Confidentiality Policy

POLICY

St. Anne’s will protect the confidentiality of information regarding clients and closely monitor the disclosure of confidential information.

PURPOSE

The purpose of this policy is to guarantee the privacy and confidentiality of client

information.

PROCEDURE

St. Anne’s understands the obligations regarding the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy, Security and Breach Notification Rules with respect to confidentiality, privacy, and security of patients’ medical information, and incorporates several steps to ensure these are protected.

1. All Employees will be trained regarding HIPAA and confidentiality policies during New Hire Orientation, annually, and as needed.

2. For the purpose of enhancing treatment and ensuring clients receive services

that meet their needs, Staff will discuss and have clients sign an acknowledgment that states confidentiality pertains to the client and St. Anne’s as the “Treatment Team”. For clients receiving services from more than one St. Anne’s Program, this means that Staff may share pertinent information with Staff providing services to the same client in a different Program in order to ensure all servicing Programs have the most current, accurate, and complete information. This also includes communication and review of client information for administrative and management purposes, such as agency quality assurance/improvement efforts.

a. In order to uphold the ethical standards and integrity of the agency, interprogram communication regarding clients will be limited to information considered pertinent to the treatment, wellbeing, and safety of clients.

3. The use or disclosure of all information pertaining to the client and his/her family will be restricted to purposes directly connected with the administration of the program.

4. During intake, St. Anne’s will inform clients of circumstances when the agency may be legally or ethically permitted or required to release information without the clients consent. St. Anne’s may use and disclose a client’s Personal Health Information (PHI) without their authorization only in the following ways:

a. Treatment: To a provider who requests this information to treat the client.

b. Payment: To pay claims for covered services provided to the client.

c. Care Coordination: To engage in care coordination and case management, and ensure all St. Anne’s providers have the information necessary to provide quality and individualized care.