Notice of Privacy Practices

Your Information | Your Rights | Our Responsibilities

Greater Nashua Mental Health (GNMH) is legally required to maintain the privacy and security of your Protected Health Information (PHI). PHI is the information you provide to us, we receive, and we create about your healthcare – including medical records and billing information. The Notice of Privacy Practices (NPP) or “Notice” provides information to you about our privacy practices and legal duties, and your rights relating to your PHI – GNMH is mandated to provide all our clients and/ or their lawful guardian a copy of this Notice. GNMH will abide by the terms of this Notice currently in effect, along with any future revisions that we may make to the Notice as required or authorized by law. Additionally, we will promptly notify you if a breach occurs that may have compromised the privacy or security of your PHI.

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.

PHI Uses/Disclosures Allowed Without Written Authorization

Following certain state and federal regulations, GNMH is allowed or may be required to use and/ or disclose (share) PHI without a signed authorization (permission) in the ways listed below.   

Typical uses include for the purposes of Treatment, Payment, and Operations (TPO): 

  • Treating you: We can use your health information and share it with other medical professionals who are treating you.
    • Example: An emergency room clinician treating you asks for your recent office note or medication list.
  • Paying for your services: We can use and share your health information to bill and get payment from health plans or other entities.
    • Example: We give information about you to your health insurance plan so it will pay for your services.
  • We can use and share your health information to run our practice, improve your care, and contact you when necessary.
    • We perform various routine audits (MCO, internal chart reviews, etc.) to evaluate for accurate and appropriate service delivery. 

Other Possible Uses and Disclosures

We are allowed or required to share your information in other ways – usually in ways that directly affect you, or contribute to the public good, such as public health and research.

  • Contacting you: We may contact you to provide appointment reminders, information about treatment options, for clarification on a medical records request, when conducting a client-satisfaction survey, or other health-related benefits, treatments, or services we believe may be an interest to you. 
  • Submit a waiver request: If you don’t meet the minimum requirements for services,we will share a minimum amount of PHI necessary with the Department of Health and Human Services (DHHS) in order to waive (remove) those requirements to provide treatment to you.   
  • Help with public health and safety issues: We can share health information about you for certain situations such as:
    • Preventing disease
    • Helping with product recalls
    • Reporting adverse reactions to medications
    • Reporting suspected abuse, neglect, or
    • domestic violence
    • Preventing or reducing a serious threat to anyone’s health or safety
  • Do research: We can use or share your information for health research.
  • Comply with the law: We will share information about you if state or federal laws require it, including with DHHS if it wants to see that we’re complying with federal privacy law.
  • Respond to organ and tissue donation requests: We can share health information about you with organ procurement organizations.
  • Work with a medical examiner or funeral director: We can share health information with a coroner, medical examiner, or funeral director when an individual die.
  • Address workers’ compensation, law enforcement, and other government requests: We can use or share health information about you:
    • For workers’ compensation claims
    • For law enforcement purposes or with a law enforcement official
    • With health oversight agencies for activities authorized by law
    • For special government functions such as military, national security, and presidential protective services
  • Respond to lawsuits and legal actions: We can share health information about you in response to a court or administrative order, or in response to a subpoena.
  • Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may use or disclose your health information to the correctional institution or to the law enforcement official as may be necessary for the institution to provide you with health care, to protect the health or safety of you or another person, or for the safety and security of the correctional institution.

PHI Uses/Disclosures Requiring Written Authorization

In the following instances, GNHM will always obtain your written authorization to use and/ or share PHI – authorization may be revoked in writing at any time:

  • Substance Use Disorder (SUD): We will never release or re-release SUD related records protected by 42 CFR Part 2.
    • Exception: Required or permitted by law (i.e. emergency situations)
  • Media Communication: Wewill never use or share your information for marketing, advertising, fundraising, or any other kind of media purposes without first obtaining your written permission.
  • Sale: We will not sell your PHI without your written authorization. Such an authorization will state that GNMH will receive payment in the transaction.  
  • Psychotherapy Notes: GNMH does not create or maintain Psychotherapy Notes as defined in45 CFR Part § 164.501.

Consumer Rights Concerning PHI

  • Right to Inspect and Copy: You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Please submit your request in writing to the GNMH Medical Records Department. We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
  • Right to Amend: You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this. We may say “no” to your request, but we’ll tell you why in writing within 60 days.
  • Right to an Accounting of Disclosures: You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why. We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
  • Right to Request Restrictions: You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care. If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes”, unless a law requires us to share that information.   
  • Right to Request Confidential Communications: You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. All reasonable requests will be approved.
  • Right to get a copy of this notice: You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
  • Right to choose someone to act for you: If you have given someone medical 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 make sure the person has this authority and can act for you before we take any action.
  • Right to file a Complaint: If you have a question or concern, or believe that GNMH has failed to uphold your rights, you may contact the VP of Quality and Corporate Compliance to report a concern or make a complaint by phone 603-402-1519, videophone 603-821-0073, or by mail at the address below:

GNMH

Attn: VP of Quality and Corporate Compliance

100 W. Pearl Street

Nashua, NH 03060

You may also file a complaint with the Department of Health and Human Services (DHHS), Office of Civil Rights (OCR) via their online portal: https://ocrportal.hhs.gov/ocr/portal/lobby.jsf, via email at: OCRComplaint@hhs.gov, or by mail at the address below:

Centralized Case Management Operations

U.S. Department of Health and Human Services

200 Independence Avenue, S.W.

Room 509F HHH Bldg.

Washington, D.C. 20201

You will not be penalized or retaliated against for filing a complaint for exercising your rights as described in this notice.

Effective Date: August 24, 2023

Change in Terms of this Notice: We reserve the right to make change(s) to this Notice at any time. If we do change the terms within this Notice, we may make the updated Notice applicable to all PHI we create or maintain, including any PHI prior to issuing the new Notice. If we do change this Notice, we will post the new Notice in common areas throughout our various locations, and on our website https://gnmhc.org/. A paper copy of the updated Notice can be obtained upon request.