Notice of Privacy Practices
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Who This Notice Applies To
This Notice describes the privacy practices of NSH Operations, LLC and its NeuroHome telehealth program (collectively, "NeuroHome," "we," "us," or "our"). It applies to all Protected Health Information ("PHI") about you or your child that we create, receive, or maintain in connection with delivering the NeuroHome program.
If you are a parent or legal guardian receiving this Notice on behalf of a minor child, the rights described below generally belong to you on the child's behalf. State law may grant minors specific rights over their own health information in certain circumstances (for example, mental-health care after a certain age); we will follow applicable state law in those cases.
Our Responsibilities
We are required by law to:
- Maintain the privacy and security of your PHI
- Give you this Notice of our legal duties and privacy practices with respect to your PHI
- Follow the terms of the Notice currently in effect
- Notify you promptly if a breach occurs that may have compromised the privacy or security of your PHI
How We May Use and Disclose Your PHI Without Your Authorization
Federal law permits or requires us to use and disclose your PHI without your written authorization for the following purposes:
For Treatment
We use and share PHI to provide your child's care, for example, when a NeuroHome clinician reviews intake forms, develops a home protocol, conducts a telehealth session, or coordinates with another provider involved in your child's care (with your permission where required).
For Payment
We use and share PHI to bill and collect payment for our services. For example, we may share information with a payment processor or, in the future, with an insurer if NeuroHome bills insurance for a particular family.
For Health Care Operations
We may use your child's health information for treatment, care coordination, quality assurance, clinical review, professional training, and other healthcare operations. Authorized members of the NeuroHome clinical team may review health information as necessary to coordinate services, evaluate quality and safety, and support the operation of the clinical program. Each licensed healthcare professional remains responsible for care and professional decisions within the scope of their own license.
To Business Associates
We share PHI with vendors who help us deliver the program under signed Business Associate Agreements. These include, but may not be limited to:
- Zoom for Healthcare: telehealth video sessions
- GoHighLevel: scheduling, secure messaging, and clinical workflow
- Cloud-storage and electronic-health-record vendors that host clinical documentation
- Shipping carriers that deliver the home kit (limited to shipping address only)
Each Business Associate is contractually required to protect your PHI to the same standard we are.
For Public Health and Safety
We may disclose PHI when required by law for public-health activities (such as reporting communicable diseases), to prevent serious harm to you or others, or in response to suspected abuse or neglect of a child. As mandated reporters in Louisiana and Georgia, our clinicians are required by state law to report suspected child abuse or neglect to the appropriate authorities.
For Health Oversight, Lawsuits, and Law Enforcement
We may disclose PHI to government agencies that oversee our practice, in response to a valid court order, subpoena, or warrant, and to law enforcement in certain narrowly defined circumstances permitted by HIPAA.
To Family Members and Others Involved in Care
For minor patients, we routinely share PHI with the enrolled parent or legal guardian who is responsible for the child's care. We will not share PHI with other family members (extended family, separated parents who are not the enrolled guardian, etc.) without your written authorization, unless required by law or in an emergency.
Other Required Disclosures
We will disclose PHI when required by federal, state, or local law, including disclosures to the U.S. Department of Health and Human Services to investigate or determine our compliance with HIPAA.
Uses and Disclosures Requiring Your Written Authorization
We will obtain your written authorization before using or disclosing PHI for any of the following:
- Marketing. We will not use your PHI for marketing or feature your child in promotional materials without your specific written authorization. A separate testimonial/media release is required before any photo, video, or quote can be used on our website or in advertising.
- Sale of PHI. We will never sell your PHI.
- Psychotherapy notes. Most disclosures of psychotherapy notes require your written authorization, with limited exceptions defined by law.
- Most other uses not described in this Notice.
You may revoke any authorization in writing at any time, except to the extent we have already acted in reliance on it.
Your Rights
You have the following rights with respect to PHI we maintain about you or your child:
Right to Inspect and Copy
You have the right to inspect and receive a copy of PHI we use to make decisions about your care. We will respond to your request within 30 days. We may charge a reasonable, cost-based fee for copies as permitted by law.
Right to Amend
If you believe PHI we have about you is incorrect or incomplete, you may ask us to amend the record. We may deny your request in certain circumstances, but you have the right to file a written statement of disagreement.
Right to an Accounting of Disclosures
You have the right to receive a list of certain disclosures we have made of your PHI for purposes other than treatment, payment, or health care operations during the previous six years.
Right to Request Restrictions
You have the right to request that we restrict how we use or disclose your PHI for treatment, payment, or operations. We are not required to agree to most restriction requests, but if we do agree, we will honor the restriction (subject to limited exceptions). We are required to agree to a request to restrict disclosure to a health plan for services you paid for in full out of pocket.
Right to Confidential Communications
You have the right to request that we communicate with you about health matters in a specific way or at a specific location (for example, by mail to a particular address rather than by phone). 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. Email hello@neurohome.app to request one.
Right to Be Notified of a Breach
You have the right to be notified if we (or one of our Business Associates) discover a breach of unsecured PHI affecting you or your child.
Right to Complain
If you believe your privacy rights have been violated, you may file a complaint with us or with the U.S. Department of Health and Human Services Office for Civil Rights. We will not retaliate against you for filing a complaint.
- To file with NeuroHome: Contact our Privacy Officer at hello@neurohome.app
- To file with HHS: www.hhs.gov/hipaa/filing-a-complaint/
Changes to This Notice
We reserve the right to change this Notice and to make the revised Notice effective for PHI we already have about you as well as any information we receive in the future. We will post the current Notice on this page and provide a copy to new patients at intake. The Notice will display the effective date.
Contact Our Privacy Officer
For questions about this Notice, to exercise any of the rights described above, or to file a complaint:
- Email: hello@neurohome.app
- Subject line: "Privacy Officer - [your topic]"