Notice of Privacy Practices

NOTICE OF PRIVACY PRACTICES

Effective Date: November 1, 2024

Please review this notice carefully. It describes how your medical information may be used and disclosed and how you can access this information.

Your Rights

You have specific rights regarding your health information, which include:

Requesting Restrictions: You may request restrictions on the use or disclosure of your health information for treatment, payment, and healthcare operations. First Step Pregnancy Clinic will consider all reasonable requests, although we are not required to agree in all cases.
Confidential Communications: You may ask to receive communications by alternative means or at alternative locations (e.g., at a different address or via specific contact methods).
Inspecting, Copying, and Amending Your Health Information: You have the right to access and obtain a copy of your health records in an electronic or paper format. You may also request corrections if you believe your information is incomplete or inaccurate. [Note: Our response time is now 15 days, with a possible 15-day extension.]
Accounting of Disclosures: You may request an accounting of certain disclosures made by First Step Pregnancy Clinic in the past six years, excluding disclosures for treatment, payment, or healthcare operations.
Paper Copy: You may request a paper copy of this notice at any time, even if you have agreed to receive it electronically.

To exercise these rights, please contact our HIPAA Privacy Officer at 802-775-5611.

Uses and Disclosures with Your Authorization

Certain uses and disclosures require your written authorization, including:

Marketing and Third-Party Disclosures: Uses of your health information for marketing or disclosures to third-party vendors not covered by business associate agreements require your prior written authorization.
Sensitive Health Information: Information related to substance use disorder (SUD), HIV/AIDS, or mental health may have additional protections under federal and state laws and may require special authorization.

You may revoke your authorization at any time in writing, and the revocation will apply to future uses and disclosures.

Health Information That Will Be Maintained

Records maintained by First Step Pregnancy Clinic may include:

Your name, billing address, and contact information
Your health condition and reason for seeking care
Dates and details of your visits
Clinical findings, such as test results, ultrasounds, and other diagnostic records

Primary Uses and Disclosures of Health Information

Your health information is used and disclosed only as allowed by law and includes the following uses:

1. Treatment: Information about your condition may be shared with other healthcare providers involved in your care for treatment purposes.

2. Healthcare Operations: Your information may be used for activities that support our operations, including quality assessments, staff training, and legal compliance.

3. Payment: Your information may be shared to bill and collect payment for the services provided. 4. Business Associates: Certain external parties help us perform essential tasks, such as billing and lab work. We have agreements with these entities to protect your information as required by HIPAA.

5. Appointment Reminders and Health-Related Communications: We may use your information to send you reminders or information about health-related services that could benefit you.

6. Fundraising Communications: You may be contacted for fundraising efforts. You have the option to opt-out of these communications.

Additional Uses and Disclosures without Consent

Certain circumstances allow First Step Pregnancy Clinic to use or disclose your health information without your authorization:

Public Health and Safety: To assist public health authorities in preventing or controlling disease, reporting adverse drug reactions, and other health issues.
Health Oversight: For government agencies conducting audits, investigations, or licensure reviews.
Legal Compliance and Law Enforcement: For legal compliance purposes, including subpoenas, court orders, and other legal processes.
Reproductive Health Information (RHI): Disclosures of RHI are limited under the 2024 HIPAA update. Law enforcement, health oversight, judicial, and coroner requests for RHI require an attestation confirming that the disclosure is not for prohibited purposes. RHI disclosures will not be used to investigate lawful reproductive health services.
SUD Record Protections: SUD information is protected under 42 CFR Part 2, which restricts certain disclosures without consent. This includes separate consent requirements for records used in legal proceedings.
Organ and Tissue Donation: If you are an organ donor, your information may be disclosed to facilitate organ donation.
Serious Threats to Health and Safety: If there is a serious and imminent threat, your information may be disclosed to prevent or lessen the threat.
Government and Military Activities: Information may be disclosed for certain government functions, including national security and military purposes.

Enhanced Protections for Specific Information

Certain types of health information may have additional protections:

Reproductive Health Information (RHI): Includes information on contraception, pregnancy, and abortion. Disclosures require additional attestations under federal law.
Substance Use Disorder (SUD) Records: Part 2 protections require specific consent for disclosures, particularly in legal cases.
HIV/AIDS and Mental Health Information: These records are subject to heightened protections under state law.

Complaints and Contact Information

If you believe your privacy rights have been violated, you may file a complaint with First Step Pregnancy Clinic or with the U.S. Department of Health and Human Services. Filing a complaint will not impact your treatment or services. To file a complaint, please contact:

HIPAA Privacy Officer:

Kaitlin Rosenberg, Executive Director

Address: 20 Washington St. Rutland, VT 05701

Phone: 802-775-5611

Email: Hello@firststeprutland.com

First Step Pregnancy Clinic will respond within 15 days if your information is maintained onsite, or within 30 days if it is stored offsite.

Notice Updates and Changes

First Step Pregnancy Clinic reserves the right to amend this Notice of Privacy Practices. Any updates will apply to all health information we maintain, and the latest version will be available at our locations and on our website.