Notice of Privacy Practices

Our Pledge Regarding Your Health Information

We understand that information about you and your health is personal. We are committed to protecting that information. This Notice applies to all of the records of your care generated by Hew Health.

How We May Use and Disclose Your PHI Without Your Written Authorization

We may use and disclose your PHI for the following purposes without first obtaining your written authorization:

Treatment

We may use and disclose your PHI to provide, coordinate, or manage your healthcare and any related services. This includes coordination among your Hew Health providers, sharing information with pharmacies that fill your prescriptions, laboratories that process your specimens, and other treating providers you authorize.

Payment

We may use and disclose your PHI to obtain payment for the healthcare services we provide. Hew Health is a cash-pay practice; we generally do not bill insurance. However, we may need to provide information to financial institutions, payment processors, or to you to facilitate payment.

Healthcare Operations

We may use and disclose your PHI for activities necessary to run our practice — including quality assessment and improvement, provider training and credentialing, accreditation, business planning, customer service, and compliance with this Notice and applicable laws.

Business Associates

We contract with outside individuals and organizations to perform certain services on our behalf — for example, our electronic medical records platform, telemedicine platform, secure messaging system, communications providers, and IT support vendors. When these services involve access to your PHI, we require these "Business Associates" to sign Business Associate Agreements committing them to protect your PHI consistent with HIPAA.

Appointment Reminders and Treatment Alternatives

We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.

As Required by Law

We will disclose your PHI when required by federal, state, or local law.

Public Health and Safety

We may disclose your PHI for public health activities, including preventing or controlling disease, reporting adverse events related to medications or medical devices, and notifying persons who may have been exposed to a communicable disease.

Health Oversight Activities

We may disclose your PHI to a health oversight agency for activities authorized by law — including audits, investigations, inspections, and licensure.

Judicial and Administrative Proceedings

We may disclose your PHI in response to a court or administrative order, subpoena, discovery request, or other lawful process.

Law Enforcement

We may disclose your PHI to law enforcement officials for purposes authorized by law — including responding to a court order, identifying or locating a suspect or missing person, or reporting certain types of injuries.

Coroners, Medical Examiners, and Funeral Directors

We may disclose PHI to a coroner, medical examiner, or funeral director as necessary to carry out their duties.

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.

Specialized Government Functions

We may disclose PHI for military and veterans' activities, national security and intelligence, protective services, and certain other government functions.

Workers' Compensation

We may release PHI for workers' compensation or similar programs that provide benefits for work-related injuries or illness.

Uses and Disclosures That Require Your Written Authorization

Other than as described above, we will not use or disclose your PHI without your written authorization. In particular, the following always require your written authorization:

• Most uses and disclosures of psychotherapy notes
• Uses and disclosures for marketing purposes
• Disclosures that constitute a sale of PHI

You may revoke any authorization you give us at any time, in writing. The revocation will be effective except to the extent we have already taken action in reliance on it.

Your Rights Regarding Your PHI

You have the following rights regarding the PHI we maintain about you:

Right to Inspect and Copy

You have the right to inspect and obtain a copy of your PHI maintained by us, in paper or electronic format. We may charge a reasonable, cost-based fee for copies as permitted by law. We may deny your request in certain limited circumstances; if we do, we will provide a written explanation and information about your appeal rights.

Right to Amend

You have the right to request that we amend PHI we maintain about you if you believe it is incorrect or incomplete. Your request must be made in writing and include a reason supporting the request. We may deny your request in certain circumstances; if we do, you have the right to file a statement of disagreement, which we will include in your records.

Right to an Accounting of Disclosures

You have the right to receive a list ("accounting") of disclosures of your PHI we have made in the previous six years, with certain exceptions (for example, disclosures for treatment, payment, healthcare operations, and disclosures made with your authorization are not included). Your request must be made in writing.

Right to Request Restrictions

You have the right to request a restriction or limitation on the PHI we use or disclose for treatment, payment, or healthcare operations, or to a family member or friend involved in your care. We are not required to agree to most restrictions, but we will accommodate reasonable requests where possible. However, we are required to comply with your request to restrict disclosure of PHI to a health plan if the disclosure is for the purpose of payment or healthcare operations and the PHI pertains solely to a healthcare item or service for which you have paid us in full out of pocket.

Right to Request Confidential Communications

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location — for example, that we contact you only at work, or by mail only. We will accommodate reasonable requests.

Right to a Paper Copy of This Notice

You have the right to a paper copy of this Notice at any time, even if you have agreed to receive it electronically.

Right to Be Notified of a Breach

You have the right to be notified following a breach of your unsecured PHI as required by federal law.

Right to Opt Out of Fundraising and Marketing Communications

If we use your PHI to contact you for fundraising or for marketing purposes for which authorization is not required, you have the right to opt out of receiving such communications.

Florida Law

Florida law may provide you greater privacy protections than federal law in certain circumstances. Where Florida law affords greater protection, we will follow Florida law. This includes, but is not limited to, additional protections for HIV/AIDS-related information, mental health information, and substance use disorder treatment information.

Changes to This Notice

We reserve the right to change this Notice at any time and to make the revised Notice effective for all PHI we maintain. We will post the current Notice in our offices, on our website, and provide a copy upon request. The Notice will contain the effective date on the first page.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the U.S. Department of Health and Human Services. You will not be retaliated against for filing a complaint.

To file a complaint with Hew Health, contact:

To file a complaint with the federal government, contact:

For More Information

If you have questions about this Notice or want more information about our privacy practices, please contact our HIPAA Privacy Officer at the address above.