HIPAA Notice of Privacy Practices

Purpose

Access Path Management, LLC d/b/a ProviderNotes.com ("Access Path," "we," or "us") respects your privacy and is required by law to: (1) maintain the privacy of your protected health information ("PHI") under the Health Insurance Portability and Accountability Act ("HIPAA"); (2) provide you with this Notice of our legal duties and privacy practices; and (3) notify you in the event of a breach of your unsecured PHI.

This Notice describes our legal duties and privacy practices regarding your PHI, how we may use and disclose your PHI, and your rights with respect to your PHI.

Contact

Questions about this Notice may be directed to:

PHI Defined

PHI is health information about you that may be used to identify you and that we maintain or transmit in electronic, oral, or written form, including information about your health condition, treatment, or payment for services.

Scope

We create and maintain records of the care and services you receive in order to provide care and comply with legal requirements. This Notice applies to all PHI that we create or maintain.

Telehealth Services and Service States

Certain services are provided via telehealth. Telehealth encounters occur only when you are physically located in a state where the treating clinician is licensed and authorized to provide services (each, a "Service State"). We do not use or disclose PHI in connection with telehealth services outside permitted Service States. Telehealth communications and records are protected as PHI under HIPAA and applicable state law, including Florida law, which may impose additional privacy protections beyond HIPAA. We will comply with applicable state law where it affords greater privacy protections than HIPAA.

Website Privacy Policy Relationship

Information collected through our public website or online intake tools is also governed by our Website Privacy Policy. To the extent information collected through the website becomes PHI, it is protected under this Notice. If there is any conflict between this Notice and the Website Privacy Policy with respect to PHI, this Notice controls.

Your Rights

You have the following rights regarding your PHI:

• Right to Inspect and Copy: You have the right to inspect and obtain a copy of your PHI that we maintain. Requests must be submitted in writing to the contact above.
• Right to Amend: You have the right to request that we amend PHI you believe is inaccurate or incomplete. We may deny your request under certain circumstances.
• Right to Request Restrictions: You have the right to request restrictions on certain uses or disclosures of your PHI. We are not required to agree to all requests, but will comply with any restriction we do agree to. However, we are required by law to agree to a request to restrict disclosure of your PHI to a health plan if the disclosure is for payment or healthcare operations purposes and the PHI pertains solely to a service for which you have paid us out of pocket in full.
• Right to Confidential Communications: You have the right to request that we communicate with you about your PHI in a certain way or at a certain location.
• Right to an Accounting of Disclosures: You have the right to request a list of certain disclosures of your PHI we have made.
• Right to a Personal Representative: You may designate a personal representative to act on your behalf regarding your PHI.
• Right to Receive a Paper Copy of This Notice: You have the right to receive a paper copy of this Notice upon request, even if you have agreed to receive it electronically.
• Right to Breach Notification: You have the right to be notified in the event of a breach of your unsecured PHI.
• Right to File a Complaint Without Retaliation: You have the right to file a complaint with us or with the U.S. Department of Health and Human Services without retaliation. See the Complaints section below.

Uses and Disclosures of PHI

We may use and disclose PHI for the following purposes:

• Treatment: To provide, coordinate, or manage your healthcare and related services. For example, we may share PHI with other treating clinicians involved in your care.
• Healthcare Operations: To support our business functions, such as quality assessment, training, and compliance activities.
• Payment: To process payment for services you receive. Because Access Path operates on a cash-pay basis, we use PHI for payment purposes only as necessary to process your payment or as required by law.
• As Required by Law: We will disclose PHI when required to do so by federal, state, or local law, including disclosures to public health authorities, in judicial or administrative proceedings, for law enforcement purposes, and to the U.S. Department of Health and Human Services for compliance reviews.
• Other Permitted Disclosures: We may use or disclose PHI for other purposes permitted by HIPAA, such as to avert a serious threat to health or safety, or to a patient's personal representative.
• With Your Authorization: Uses and disclosures not described in this Notice will be made only with your written authorization, which you may revoke at any time in writing.

We limit uses and disclosures to the minimum necessary to accomplish the intended purpose.

Payment

Access Path operates on a cash-pay basis. PHI is used for payment purposes only as necessary to process payment or as required by law.

Our Responsibilities

Access Path Management, LLC is required by law to:

• Maintain the privacy and security of your protected health information.
• Notify you promptly if a breach occurs that may have compromised the privacy or security of your PHI.
• Follow the duties and privacy practices described in this Notice and provide you with a copy of it.
• Not use or share your PHI other than as described in this Notice unless you provide written authorization. If you provide such authorization, you may revoke it in writing at any time.

For more information about your rights under HIPAA, visit: hhs.gov/hipaa/for-individuals/index.html

Changes to This Notice

We reserve the right to change this Notice at any time and to make the revised Notice effective for all PHI we maintain. We will promptly revise and distribute the updated Notice, which will include the new effective date. Updated Notices will be available upon request and posted on our website.

Complaints

You may file a complaint with Access Path using the contact information above or with the U.S. Department of Health and Human Services Office for Civil Rights at hhs.gov/hipaa/filing-a-complaint. We will not retaliate against you for filing a complaint.