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HIPAA NPA

Wisdom Medicine, Inc

Notice of HIPAA privacy practices

Last updated: March 2024

THIS HIPAA NOTICE OF PRIVACY PRACTICES (“Notice”) DESCRIBES HOW YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED BY WISDOM MEDICINE, INC AND OUR WELLNESS PRACTITIONERS (DEFINED BELOW) AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THE NOTICE CAREFULLY.

Wisdom Medicine, Inc (“Wisdom,” “we,” “our” or “us”) is dedicated to providing service with respect for your personal information. The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) requires us to ask each of our members to acknowledge receipt of our HIPAA Notice of Privacy Practices. The Notice is published on the Wisdom website, Wisdom mobile application, and available at Wisdom clinics (if applicable). You acknowledge receipt of the Notice by clicking on the “I Acknowledge Receipt of the Notice of HIPAA Privacy Practices” button, or by indicating your acknowledgement in another written or digital manner provided. You can receive a copy of the Notice by asking for one, or by printing one from our website at any time.

Wisdom contracts with professionals who practice in a wide range of areas of wellness including functional medicine, nutrition, health coaching, and mental health (collectively, “Wellness Practitioners”). All Wellness Practitioners follow this Notice. In addition, the Wellness Practitioners may share information with each other for your treatment and all Wellness Practitioners who work with a member will be able to access such member’s records on the Wisdom electronic records system. Collectively Wisdom and the Wellness Practitioners are referred to herein as the “Wisdom Health Group”.

Wisdom Health Group Responsibilities

 

Under HIPAA, the Wisdom Health Group must take steps to protect the privacy of your “Protected Health Information” (“PHI”). PHI includes information that we have created or received regarding your health or payment for your health. It includes both your medical records and personal information such as your name, social security number, financial information, address, and phone number.

Under federal law, we are required to:

  • Protect the privacy of your PHI. All Wisdom employees and all Wellness Practitioners are required to maintain the confidentiality of PHI and receive appropriate privacy training.
  • Provide you with this Notice of Privacy Practices explaining our duties and practices regarding your PHI
  • Notify you in the case of a breach of unsecured PHI
  • Follow the practices and procedures set forth in this Notice

Uses and Disclosures of Your Protected Health Information That Do Not Require Your Authorization

The Wisdom Health Group discloses PHI in a number of ways connected to your treatment, payment for your care, and operations. Some examples of how we may use or disclose your PHI without your authorization are listed below.

TREATMENT

  • Any Wellness Practitioners in the Wisdom network who are involved in your care will have access to your records on the Wisdom electronic records system.

PAYMENT

  • To bill you for services provided.

HEALTHCARE OPERATIONS

  • To administer and support our business activities.
  • To other individuals (such as consultants and attorneys) and other companies and organizations that help us with our business activities. (Note: If we share your PHI with other organizations for this purpose, they must agree to protect your privacy.)

OTHER

We may use or disclose your PHI without your authorization for legal and/or governmental purposes in the following circumstances:

  • As required by law – When we are required by laws, including workers’ compensation laws.
  • Public health and safety – To an authorized public health authority or individual to:
  • Protect public health and safety.
  • Prevent or control disease, injury, or disability.
  • Report vital statistics such as births or deaths.
  • Investigate or track problems with prescription drugs and medical devices.
  • Abuse or neglect – To government entities authorized to receive reports regarding abuse, neglect, or domestic violence.
  • Minors – In general, parents and legal guardians are legal representatives of minor patients. However, in certain circumstances, as dictated by state law, minors can act on their own behalf and consent to their own treatment. In general, we will share the PHI of a patient who is a minor with the minor’s parents or guardians, unless the minor could have consented to the care themselves (except where parental disclosure may be required per applicable law).
  • Oversight agencies – To health oversight agencies for certain activities such as audits, examinations, investigations, inspections, and licensures.
  • Legal proceedings – In the course of any legal proceeding or in response to an order of a court or administrative agency and in response to a subpoena, discovery request, or other lawful process.
  • Law enforcement – To law enforcement officials in certain circumstances for law enforcement purposes. By way of example and without limitation, disclosures may be made to identify or locate a suspect, witness, or missing person; to report a crime; or to provide information concerning victims of crimes.
  • Research – We may disclose health information about you for research purposes, subject to the confidentiality provisions of state and federal law. In most cases, we will ask for your written authorization before using your PHI or sharing it with others in order to conduct research.
  • We may also use or disclose your PHI without your authorization in the following miscellaneous circumstances:
  • Contacting you directly – We may use your PHI, including your email address or phone number, to contact you. For example, we may also use this information to send you appointment reminders and other communications relating to your care and treatment, or let you know about treatment alternatives or other health related services or benefits that may be of interest to you, via email, phone call, or text message.
  • Your member account – We may make certain PHI, such as information about care or treatment, appointment histories and other records, accessible to you through online tools, such as email or your member account.
  • Family and friends – To a member of your family, a relative, a close friend—or any other person you identify who is directly involved in your healthcare—when you are either not present or unable to make a healthcare decision for yourself and we determine that disclosure is in your best interest. We will also assume that we may disclose PHI to any person you permit to be physically present with you as we discuss your PHI with you. For example, we will assume that we may discuss your healthcare with a person you bring with you to your appointments.
  • Treatment alternatives and plan description – To communicate with you about treatment services, options, or alternatives, as well as health-related services that may be of interest to you, or to describe our providers to you.
  • Coroners, funeral directors, and organ donation – To coroners, funeral directors, and organ donation organizations as authorized by law.
  • Unless you notify us that you object, your name, location within our facility, and general information about your health condition may be disclosed to people who ask for you by name. Members of the clergy will be told your religious affiliation if they ask. This is to help your family, friends, and clergy visit you in the facility and generally know how you are doing.
  • Disaster relief – To an authorized public or private entity for disaster relief purposes. For example, we might disclose your PHI to help notify family members of your location or general condition.
  • Threat to health or safety – To avoid a serious threat to the health or safety of yourself and others.
  • De-identified information – If information is removed from your PHI so that you can’t be identified, except as prohibited by law.
  • Coroners, funeral directors, and organ donation – To coroners, funeral directors, and organ donation organizations as authorized by law.
  • Disaster relief – To an authorized public or private entity for disaster relief purposes. For example, we might disclose your PHI to help notify family members of your location or general condition.
  • Threat to health or safety – To avoid a serious threat to the health or safety of yourself and others.

