Privacy and Consent

Listed below is information on our Privacy Practices and Consent for Services. All incoming clients of Suppression 2 Expression Counseling will receive a copy of these notices to review and sign. These are required to be completed before the start of the first session.

There is also a notice pertaining to Telehealth, this is not a form that will need to be signed, it is strictly informational.

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.

Suppression Expression Counseling, LLC (The Practice) is committed to protecting your privacy. The Practice is required by federal law to maintain the privacy of Protected Health Information (“PHI”), which is information that identifies or could be used to identify you. The Practice is required to provide you with this Notice of Privacy Practices (this “Notice”), which explains the Practice's legal duties and privacy practices and your rights regarding PHI I. OUR PLEDGE REGARDING HEALTH INFORMATION:

We understand that health information about you and your health care is personal. We are committed to protecting health information about you. We create a record of the care and services you receive from us. We need this record to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by this mental health care practice. This notice will tell you about the ways in which we may use and disclose health information about you. We also describe your rights to the health information we keep about you, and describe certain obligations we have regarding the use and disclosure of your health information. We am required by law to:

• Make sure that protected health information (“PHI”) that identifies you is kept private.

• Give you this notice of my legal duties and privacy practices with respect to health information.

• Follow the terms of the notice that is currently in effect.

• We can change the terms of this Notice, and such changes will apply to all information I have about you. The new Notice will be available upon request and on our website.

HOW WE MAY USE AND DISCLOSE HEALTH INFORMATION ABOUT YOU:

The following categories describe different ways that we use and disclose health information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

For Treatment Payment, or Health Care Operations: Federal privacy rules (regulations) allow health care providers who have direct treatment relationship with the patient/client to use or disclose the patient/client’s personal health information without the patient’s written authorization, to carry out the health care provider’s own treatment, payment or health care operations. We may also disclose your protected health information for the treatment activities of any health care provider. This too can be done without your written authorization. For example, if a clinician were to consult with another licensed health care provider about your condition, we would be permitted to use and disclose your person health information, which is otherwise confidential, in order to assist the clinician in diagnosis and treatment of your mental health condition.

Disclosures for treatment purposes are not limited to the minimum necessary standard. Because therapists and other health care providers need access to the full record and/or full and complete information in order to provide quality care. The word “treatment” includes, among other things, the coordination and management of health care providers with a third party, consultations between health care providers and referrals of a patient for health care from one health care provider to another.

Lawsuits and Disputes: If you are involved in a lawsuit, I may disclose health information in response to a court or administrative order. We may also disclose health information about your child in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

CERTAIN USES AND DISCLOSURES REQUIRE YOUR AUTHORIZATION:

1. Psychotherapy Notes. We do keep “psychotherapy notes” as that term is defined in 45 CFR § 164.501, and any use or disclosure of such notes requires your Authorization unless the use or disclosure is:

• For our use in treating you.

• For our use in training or supervising mental health practitioners to help them improve their skills in group, joint, family, or individual counseling or therapy.

• For our use in defending myself in legal proceedings instituted by you.

• For use by the Secretary of Health and Human Services to investigate my compliance with HIPAA.

• Required by law and the use or disclosure is limited to the requirements of such law.

• Required by law for certain health oversight activities pertaining to the originator of the psychotherapy notes.

• Required by a coroner who is performing duties authorized by law.

• Required to help avert a serious threat to the health and safety of others.

2. Marketing Purposes. Our Practice will not use or disclose your PHI for marketing purposes.

3. Sale of PHI. Our Practice will not sell your PHI in the regular course of our business.

CERTAIN USES AND DISCLOSURES DO NOT REQUIRE YOUR AUTHORIZATION:

Subject to certain limitations in the law, we can use and disclose your PHI without your Authorization for the following reasons:

• When disclosure is required by state or federal law, and the use or disclosure complies with and is limited to the relevant requirements of such law.

• For public health activities, including reporting suspected child, elder, or dependent adult abuse, or preventing or reducing a serious threat to anyone’s health or safety.

• For health oversight activities, including audits and investigations.

• For judicial and administrative proceedings, including responding to a court or administrative order, although my preference is to obtain an Authorization from you before doing so.

• For law enforcement purposes, including reporting crimes occurring on my premises.

