and disclosures of your PHI not described in this Privacy Policy.

If you provide us with written authorization to use or disclose your PHI, you may revoke that authorization, in writing, at any time.

Note:  AIDS and HIV-related information, genetic information, information about sexually transmitted infections, alcohol and/or substance abuse records, mental health records, and other sensitive health information may have additional confidentiality protections under state and federal law.  Any disclosures of these types of PHI will be subject to those additional protections.

YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION:

You have the following rights with respect to your PHI:

• Right to Inspect and Copy:  You may request access to your medical record and billing records maintained by BasePoint in order to inspect and request copies of your health record.  To inspect and request copies of your PHI, you must complete and submit the record request form to our Compliance Officer at the address listed appearing on page 1.  We shall comply with your request to inspect or copy your health record within a reasonable time, but not to exceed 30 days from the date your request is received.  We may charge a reasonable cost-based fee. We may deny your request under certain limited circumstances.
• Right to Amend:  You have the right to request that we amend your PHI health record about you if you feel that health information, we have about you is incorrect or incomplete.  You have the right to request an amendment for as long as we keep the information. To request an amendment, your request must be made in writing, submitted to our Compliance Officer at the address listed on the first page of this Privacy Policy, and must provide a reason that supports your request for an amendment.  We may deny your request under certain limited circumstances.
• Right to an Accounting of Disclosures:  Upon written request, you may obtain an accounting of certain disclosures of your PHI made during any period of time prior to the date of your request provided such period does not exceed six years and does not apply to disclosures that occurred prior to April 14, 2003.  If you request an accounting more than once during a twelve (12) month period, you will be charged for the accounting of disclosures statement.  Contact our Privacy Officer to request an accounting.
• Right to Request Restrictions:  You have the right to request a restriction or limitation on the use and disclosure of your PHI.  You also have the right to request a restriction or limitation on the disclosure of your PHI to someone who is involved in your care or the payment for your care, such as a family member or friend.  For example, you could ask that we restrict a specified nurse from use of your PHI or that we not disclose information to your spouse about a surgery you had.  If you pay for a service entirely out-of- pocket, you may request that information regarding the service be withheld and not provided to a third party payor for purposes of payment or health care operations. We are obligated by law to abide by such restriction.  To request a restriction on the use and disclosure of your PHI, you must make your request in writing to our Privacy Officer at the address listed on the first page of this Privacy Policy. In your request, you must tell us what information you want to limit and to whom you want the limitations to apply.  We will notify you of our decision regarding the requested restriction.  If we do agree to your requested restriction, we will comply with your request unless the information is needed to provide you emergency treatment.
• Right to Receive Confidential Communications:  You have the right to request that we communicate with you about your PHI in a certain way or have such communications addressed to a certain location.  For example, you can ask that we only contact you at work or by mail to a post office box.  To request confidential communications, you must make your request in writing to our Privacy Officer at the address listed on the first page of this Privacy Policy. Your request must specify how or where you wish to be contacted.
• Right to a Paper Copy of this Privacy Policy:  You have the right to obtain a paper copy of this Privacy Policy at any time upon request.  At the time of first service rendered, we are required to provide you with a paper copy of this Privacy Policy.  To obtain a copy of this Privacy Policy at any other time, please request it from our Privacy Officer at the address listed on the first page of this Privacy Policy.
• Right to Revoke Authorization:  If you execute any authorization(s) for the use and disclosure of your PHI, you have the right to revoke such authorization(s), except to the extent that action has already been taken in reliance on such authorization.

ONLINE PRIVACY POLICY ONLY

This online privacy policy pertains solely to information collected through our Sites and does not cover information gathered offline, including via telephone, email, or other means.

What Information Do We Collect From Visitors to Our Website?

When you visit our Sites, our server automatically logs your visit, capturing information such as your web request, Internet Protocol (IP) address, browser type, browser language, date and time of your request, and one or more cookies that may uniquely identify your browser.

Additionally, we collect information that you expressly provide. This includes when you subscribe to our newsletter, fill out a form, comment on our blog, or participate in a certification quiz. We may ask for your name, email address, mailing address, phone number, or other contact information. Furthermore, we may request information to assist in referring you or a loved one to an appropriate treatment center, such as details regarding the condition or ailment you wish to address and your insurance information. Payment information, such as credit and debit card numbers, may also be collected when making purchases through the site.

We may monitor and/or record telephone, text, and/or chat conversations for business purposes, such as quality assurance and training, and to protect our rights.

Information received through our Sites may be combined with data from our affiliates and/or third parties. We handle combined information as described in this privacy policy to help us provide services and information to you.

Do We Disclose Visitors’ Information to Third Parties?