Uses and Disclosures of Your Protected Health Information That Require Us to Obtain Your Authorization

Except in the situations listed in the sections above, we will use and disclose your PHI only with your written authorization. This means we will not use your PHI in the following cases, unless you give us written permission:

  • Marketing purposes, except as allowed by HIPAA or applicable law (by way of example, marketing communications allowed by HIPAA without authorization include communications pertaining to care or treatment and/or our products or services.)
  • Sale of your information.
  • Sharing your PHI with your employer or school.
  • Most sharing of psychotherapy notes.

In some situations, federal and state laws provide special protections for specific kinds of PHI and require authorization from you before we can disclose that specially protected PHI. For example, additional protections may apply in some states to genetic, mental health, drug and alcohol abuse, rape and sexual assault, sexually transmitted disease and/or HIV/AIDS-related information, and/or to the use of your PHI in certain review and disciplinary proceedings of healthcare professionals by state authorities. In these situations, we will comply with the more stringent state laws pertaining to such use or disclosure.

Your Rights Regarding Your Protected Health Information

You have the right to:

  • Request restrictions by asking that we limit the way we use or disclose your PHI for treatment, payment, or healthcare operations. You may also ask that we limit the information we give to someone who is involved in your care, such as a family or friend. Please note that we are not required to agree to your request. If we do agree, we will honor your limits unless it is an emergency situation.
  • Ask that we communicate with you by another means. For example, if you want us to communicate with you at a different address, we can usually accommodate that request. We may ask that you make your request to us in writing. We will agree to reasonable requests.
  • Request to access or receive an electronic or paper copy of your PHI. To access or receive a copy of your PHI, you can: (1) complete a Medical Records Request Form and submit it to info@wisdommedicine.com. We may charge a reasonable fee for the cost of producing or mailing the copies, which you will receive usually within 30 days. In certain situations, we may deny your request and will tell you why we are denying it. In some cases, you may have the right to ask for a review of our denial. We may charge a reasonable fee for the cost of producing or mailing the copies, which you will receive usually within 30 days. In certain situations, we may deny your request and will tell you why we are denying it. In some cases, you may have the right to ask for a review of our denial.
  • Ask to amend PHI we created that you feel is incorrect or incomplete. To request an amendment to your PHI that you believe is inaccurate or incomplete, please email info@wisdommedicine.com. In certain cases, we may deny your request and we will do so in writing. You may respond by filing a written statement of disagreement with us and ask that the statement be included with your PHI. You may respond by filing a written statement of disagreement with us and ask that the statement be included with your PHI.
  • Choose someone to act for you. If you have given someone power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information. We will confirm the person has the authority and can act for you before we take any action.
  • Seek an accounting of certain disclosures by asking us for a list of the times we have disclosed your PHI. To request an accounting of disclosures list, please email info@wisdommedicine.com. You may request disclosures made up to six years before your request. You may receive one list per year at no charge. If you request another list during the same year, we may charge you a reasonable fee. These lists will not include disclosures made for treatment, payment, or healthcare operations and certain other disclosures as permitted by law. You may request disclosures made up to six years before your request. You may receive one list per year at no charge. If you request another list during the same year, we may charge you a reasonable fee. These lists will not include disclosures made for treatment, payment, or healthcare operations and certain other disclosures as permitted by law.
  • Request a paper copy of this Notice.
  • Receive written notification of any breach of your unsecured PHI.
  • File a complaint if you believe your privacy rights have been violated. You can file a written complaint with us at the address below, or 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. We will not retaliate against you for filing a complaint.

Communication Platforms

We may also use PHI to send you appointment reminders and other communications relating to your care and treatment, or let you know about treatment alternatives or other health related services or benefits that may be of interest to you, via email, phone call, or text message.

If you choose to communicate with us via emails, texts or chats, you acknowledge that we may exchange PHI with you via email, text or chat, that email, text and certain chat functionality may not be a secure method of communication, and that you agree to the security risks of such communication. If you would prefer not to exchange PHI via email, text or chat, you can choose not to communicate with us via those means, and you can notify us atinfo@wisdomhealth.co.

Changes to Privacy Practices

We may modify this Notice from time to time. The revised Notice will apply to all PHI that we maintain. We will make any such changes to this Notice by posting the revised Notice on our website. The date of the last update will be clearly indicated at the top of this Notice. Please review this Notice from time to time to ensure you are familiar with our HIPAA privacy practices.

Questions and Complaints

If you have any questions about this Notice or would like an additional copy, please contact our  info@wisdommedicine.com.

If you think that we may have violated your privacy rights or you disagree with a decision we made about access to your PHI, you may send a written complaint to info@wisdommedicine.com.