• To coroners or medical examiners, when such individuals are performing duties authorized by law.

• For research purposes, including studying and comparing the mental health of patients who received one form of therapy versus those who received another form of therapy for the same condition.

• Specialized government functions, including, ensuring the proper execution of military missions; protecting the President of the United States; conducting intelligence or counter-intelligence operations; or, helping to ensure the safety of those working within or housed in correctional institutions.

• For workers’ compensation purposes. Although our preference is to obtain an Authorization from you, we may provide your PHI in order to comply with workers’ compensation laws.

• Appointment reminders and health related benefits or services. We may use and disclose your PHI to contact you to remind you that you have an appointment with one of our Providers. We may also use and disclose your PHI to tell you about treatment alternatives, or other health care services or benefits that we offer or can refer you to.

CERTAIN USES AND DISCLOSURES REQUIRE YOU TO HAVE THE OPPORTUNITY TO OBJECT:

Disclosures to family, friends, or others. We may provide your PHI to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object in whole or in part. The opportunity to consent may be obtained retroactively in emergency situations.

YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI:

• The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask me not to use or disclose certain PHI for treatment, payment, or health care operations purposes. We are not required to agree to your request, and we may say “no” if we believe it would affect your health care.

• The Right to Request Restrictions for Out-of-Pocket Expenses Paid for In Full. You have the right to request restrictions on disclosures of your PHI to health plans for payment or health care operations purposes if the PHI pertains solely to a health care item or a health care service that you have paid for out-of-pocket in full.

• The Right to Choose How We Send PHI to You. You have the right to ask your Provider to contact you in a specific way (for example, home or office phone) or to send mail to a different address, and we will agree to all reasonable requests.

• The Right to See and Get Copies of Your PHI. Other than “psychotherapy notes,” you have the right to get an electronic or paper copy of your medical record and other information that we have about you. We will provide you with a copy of your record, or a summary of it, if you agree to receive a summary, within 30 days of receiving your written request, and we may charge a reasonable, cost based fee for doing so.

• The Right to Get a List of the Disclosures We Have Made. You have the right to request a list of instances in which your Provider has disclosed your PHI for purposes other than treatment, payment, or health care operations, or for which you provided me with an Authorization. We will respond to your request for an accounting of disclosures within 60 days of receiving your request. The list we will give you will include disclosures made in the last six years unless you request a shorter time. We will provide the list to you at no charge, but if you make more than one request in the same year, we will charge you a reasonable cost based fee for each additional request.

• The Right to Correct or Update Your PHI. If you believe that there is a mistake in your PHI, or that a piece of important information is missing from your PHI, you have the right to request that your Provider correct the existing information or add the missing information. We may say “no” to your request, but we will tell you why in writing within 60 days of receiving your request.

• The Right to Get a Paper or Electronic Copy of this Notice. You have the right get a paper copy of this Notice, and you have the right to get a copy of this notice by e-mail. And, even if you have agreed to receive this Notice via e-mail, you also have the right to request a paper copy of it.

EFFECTIVE DATE OF THIS NOTICE:

This notice went into effect on 04/08/2022


Consent for Services

This form is called a Consent for Services (the "Consent"). Your therapist, counselor, psychologist, doctor, or other health professional ("Provider") has asked you to read and sign this Consent before you start therapy. Please review the information. If you have any questions, contact your Provider.


THE THERAPY PROCESS


Therapy is a collaborative process where you and your Provider will work together on equal footing to achieve goals that you define. This means that you will follow a defined process supported by scientific evidence, where you and your Provider have specific rights and responsibilities. Therapy generally shows positive outcomes for individuals who follow the process. Better outcomes are often associated with a good relationship between a client and their Provider. To foster the best possible relationship, it is important you understand as much about the process before deciding to commit.


