Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW MEDICAL AND SUBSTANCE USE DISORDER INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Cliff Coaching, LLC ("Cliff Coaching," "we," "us") provides clinical assessments, interventions, treatment navigation, recovery coaching, family coaching, and therapy. In the course of that work we create and receive information about your health, including mental health and substance use information. This information is called Protected Health Information ("PHI"). We are required by law to keep your PHI private, to give you this notice of our legal duties and privacy practices, and to follow the terms of the notice currently in effect.

If you have questions about this notice, contact our Privacy Officer (see "Contact Us" at the end).

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get a copy of your health and claims records. You can ask to see or get an electronic or paper copy of your records and other health information we have about you. Ask us how to do this. We will provide a copy or a summary, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your records. You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this. We may say "no," but we will tell you why in writing within 60 days.

Request confidential communications. You can ask us to contact you in a specific way (for example, home or cell phone, or a specific email) or to send mail to a different address. We will say "yes" to all reasonable requests.

Ask us to limit what we use or share. You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree, and we may say "no" if it would affect your care. If you pay for a service or item out of pocket in full, you can ask us not to share that information with your health insurer for payment or operations purposes. We will say "yes" unless a law requires us to share that information.

Get a list of those with whom we've shared information. You can ask for a list (accounting) of the times we've shared your health information for six years prior to the date you ask, who we shared it with, and why. We will include all disclosures except those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We'll provide one accounting a year for free but may charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice. You can ask for a paper copy of this notice at any time, even if you have agreed to receive it electronically. We will provide you with a paper copy promptly.

Choose someone to act for you. If you have given someone medical power of attorney, or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will make sure the person has this authority and can act for you before we take any action.

Be notified of a breach. You have the right to be notified if a breach of your unsecured PHI occurs.

File a complaint if you feel your rights are violated. You can complain if you feel we have violated your rights by contacting our Privacy Officer using the information at the end of this notice. You can also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. We will not retaliate against you for filing a complaint.

For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

• Share information with your family, close friends, or others involved in your care (for example, a parent or spouse who is participating in family coaching or an intervention)
• Share information in a disaster relief situation

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

In these cases, we never share your information unless you give us written permission:

• Marketing purposes
• Sale of your information
• Most sharing of psychotherapy notes

In the case of fundraising, we may contact you for fundraising efforts, but you can tell us not to contact you again.

Family involvement. Much of our work involves families. Participation of a family member in services does not by itself give that family member access to your records. We will share your information with family members only as you authorize or as otherwise permitted by law.

How do we typically use or share your health information?

Treat you. We can use your health information and share it with other professionals who are treating you. Example: With your consent, a treatment navigator shares your assessment results with a treatment program you are being admitted to.

Run our organization. We can use and share your health information to run our practice, improve your care, and contact you when necessary. Example: We use health information about you to manage your services, schedule sessions, and supervise the quality of our staff's work.

Bill for your services. We can use and share your health information to bill and get payment from you, health plans, or other entities responsible for payment.

How else can we use or share your health information? We are allowed or required to share your information in other ways — usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes.

• Help with public health and safety issues, such as reporting suspected abuse, neglect, or domestic violence, or preventing or reducing a serious threat to anyone's health or safety
• Comply with the law, including with the Department of Health and Human Services if it wants to see that we're complying with federal privacy law
• Respond to organ and tissue donation requests and work with a medical examiner or funeral director
• Address workers' compensation, law enforcement, and other government requests, including for health oversight activities authorized by law and for special government functions such as military, national security, and presidential protective services
• Respond to lawsuits and legal actions, such as in response to a court or administrative order or subpoena (subject to the additional protections for substance use disorder records described below)
• Do research, under conditions required by law

Any other use or disclosure of your PHI not described in this notice will be made only with your written authorization. You may revoke an authorization in writing at any time, except to the extent we have already acted in reliance on it.

Some records relating to substance use disorder ("SUD") diagnosis, treatment, or referral are protected by a separate federal law, 42 U.S.C. § 290dd-2 and its regulations at 42 CFR Part 2 ("Part 2"). To the extent Part 2 applies to records we create or receive — including Part 2 records we receive from a treatment program with your consent — we will protect those records as Part 2 requires, in addition to the protections described above.

• Consent generally required. Except as described below, we will not use or disclose Part 2 records without your written consent. You may give a single consent for all future uses and disclosures for treatment, payment, and health care operations. Once disclosed under such a consent, a HIPAA covered entity or business associate that receives the records may further use and disclose them as HIPAA permits, other than for legal proceedings against you.
• Disclosures permitted without consent. Part 2 permits limited disclosures without your consent, including: to medical personnel in a bona fide medical emergency; for certain research, audit, and program evaluation activities; to report suspected child abuse or neglect as required by state law; to report a crime on our premises or against our personnel; to public health authorities if the information is de-identified; to qualified service organizations and our own staff as needed to provide services; and as authorized by a court order that meets Part 2 requirements.
• Legal proceedings. Part 2 records, or testimony relaying their content, will not be used or disclosed in any civil, criminal, administrative, or legislative proceeding against you unless you give specific written consent or a court issues an order that meets Part 2 requirements, accompanied by a subpoena or similar legal mandate.
• SUD counseling notes. Separate written consent is required to use or disclose SUD counseling notes, where they exist.
• Revoking consent. You may revoke your consent in writing at any time, except to the extent we have already acted in reliance on it.
• Your rights. In addition to the rights listed above, you may request restrictions on disclosures of Part 2 records, including disclosures you have otherwise consented to for treatment, payment, and health care operations; request a list of disclosures made under a general consent; and opt out of any fundraising communications. You may file a complaint about a Part 2 violation with us or with the Secretary of HHS as described in "Your Rights."
• Federal law does not protect information about a crime committed by a patient either on our premises or against our personnel, or about any threat to commit such a crime.

Where Indiana law or the law of another state in which you receive services is more protective of your health information than federal law — for example, laws governing mental health records — we will follow the more protective law.

• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
• We require our business associates — vendors that handle PHI on our behalf, such as scheduling, communication, and records systems — to sign agreements to protect your information.

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html

When you contact us through this website — by filling out a contact form, booking a consultation, calling, texting, or emailing — you may share personal or health information with us. We use that information only to respond to you and to provide or arrange services. We do not sell your information. Once you become a client, information you provide is protected as described in this notice.

Email, text messaging, and web forms may not be fully secure. Please avoid sending detailed health information through these channels until you have spoken with a member of our team. In an emergency, call 911 or the 988 Suicide & Crisis Lifeline.

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website.