NOTICE OF PRIVACY RIGHTS

This Notice applies to Commonwealth Psychotherapy PLLC and describes how the Practice may use and disclose your protected health information and your rights concerning that information.

Commonwealth Psychotherapy PLLC (the “Practice”) is committed to protecting your privacy. The Practice is required by federal law to maintain the privacy of Protected Health Information (“PHI”), which is information that identifies or could be used to identify you. The Practice is required to provide you with this Notice of Privacy Practices (this “Notice”), which explains the Practice's legal duties and privacy practices and your rights regarding PHI that we collect and maintain.

YOUR RIGHTS

Your rights regarding PHI are explained below. To exercise these rights, please submit a written request to the Practice at the address noted below.

Massachusetts Confidentiality Protections

In addition to the privacy protections described in this Notice, Massachusetts law provides additional protections for the confidentiality of communications and clinical records maintained by licensed social workers. Information concerning your treatment, clinical records, and the fact that you are or have been a client of the Practice may be confidential under Massachusetts law. The Practice will comply with applicable Massachusetts confidentiality requirements and will disclose confidential information only as permitted or required by law.

To inspect and copy PHI.

  • You can ask for an electronic or paper copy of your PHI and clinical records, as permitted by applicable law. The Practice may charge a fee permitted by applicable Massachusetts and federal law for reproducing records.

  • In certain circumstances, Massachusetts law permits the Practice to deny access to clinical records when, in the social worker's reasonable professional judgment, allowing you to inspect or copy the record would adversely affect your physical or mental well-being. If the Practice declines to provide you with a copy of your clinical treatment record on this basis, the Practice will provide you with a treatment summary. If you continue to request a copy of the full clinical treatment record, the Practice will provide it to an attorney or psychotherapist designated by you, as required by Massachusetts law. Psychotherapy notes maintained separately from the clinical record are treated differently under HIPAA and generally are not available for client access. Other clinical records and health information may be available to you as provided by applicable federal and Massachusetts law.

To amend PHI.

  • You can ask to correct PHI you believe is incorrect or incomplete. The Practice may require you to make your request in writing and provide a reason for the request.

  • The Practice may deny your request. The Practice will send a written explanation for the denial and allow you to submit a written statement of disagreement.

To request confidential communications.

  • You can ask the Practice to contact you in a specific way. The Practice will say “yes” to all reasonable requests.

To limit what is used or shared.

  • You can ask the Practice not to use or share PHI for treatment, payment, or business operations. The Practice is not required to agree if it would affect your care.

  • If you pay for a service or health care item out-of-pocket in full, you can ask the Practice not to share PHI with your health insurer.

  • You can ask for the Practice not to share your PHI with family members or friends by stating the specific restriction requested and to whom you want the restriction to apply.

To obtain a list of those with whom your PHI has been shared.

  • You can request an accounting of certain disclosures of your PHI made by the Practice, subject to the exceptions and limitations established by federal law. You can receive one accounting in any 12-month period at no charge. The Practice may charge a reasonable, cost-based fee for additional requests within the same 12-month period, provided that you are informed of the fee in advance and given an opportunity to withdraw or modify your request.

To receive a copy of this Notice.

  • You can ask for a paper copy of this Notice, even if you agreed to receive the Notice electronically.

To 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.

To file a complaint if you feel your rights are violated.

  • You can file a complaint by contacting the Practice.

  • You can 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/.

  • You may also contact the Massachusetts Board of Registration of Social Workers regarding concerns about professional conduct or compliance with applicable social-work laws and regulations.

  • The Practice will not retaliate against you for filing a complaint.

To file a complaint or exercise your rights, contact the practice using the information below:

Commonwealth Psychotherapy PLLC
185 Devonshire St, 5th Floor, Boston, MA 02110
Privacy Officer: Julia Averna, LICSW
Phone: 617-221-3174

OUR USES AND DISCLOSURES

1. Routine Uses and Disclosures of PHI

The Practice is permitted under federal law to use and disclose PHI, without your written authorization, for certain routine uses and disclosures, such as those made for treatment, payment, and the operation of our business. The Practice typically uses or shares your health information in the following ways:

To treat you.

  • The Practice may use and disclose PHI to coordinate and provide your treatment, including sharing information with other health care professionals involved in your care, as permitted by law.

  • Example: The Practice may communicate with another health care professional involved in your care to coordinate treatment, as permitted by law.

To run the health care operations.

  • The Practice can use and share PHI to conduct health care operations, improve the quality of care, and carry out other activities permitted by law.

  • Example: The Practice may use your contact information to send appointment reminders if you choose.

To bill for your services.

  • The Practice can use and share PHI to bill and get payment from health plans or other entities.

  • Example: The Practice gives PHI to your health insurance plan so it will pay for your services.