Therapy begins with the intake process. First, you will review your Provider's policies and procedures, talk about fees, identify emergency contacts, and decide if you want health insurance to pay your fees depending on your plan's benefits. Second, you will discuss what to expect during therapy, including the type of therapy, the length of treatment, and the risks and benefits. If your Provider is practicing under the supervision of another professional, your Provider will tell you about their supervision and the name of the supervising professional. Third, you will form a treatment plan, including the type of therapy, how often you will attend therapy, your short- and long-term goals, and the steps you will take to achieve them. Over time, you and your Provider may edit your treatment plan to be sure it describes your goals and steps you need to take. After intake, you will attend regular therapy sessions at your Provider's office or through video, called telehealth. Participation in therapy is voluntary - you can stop at any time. At some point, you will achieve your goals. At this time, you will review your progress, identify supports that will help you maintain your progress, and discuss how to return to therapy if you need it in the future.


TELEHEALTH SERVICES

To use telehealth, you need an internet connection and a device with a camera for video. Your Provider can explain how to log in and use any features on the telehealth platform. If telehealth is not a good fit for you, your Provider may refer you to another practice or provider. There are some risks and benefits to using telehealth:


Risks

• Privacy and Confidentiality. You may be asked to share personal information with the telehealth platform to create an account, such as your name, date of birth, location, and contact information. Your Provider carefully vets any telehealth platform to ensure your information is secured to the appropriate standards.

• Technology. At times, you could have problems with your internet, video, or sound. If you have issues during a session, your Provider will follow the backup plan that you agree to prior to sessions.

• Crisis Management. It may be difficult for your Provider to provide immediate support during an emergency or crisis. You and your Provider will develop a plan for emergencies or crises, such as choosing a local emergency contact, creating a communication plan, and making a list of local support, emergency, and crisis services.


Benefits

• Flexibility. You can attend therapy wherever is convenient for you.

• Ease of Access. You can attend telehealth sessions without worrying about traveling, meaning you can schedule less time per session and can attend therapy during inclement weather or illness.

• Counselor competency. If you live in a small or rural area, you may find it difficult to find competent care in certain areas you need to address in therapy. Telehealth helps provide access to therapists who have the necessary competencies to understand, empathize, and provide therapeutic care.


Recommendations

• Make sure that other people cannot hear your conversation or see your screen during sessions.

• Do not use video or audio to record your session unless you ask your Provider for their permission in advance.

• Make sure to let your Provider know if you are not in your usual location before starting any telehealth session.


CONFIDENTIALITY

Your Provider will not disclose your personal information without your permission unless required by law. If your Provider must disclose your personal information without your permission, your Provider will only disclose the minimum necessary to satisfy the obligation. However, there are a few exceptions.


• Your Provider may speak to other healthcare providers involved in your care.

• Your Provider may speak to emergency personnel.

• If you report that another healthcare provider is engaging in inappropriate behavior, your Provider may be required to report this information to the appropriate licensing board. Your Provider will discuss making this report with you first, and will only share the minimum information needed while making a report. If your Provider must share your personal information without getting your permission first, they will only share the minimum information needed. There are a few times that your Provider may not keep your personal information confidential.

• If your Provider believes there is a specific, credible threat of harm to someone else, they may be required by law or may make their own decision about whether to warn the other person and notify law enforcement. The term specific, credible threat is defined by state law. Your Provider can explain more if you have questions.

• If your Provider has reason to believe a minor or elderly individual is a victim of abuse or neglect, they are required by law to contact the appropriate authorities.

• If your Provider believes that you are at imminent risk of harming yourself, they may contact law enforcement or other crisis services. However, before contacting emergency or crisis services, your Provider will work with you to discuss other options to keep you safe.


RECORD KEEPING

Your Provider is required to keep records about your treatment. These records help ensure the quality and continuity of your care, as well as provide evidence that the services you receive meet the appropriate standards of care. Your records are maintained in an electronic health record provided by TherapyNotes. TherapyNotes has several safety features to protect your personal information, including advanced encryption techniques to make your personal information difficult to decode, firewalls to prevent unauthorized access, and a team of professionals monitoring the system for suspicious activity. TherapyNotes keeps records of all log-ins and actions within the system.


COMMUNICATION

At this practice the main method of contact between Provider and Clients, outside of scheduled therapy appointments, is via Email.


• Please note that Email is not a secure method of communication and should not be used to communicate personal information. You may choose to receive appointment reminders via text message, email, or both. You should carefully consider who may have access to your text messages or emails before choosing to communicate via either method.


