HIPAA Privacy Policy

HIPAA CONFIDENTIALITY
POLICY
It is the policy of JourneyPure, Inc. to maintain an individual’s right to privacy and confidentiality of
information. Information known or contained in the client’s medical record (known as protected
health information) shall be treated as confidential and will be released in appropriate circumstances
only with the written consent of the client or legal guardian. Information concerning patients, visitors
and staff shall be managed with the highest degree of appropriateness and confidentiality, pursuant
to organization wide policies and procedures.
Federal and State confidentiality regulations authorize disclosure of information regarding the
identity, diagnosis, prognosis, or treatment of Alcohol and Drug Program patients under specific
guidelines. JourneyPure, Inc. shall adhere to the regulations stipulated in the Code of Federal
Regulations (Title 42, Section 2.1 Through 2.67‐1).
The Notice of Privacy Practices shall be distributed to patients and available on the company website,
americanaddictioncenters.org.
PROCEDURES
 All employees at JourneyPure, Inc. having access to information concerning patients, such as
volunteers, staff members and physicians must hold all information in strict confidence, and
shall abide by the Health Insurance Portability and Accountability Act (HIPAA) regulations.
 Information concerning patients which may be considered ordinary facts and necessary for
planning of specific care and services, will be handled with professional discretion and on a
“need to know” basis.
 Information regarding physicians, staff members or volunteers is to be relayed to others as
appropriate to the related job function or task and/or to facilitate client care and services
only. Information regarding physicians, staff members or volunteers is to be kept on a
professional level, and only discussed in relationship to the individual’s purpose and function
within the institution.
 Requests for client information will be directed to the Health Information Management
Department. Disposition of such requests will be in accordance with the program’s
established policy and procedure for Release of Information and pursuant to the HIPAA
regulations.
 Advances in technology will be reviewed as these are made available to the institution, to
determine if these advances can be employed to improve privacy and confidentiality
practices.
 Personal opinions as to the competence of staff members or any staff members, are not to
be expressed in a public environment and should always be addressed to the staff member’s
supervisor for resolution.
 At no time shall physicians, staff members, volunteers or others associated with this program
engage in discussions of a personal nature which are unrelated to the organization’s mission,
values and purpose (i.e., gossip).
 At no time shall staff members, volunteers, or others associated with this program, who have
access to confidential client or program information, speak with the news media, or others
outside the program, without prior approval from administration. All encounters with the
news media should be directed to administration.
 All staff will be educated and trained about the requirements for information privacy and
confidentiality appropriate for each level of employee to carry out his/her healthcare function
within the program. Education and training includes orientation, initial education and any
ongoing education and training necessary related to changes with this organization’s
information confidentiality and privacy practices.
 Outcomes from monitoring activities will be analyzed to determine if improvements can be
made in privacy and confidentiality practices.
Any information, recorded or not, relating to a client of JourneyPure, Inc. is to be afforded full
confidentiality as outlined in the above regulations. Exceptions to confidentiality are as follows:
1. If information about suspected child/dependent adult/elderly abuse or neglect is
reported.
2. If patients threaten to harm themselves or others.
3. If the court orders that information be released.
4. If the client gives written permission to release information; or Disclosure is made to
medical personnel in a medical emergency or to qualified personnel for program audit or
program self‐evaluation.
All staff and volunteers must sign an Oath of Confidentiality before they begin working at JourneyPure,
Inc. The confidentiality policy and the exceptions to confidentiality must be explained fully to patients
at intake.
Telephone Answering: Program Representatives Properly trained to do so will answer the telephones.
All receptionists shall be trained to not acknowledge whether or not an individual is a client of the
program. All inquiries regarding individuals that are, or have been, or might be a potential client of
the program should be treated with complete confidentiality; the caller shall be respectfully informed
that this information cannot be acknowledged either way and if they would like to speak to someone
else, the call will be transferred to another staff member. Calls should then be transferred as follows:
 Current Patients: calls regarding current patients should be transferred to the Clinical
Director.
 Unknown or Past Patients: calls should be directed to whichever staff seems the most
appropriate: Clinical Director, Program Administrator or Clinical Staff.