2. Uses and Disclosures of PHI That May Be Made Without Your Authorization or Opportunity to Object

The Practice may use or disclose PHI without your authorization or an opportunity for you to object, including:

To help with public health and safety issues

  • Public health: To prevent the spread of disease, assist in product recalls, and report adverse reactions to medication.

  • Required by the Secretary of Health and Human Services: We may be required to disclose your PHI to the Secretary of Health and Human Services to investigate or determine our compliance with the requirements of the final rule on Standards for Privacy of Individually Identifiable Health Information.

  • Health oversight: For audits, investigations, and inspections by government agencies that oversee the health care system, government benefit programs, other government regulatory programs, and civil rights laws.

  • Serious threat to health or safety: To prevent or lessen a serious, foreseeable, and imminent threat to the health or safety of you, another person, or the public, as permitted or required by law.

  • Abuse or Neglect: To report abuse, neglect, or domestic violence.

To comply with law, law enforcement, or other government requests

  • Required by law: If required by federal, state or local law.

  • Judicial and administrative proceedings: To respond to a court order, subpoena, or discovery request.

  • Law enforcement: The Practice may disclose PHI to law enforcement officials when permitted or required by applicable federal or Massachusetts law, including in response to a valid legal process or in other circumstances specifically authorized by law.

  • Specialized Government Functions: For military or national security concerns, including intelligence, protective services for heads of state, or your security clearance.

  • National security and intelligence activities: For intelligence, counterintelligence, protection of the President, other authorized persons or foreign heads of state, for purpose of determining your own security clearance and other national security activities authorized by law.

  • Workers' Compensation: The Practice may disclose PHI as authorized or required by workers' compensation laws.

To comply with other requests

  • Coroners and Funeral Directors: To perform their legally authorized duties.

  • Organ Donation: For organ donation or transplantation.

  • Research: For research that has been approved by an institutional review board.

  • Inmates: To correctional institutions or law enforcement officials when permitted by law to provide health care, protect health or safety, or for other permitted purposes.

  • Business Associates: To organizations that perform functions, activities or services on our behalf.

3. Uses and Disclosures of PHI That May Be Made With Your Authorization or Opportunity to Object

Unless you object, the Practice may disclose PHI:

  • To a family member, close personal friend, or another person you identify as being involved in your care or payment for your care, when the information disclosed is directly relevant to that person's involvement, and when you have been given an opportunity to agree or object when required by law.

  • If you are unable to agree or object to a disclosure, the Practice may, using its professional judgment, determine whether the disclosure is in your best interests and is permitted by applicable law.

4. Uses and Disclosures of PHI Based Upon Your Written Authorization

The Practice generally must obtain your written authorization before using or disclosing your PHI for the following purposes, except where federal or Massachusetts law permits or requires the use or disclosure without authorization:

  • Marketing,

  • Sale of PHI, or

  • Psychotherapy notes.

5. Uses and Disclosures of Substance Use Disorder Records Subject to 42 CFR Part 2

If applicable, certain substance use disorder (“SUD”) records may be subject to additional federal confidentiality protections under 42 C.F.R. Part 2 (“Part 2”). Part 2 may impose restrictions on the use and disclosure of SUD records that are maintained by a Part 2 program.

When Part 2 applies, the Practice will comply with the applicable requirements of Part 2, including requirements concerning patient consent, permitted uses and disclosures, and restrictions on the use and disclosure of Part 2 records in legal proceedings.

Part 2 protections may apply differently depending on the type of record and the circumstances under which the record was created or received. Nothing in this Notice is intended to reduce any confidentiality protections provided by applicable federal or Massachusetts law.

If the Practice receives Part 2 records from another provider or program, the Practice will handle those records in accordance with applicable Part 2 requirements and other applicable privacy laws.

You may revoke this authorization at any time, as permitted by applicable law.

You may revoke a written authorization in writing at any time, to the extent permitted by applicable law. Revocation will not affect any action the Practice has already taken in reliance on the authorization. The Practice will not use or disclose your PHI other than as described in this Notice or as otherwise permitted or required by law. Where your written authorization is required, the Practice will obtain your authorization before making the use or disclosure.

OUR RESPONSIBILITIES

  • The Practice is required by law to maintain the privacy and security of PHI.

  • The Practice is required to abide by the terms of this Notice currently in effect. Where more stringent state or federal law governs PHI, the Practice will abide by the more stringent law.

  • The Practice reserves the right to amend this Notice. All changes are applicable to PHI collected and maintained by the Practice. Should the Practice make changes, you may obtain a revised Notice by requesting a copy from the Practice using the contact information above. A current copy of this Notice will also be posted on the Practice’s website.

  • The Practice will notify you of a breach of your unsecured PHI when notification is required by applicable federal or Massachusetts law.

This Notice is effective on 9/12/2026.