Social Media/Review Websites

• If you try to communicate with your Provider via these methods, they will not respond. This includes any form of friend or contact request, @mention, direct message, wall post, and so on. This is to protect your confidentiality and ensure appropriate boundaries in therapy.

• Your provider may publish content on various social media websites or blogs. There is no expectation that you will follow, comment on, or otherwise engage with any content. If you do choose to follow your Provider on any platform, they will not follow you back.

• If you see your Provider on any form of review website, it is not a solicitation for a review. Many such sites scrape business listings and may automatically include your Provider. If you choose to leave a review of your Provider on any website, they will not respond. While you are always free to express yourself in the manner you choose, please be aware of the potential impact on your confidentiality prior to leaving a review. It is often impossible to remove reviews later, and some sites aggregate reviews from several platforms leading to your review appearing other places without your knowledge.


FEES AND PAYMENT FOR SERVICES

All payments are expected at the time of service. You will be provided with these costs prior to beginning therapy, and should confirm with your insurance if part or all of these fees may be covered. You should also know about the following:


No-Show and Late Cancellation Fees

• If you are unable to attend therapy, you must contact your Provider before your session. Otherwise, you may subject to fees outlined in your fee agreement. Insurance does not cover these fees. Cancellations and re-scheduled sessions will be subject to a $50 fee if notification is not received at least 24 hours in advance. This is necessary because a time commitment is made to you and is held exclusively for you.


Balance Accrual

• Full payment is due at the time of your session. If you are unable to pay, tell your Provider. Any balance due will continue to be due until paid in full. If necessary, your balance may be sent to a collections service.


Administrative Fees

• Your Provider may charge administrative fees for writing a letter or report at your request; consulting with another healthcare provider or other professional outside of normal case management practices; or for preparation, travel, and attendance at a court appearance. These fees are listed in the fee agreement. Payment is due in advance.

• Should your records or information be subpoenaed as part of a lawsuit you are party to, or the therapist’s testimony is requested by you or required by law, you will be responsible for and shall be expected to pay the costs involved. Insurance will not cover the following costs - Record Requests: $3 per page requested, and Report Writing, Deposition, Mediation, Testifying: $200 per hour including travel and waiting time.


Insurance Benefits

Before starting therapy, you should confirm with your insurance company if:

• Your benefits cover the type of therapy you will receive;

• Your benefits cover in-person and telehealth sessions;

• You may be responsible for any portion of the payment; and

• Your Provider is in-network or out-of-network.


Sharing Information with Insurance Companies

• If you choose to use insurance benefits to pay for services, you will be required to share personal information with your insurance company. Insurance companies keep personal information confidential unless they must share to act on your behalf, comply with federal or state law, or complete administrative work.

• By signing this consent form, you are agreeing to release information to your insurance company in order to submit insurance claims on your behalf. This authorization extends to the extent necessary to obtain payment for the services provided to me, and includes authorization to release information about mental health, substance use, or HIV diagnoses as required. This is also an agreement to authorize your insurance company, Medicare, or other third-party payers to make payments directly to this practice and its affiliates.


Covered and Non-Covered Services

• When your Provider is in-network, they have a contract with your insurance company. Your insurance plan may cover all or part of the cost of therapy. You are responsible for any part of this cost not covered by insurance, such as deductibles, copays, or coinsurance. You may also be responsible for any services not covered by your insurance.

• When your Provider is out-of-network, they do not have a contract with your insurance company. You can still choose to see your Provider; however, all fees will be due at the time of your session to your Provider. Your Provider will tell you if they can help you file for reimbursement from your insurance company. If your insurance company decides that they will not reimburse you, you are still responsible for the full amount.


Payment Methods

• The practice requires that you keep a valid credit card, debit card, HSA, or FSA on file in order to ensure efficient processing of co-payments, deductibles, self-pay payments, and cancelation fees. This information is required to be on file prior to the start of the first scheduled appointment. This card will be charged for the amount due at the time of service and for any fees you may accrue unless other arrangements have been made with the practice ahead of time. It is your responsibility to keep this information up to date, including providing new information if the card information changes or the account has insufficient funds to cover these charges.