We do not sell or trade the information collected from you, except as outlined herein. Information may be disclosed to third parties, including affiliates and business partners, who assist in operating our Sites, conducting business, or servicing you, provided they agree to maintain confidentiality. Additionally, information may be released in compliance with the law, legal processes, or to enforce our Sites’ policies or protect ours or others’ rights, property, or safety. Non-personally identifiable visitor information (including unique device identifiers) may be shared with other parties for marketing, advertising, or other purposes. Your personal information may also be disclosed with your express consent for purposes not listed here, or as part of a business transaction such as a merger or sale.

How Do We Use Visitors’ Information?

Information collected from you may be used in the following ways:

• To process placement and/or consulting requests
• To personalize your experience and respond to your individual needs
• To improve our Website, address problems, and protect site security
• To enhance customer service and support
• To administer promotions, surveys, or other Website features
• To communicate information and updates regarding your placement and/or consulting request
• To monitor the site for compliance with our Terms of Use and the law

Non-personal information may be used for statistical analysis, research, and other purposes.

Cookies and Similar Technologies

We utilize cookies to recognize your browser and capture certain information. These technologies are used to understand and save your preferences for future visits, as well as to compile aggregate data about Site usage and interaction. Third-party service providers may assist us in better understanding our Sites’ visitors by employing these technologies. Such providers may collect information about your online activities over time, on other devices, and on other websites or apps, if those sites and apps use the same service provider.

We utilize Google Analytics, which employs cookies and similar technologies to collect and analyze information about Site usage, activities, and trends. This service may also gather information regarding the use of other websites, apps, and online resources. For more details on Google’s practices regarding data collection and privacy, please refer to Google’s Privacy Policy. You can opt out of Google Analytics tracking by downloading the Google Analytics opt-out browser add-on.

If you have any questions about our use of cookies, please contact us.

Opt Out of Cookies

The following list outlines services used by our site that have access to non-identifiable user information. Each service offers its own opt-out procedures, accessible via the provided links.

• Google Analytics: Opt Out
• Call Rail: Opt Out

I’m Cookie-Free. Now What?

To ensure your browser allows first-party cookies while blocking third-party cookies, follow these instructions for popular browsers:

• Chrome: Preferences > Privacy > Content settings > Cookies > Block third-party cookies
• Firefox: Preferences > Privacy > History > Use custom settings for history > Choose options for third-party cookies
• Safari: Preferences > Privacy > Allow cookies from websites I visit

To clear cookies in your browser:

•  Chrome: Clear browsing data
• Firefox: Show Cookies > Remove All
• Safari: Manage Website Data > Remove All

TO MAKE A COMPLAINT:

If you believe that your privacy rights have been violated, you may complain to BasePoint at 972-325-2633 or Reynalyn.Hall@basepointacademy.com and/or to the Director, Office for Civil Rights at https://ocrportal.hhs.gov/ocr/smartscreen/main.jsf .  There will be no retaliation against you for filing a complaint.  Complaints to BasePoint should be filed in writing and should state the specific incident(s) in terms of subject, date, and other relevant matters.  To file a Complaint by mail:

U.S. Department of Health and Human Services: 

US Department of Health and Human Services 

Attn.: Director, Office for Civil Rights 

200 Independence Ave. SW Washington, D.C. 20201 

BasePoint:

972-325-2633

Reynalyn.Hall@basepointacademy.com

Attn: Compliancy Officer

711 W. Broad Street Forney, TX 75126

CHANGES TO THIS PRIVACY POLICY:

This Privacy Policy is effective as of August 20, 2024.  We reserve the right to change our privacy practices and any terms of this Privacy Policy.  If our privacy practices materially change, we will revise this Privacy Policy and make copies of the revised Privacy Policy available upon request.  We reserve the right to make the revised or changed Privacy Policy effective for PHI we already have about you as well as any PHI we receive in the future.

NOTICE OF NONDISCRIMINATION:

BasePoint does not discriminate against any person on the ground of race, color, national origin, age, disability (physical or mental) or sex in admission to, participation in, or receipt of the services and benefits under any of its programs and activities, and in staff and employee assignments to patients. 

BasePoint provides: 

• Free aids and services to people with disabilities to communicate effectively with us, such as: Qualified sign language interpreters
• Written information in other formats (large print, audio, accessible electronic formats, other formats)
• Free language services to people whose primary language is not English, such as: Qualified interpreters and Information written in other languages

If you need these services or if you have questions, contact:

Reynalyn Hall

Reynalyn.Hall@basepointacademy.com

972-325-2633

If you believe that BasePoint has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance with: Reynalyn Hall.  You can file a grievance in person or by mail, fax, or email. 

If you need help filing a grievance, Reynalyn Hall is available to help you.  You may also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf or by mail or phone at: U.S. Department of Health and Human Services 200 Independence Avenue, SW Room 509F, HHH Building Washington, D.C. 20201 1-800-368-1019, 800-537-7697 (TDD).   Complaint forms are available at http://www.hhs.gov/ocr/office/file/index.htm