All information that is provided during the screening, admission, and services/treatment process is considered confidential by the employees, interns, and volunteers of all Freedom House programs. We are required to protect the privacy of health information about you, and the disclosure of protected health information will be governed by North Carolina General Statute 122C, federal law regarding substance abuse records 42 CFR Part 2, and the Health Insurance Portability and Accountability Act of 1996, as well as any other applicable federal or state laws.

Exchange and use of protected health information between Freedom House staff and/or Freedom House programs for the purpose of services/treatment, payment, or healthcare operations will be permitted and based on “need to know” guidelines, and positional authority. For example:

• Information obtained about you by a counselor, case manager, doctor, nurse or other member of your services/treatment team will be recorded in your record and used to determine the course of services/treatment that should work best for you.
• Services/treatment team members will also be expected to discuss your progress in services/treatment on a routine basis.
• Information about the services you receive will be submitted and processed by the billing department so that we can be reimbursed.
• Your medical record may also be pulled for Quality Improvement review in preparation for an audit or for other internal review to improve the quality and effectiveness of the services we provide.

Disclosure of protected health information outside of Freedom House is permitted when you or your legal representative signs a written authorization, or gives verbal authorization in an emergency situation. Any authorization for disclosure may be revoked at any time, except to the extent that action has been taken in reliance on it. Authorizations for disclosure of protected health information shall be valid for one year from the date signed unless revoked by the consumer or their legal guardian prior to that date. Consumers or their legal guardian may revoke consent at any time by notifying staff verbally or in writing.

You have the right to request restriction of the disclosure of your health information, except when Freedom House is required to do so. Under the following specific conditions, disclosure of information outside of Freedom House is permitted and/or required by law and professional ethics without your specific authorization:

• When there is a medical or psychiatric emergency involving your health or safety or the safety of others.
• When Freedom House is required by law to report instances of neglect or abuse of a child or disabled adult.
• When the disclosure is for judicial or administrative proceedings and Freedom House is responding to an order of a court or administrative tribunal.
• When Freedom House is required by North Carolina Administrative Code to disclose physician information due to an incident which would cause health risk to other persons.
• When Freedom House authorizes research for the purpose of program planning and evaluation of services through the use of statistical information that cannot be linked to any individual.

Freedom House uses computerized records to meet statistical, financial, and medical record requirements. Freedom House will comply with expected norms for security of electronic records and will make every effort to secure any identifying information that is transmitted outside of the organization. When a copy of the record is required to be transported off-site, it will only be done when: responding to a subpoena, the record is needed for treatment, habilitation or audit purposes, the facility determines it is not feasible to bring a copy or a portion of the record to the local healthcare provider, or for the purposes of autopsy. If the record is taken off-site to another healthcare provider, it will remain in the hands of a Freedom House employee.

Your Rights Include:

• Right to request your medical record be designated as a “Secure/Hot File”
  All medical records are considered to be secure and confidential. However, if special circumstances exist (e.g., you are the neighbor of a Freedom House employee) you may request that your record be filed as a “Secured/Hot File”. We will make every effort to accommodate your request, but we are not required to do so.
• Right to inspect and request a copy of your medical record
  If you would like to inspect or receive a copy of your health information, please contact the manager of the program serving you for instructions on how to submit a written request. We may deny your request in very limited circumstances. If we deny your request, we will respond to you in writing, stating why we will not grant your request and describing any rights you may have to request a review of our denial. If your request is approved, we may charge a reasonable fee for the costs of copying, mailing or other supplies associated with any request for copies.
• Right to request amendment of any section of your medical record
  If you feel that we have information that is inaccurate or incomplete, you have the right to request that your record be amended. If we deny your request, we will notify you in writing of our reason and will describe your rights to provide a written statement disagreeing with our denial.
• Right to receive an accounting of disclosures that have occurred
  Each disclosure of protected health information will be documented in the medical record. You have the right to request an accounting of these disclosures for the previous six years beginning April 14, 2003.
• Right to request an alternative method of contact
  Freedom House may call you or mail information to you regarding appointment reminders, billing information, or other information about services/treatment alternatives or services that might be of interest to you. If you would like to request an alternative method of contact, please notify your service provider. We will accommodate reasonable requests, but may condition our accommodation on your providing us with information regarding how payment, if any, will be handled.
• Right to a copy of this Notice
  You have the right to receive a paper copy of this Notice. Freedom House reserves the right to change this notice and to make the new notice effective for all protected health information that is maintained in hard copy or electronic format. Revisions to the NOTICE OF PRIVACY PRACTICES will be made available at each facility for distribution to all consumers.

Freedom House recognizes the importance of confidentiality and your right to be fully informed of all regulations regarding protected health information. If you feel that your privacy rights have been violated, you may contact Freedom House’s VP of Quality Assurance and Training at 919-942-2803 to file a complaint. Or you may contact the Secretary of the North Carolina Department of Health & Human Services, 2001 Mail Service Center, Raleigh, North Carolina 27699-2001, or 919-733-4534; or the U.S. Secretary of Health & Human Services, 200 Independence Avenue SW, Washington, DC 20201, or 1-877-696-6775. Provision of services will not be affected by the filing of any complaint.

Effective Date: March 1, 2005