Confidentiality and privacy are the cornerstones of the mental health professions. Clients have an expectation that their communications with therapists, and their treatment records, will generally be kept confidential and will not be released to others without the written authorization of the client. One of the purposes of the Notice of Privacy Practices is to inform and educate clients about the fact that there are exceptions to the general rule of confidentiality. Many of these exceptions have existed for years, and many of them are the result of laws and regulations being passed by state legislatures and by the federal government. These laws and regulations are essentially statements of public policy. My office policies and procedures, as well as the ethical standards of my profession, are intended to shape my practice so that privacy and confidentiality are maintained, consistent with Michigan law and the federal “Privacy Rule.”

1. Privacy Officer: I, Lori Hall, MSW, LMFT, CAC-II am the privacy officer for this practice. I am the one responsible for developing and implementing these policies and procedures.
2. Contact Person: I, Lori Hall, MSW, LMFT, CAC-II, am the contact person for this practice. If a client needs or desires further information related to the Notice of Privacy Practices, or if the client has a complaint regarding these policies and procedures or compliance with them, I am the person who should be contacted.
3. The effective date of these policies and procedures is April 14, 2003.
4. I will maintain documentation of all consents, authorizations, Notices of Privacy Practices, Office Policies and Procedures, trainings, and client requests for records or for amendments to records. I will also document complaints received and their disposition.
5. Lori Hall, MSW, LMFT, CAC-II is the sole owner/employee of ReLife.
6. I will not maintain or use client sign-in sheets.
7. Conversations regarding confidential material or information will take place in an area and in a manner where they will not be easily overheard. 
8. Client records will be kept in locked file cabinets in my individual office. My individual office is locked when I am not there. Client records will not be left in places in my office where others are able to see its contents.
9. Computers will be placed appropriately and with password and firewall protection so that confidential information transmitted or received is not seen by others.
10. With respect to electronic equipment such as computers, I will periodically change the computer passwords to further ensure confidentiality.
11. With respect to office keys, myself, the colleague I share office space with and building management are the only persons with access to the office suite.
12. Since I am the sole owner of a private practice, I have not had the need to develop and implement a formal disciplinary policy. I will act in good faith and will do my best to correct errors or deficiencies that become known to me.
13. Information and records concerning a client may be disclosed as described in the Notice of Privacy Practices and in accordance with applicable law or regulation. I will obtain a written authorization from the client before releasing information to third parties for purposes other than treatment payment, and health care operations, unless disclosure is required by law or permitted by law.
14. If mental health records are subpoenaed by an adverse party I will assert the psychotherapist-patient privilege on behalf of the client and will thereafter act according to the wishes of the client and the client’s attorney, unless I am ordered by a Court or other lawful authority to release records or portions thereof.
15. To the extent that I keep client records electronically (e.g. on my computer), I will backup the computer files on a daily basis and will store the backup offsite. By doing so, I will be prepared in the case of an incident of some kind that causes  destruction, deletion, or damage to electronically stored client records.
16. I keep client records for at least seven years from the date of last treatment. With respect to the records of a minor, I keep those records for at least seven years or until the patient is twenty-one years old, whichever is longer. Thereafter, I may destroy patient records. When records are destroyed, they will be destroyed in a manner that protects patient privacy and confidentiality.
17. I will attempt to find out from clients, as early as possible, whether they have any objection to me sending correspondence to their residence (e.g., claim forms, bills) and whether I am permitted to call them at their residence or elsewhere to change appointment times or dates, or to discuss matters related to their treatment.
18. If I share protected health information about a client with third party business associates as part of my health care operations (e.g., a billing or transcription service), I will have a written contract with that business associate that contains terms that will protect the privacy of the client’s protected health information.
19. My duty of confidentiality and the psychotherapist-patient privilege survive the death of a patient.
20. With respect to email communications, I will do my best to ensure that communications can only be opened by the person to whom they are being sent.
21. I will do my best to ensure that electronic information, such as billing records and correspondence, is protected from computer viruses and unauthorized intruders.

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Last modified: July 09, 2008