• By signing this consent form, you are stating that you understand that you remain responsible for all amounts due, including (but not limited to) copays, coinsurance, deductible amounts, and all services not covered by your insurance plan (including those for which you fail to obtain prior authorization), and mutually agreed-upon services or fees that are deemed not medically necessary.


COMPLAINTS

If you feel your Provider has engaged in improper or unethical behavior, you can talk to them, or you may contact the licensing board that issued your Provider's license, your insurance company (if applicable), or the US Department of Health and Human Services.

Consent for Group Therapy

General Information

Please read through the information below and feel free to ask questions about group sessions and/or expectations to the coordinator of the group. Once you are ready to participate, please sign this informed consent form below so we will have on our records that you have read the information and that you have been properly informed about the therapy.

The Therapeutic Process

Group Therapy is a unique kind of therapy where a group of people who are likely experiencing similar challenges in the period of their lives gets together to share their difficulties which as a result give and at the same time, receive help from each other.

The sessions consist of processing on the issues that a member is involved where the others will give their feedback and reaction towards the said issue. This helps each member understand the issue from a different perspective in order to understand others. This also helps with one's reflection about their situation which can then help for insight and personal growth.

We make sure to maintain a safe environment that is conducive both for sharing and accepting each other where each can grow and trust one another and where each and everyone will feel respected and valued.

For the safety it is necessary that the following is required to be complied with by its members:

• Discussions made within the group session are not allowed to be discussed outside with anyone and should maintain the practice of confidentiality in order to build trust with fellow members.

• Members should maintain positivity and not induce disrespect among others.

• Members should not be drunk, nor they are allowed to take alcohol or take illicit drugs before or after therapy.

• Maintain conduct that brings respect to fellow members' thoughts, emotions, or behavior.

• Refrain from having a relationship with a fellow member other than therapeutic while engaged in the session.

Confidentiality

We respect each and everyone's right to privacy and confidentiality and we shall make sure to maintain it that way. However, please understand that this is not absolute and is limited to provide for by law. Certain limitations are as follows:

• If a client threatens or attempts to commit suicide or otherwise conducts him/her self in a manner in which there is a substantial risk of incurring serious bodily harm.

• If a client threatens grave bodily harm or death to another person.

• If the therapist has a reasonable suspicion that a client or other named victim is the perpetrator, observer of, or actual victim of physical, emotional or sexual abuse of children under the age of 18 years.

• Suspicions as stated above in the case of an elderly person who may be subjected to these abuses.

• Suspected neglect of the parties named in items #3 and # 4.

• Whenever we are summoned by court order to disclose information against a participant. However, we shall notify you and let you exercise your privilege in the right to deny the disclosure of your records with us.

• Your prior written consent to release records.

Occasionally your therapist may need to consult with other professionals in their areas of expertise in order to provide the best treatment. Information about you may be shared in this context without using your name.

The therapists should maintain a professional relationship with the participants at all times. Any relationship with a participant outside of the therapeutic setting may result in a "dual relationship" and may affect the goals of the session.

Telehealth During and After the COVID-19 Pandemic

Please note that while Telehealth is presently widely accepted by insurance companies and paid out at an equal rate as in-person sessions, it is possible for current policies surrounding telehealth to change after the pandemic is declared over (set for July 15th, unless extended).


Michigan has a law for “Coverage Parity.” This means that all private insurance providers are required to pay for telehealth sessions. This existed pre-pandemic, and will continue after the pandemic is declared over.


Michigan does not have a law for “Payment Parity.” This means that insurance providers are not required to pay for telehealth sessions the same way that they pay out for in-person sessions. As a result, some insurance providers may choose to change their pay scales for telehealth once this is no longer required due to the pandemic.


There is still a lot we do not know about how these laws could change in the future.


See this resource for up to date information on billing regulations for telehealth services.


Suppression 2 Expression Counseling has been sending letters to House and Senate Representatives in Michigan to urge them to change current Michigan law and add Payment Parity and advocate on behalf of our clients who need telehealth services.


There is a bill being reviewed by the House that addresses this issue, HB 5651. However, there is no hearing scheduled for it at this time, and it still needs to be voted on by both the House and the Senate.


Please be assured that regardless of what happens with Payment Parity, we fully plan to continue providing therapy services and will do so 100% telehealth. We will continue to accept any insurances that we are able to.