CORNERSTONE BEHAVIORAL HEALTH
NOTICE OF PRIVACY PRACTICES
THIS CORNERSTONE BEHAVIORAL HEALTH, LLC (“CORNERSTONE” OR THE “AGENCY”)
NOTICE OF PRIVACY PRACTICES (“NOTICE”) DESCRIBES HOW HEALTH INFORMATION
MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
PLEASE REVIEW IT CAREFULLY.
I. GENERAL INFORMATION
Information regarding your health care, including payment for health care, is protected by two federal
laws: the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), 42 U.S.C. § 1320d et
seq., 45 C.F.R. Parts 160 & 164, and the Confidentiality Law, 42 U.S.C. § 290dd-2, 42 C.F.R. Part 2 and
is considered “Protected Health Information” (PHI).
II. OUR PLEDGE REGARDING HEALTH INFORMATION
Cornerstone understands 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. It also describes your rights to the health information we keep about you, and describes certain
obligations we have regarding the use and disclosure of your health information. We are required by law
to:
● Make sure that PHI that identifies you is kept private.
● Give you this Notice of Cornerstone’s 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 we have
about you. The new Notice will be available upon request, in our office, or on our website.
III. 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 provide an explanation as well as 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.
1. For Treatment Payment, or Health Care Operations: Federal privacy rules (regulations) allow
health care providers who have a 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 personal health information, which is otherwise
confidential, in order to assist the clinician in the 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 healthcare providers with a third party, consultations
between healthcare providers and referrals of a patient for health care from one healthcare
provider to another.
2. Lawsuits and Disputes: If you are involved in a lawsuit, we 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 processes 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.
IV. CERTAIN USES AND DISCLOSURES REQUIRE YOUR AUTHORIZATION
Certain uses and disclosures of your health information may be made, but only with your authorization.
1. Psychotherapy Notes: Cornerstone and/or its clinicians 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:
(a) For use in treating you.
(b) For use in training or supervising mental health practitioners to help them improve
their skills in group, joint, family, or individual counseling or therapy.
(c) For use in defense in legal proceedings instituted by you.
(d) For use by the Secretary of Health and Human Services to investigate our compliance
with HIPAA.
(e) Required by law and the use or disclosure is limited to the requirements of such law.
(f) Required by law for certain health oversight activities pertaining to the originator of
the psychotherapy notes.
(g) Required by a coroner who is performing duties authorized by law.
(h) Required to help avert a serious threat to the health and safety of others.
2. Marketing Purposes: The Agency will not use or disclose client PHI for marketing purposes.
3. Sale of PHI: The Agency will not sell client PHI in the regular course of Agency business.
V. CERTAIN USES AND DISCLOSURES DO NOT REQUIRE YOUR
AUTHORIZATION
Subject to certain limitations in the law, Cornerstone can use and disclose client PHI without client
authorization for the following reasons:
1. 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.
2. 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.
3. For health oversight activities, including audits and investigations.
4. For judicial and administrative proceedings, including responding to a court or administrative
order, although our preference is to obtain an Authorization from you before doing so.
5. For law enforcement purposes, including reporting crimes occurring on our premises.
6. To coroners or medical examiners, when such individuals are performing duties authorized by
law.
7. 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.
8. 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.
9. 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.
10. 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 us. We may also use and
disclose your PHI to tell you about treatment alternatives, or other health care services or benefits
that we offer.
VI. CERTAIN USES AND DISCLOSURES REQUIRE YOU TO HAVE THE
OPPORTUNITY TO OBJECT
1. 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.
VII. YOU HAVE THE FOLLOWING RIGHTS WITH RESPECT TO YOUR PHI
1. The Right to Request Limits on Uses and Disclosures of Your PHI: You have the right to ask us
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 may say “no” if we believe it would affect your
health care.
2. 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.
3. The Right to Choose How We Send PHI to You: You have the right to ask us 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.
4. 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.
5. The Right to Get a List of the Disclosures We Have Made: You have the right to request a list of
instances in which we have 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.
6. 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
we 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.
7. 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.
Cornerstone is required by law to maintain the privacy of your health information and to provide you with
notice of its legal duties and privacy practices with respect to your health information. Cornerstone is
required by law to abide by the terms of this Notice. Program staff shall not convey to a person outside of
the program that a client attends or receives services from the program or disclose any information
identifying a client as an alcohol or other drug services client unless the client consents in writing for the
release of information, the disclosure is allowed by a court order, or the disclosure is made to qualified
personnel for a medical emergency, research, audit or program evaluation purposes. Cornerstone reserves
the right to change the terms of this Notice and to make new Notice provisions effective for all protected
health information it maintains.
If you have any questions about your treatment or this Notice, please contact Cornerstone directly. It is
your responsibility to follow all guidelines provided in the treatment handbook and to know that failure to
follow these guidelines can result in discharge from services.
VIII. HOW WE USE CONTACT INFORMATION
1. Information We Collect
We collect personal information that you provide to us directly, such as your name, phone number, email address, and any other information you choose to share. This may include:
Contact Information: Name, phone number, and email address.
Communication Data: SMS and email messages, including any information shared during these communications.
Usage Data: Information about your interaction with our services, including log data, IP addresses, and device information.
2. How We Use Your Information
The information we collect is used to:
Provide and improve our services, including scheduling and delivering therapy sessions.
Communicate with you regarding your appointments, updates, and relevant health information.
Send you promotional messages, updates, and reminders based on your preferences.
Ensure compliance with legal and regulatory obligations.
3. How to Opt-Out
You have the right to opt-out of communications from us at any time. Here’s how:
SMS Messages: Reply STOP to any SMS message you receive from us to stop future messages.
Email Communications: Click the "Unsubscribe" link in any promotional email to opt-out of future emails.
Contact Us: You can also contact us directly at 216-270-2955 or email us at practicemanagement@cornerstonebehavioralhealth.org to manage your communication preferences.
4. Data Security
We take the security of your personal information seriously. We implement appropriate technical and organizational measures to protect your data from unauthorized access, loss, or misuse. Contact information (Name, E-Mail, Mobile Phone, etc.) will not be shared or sold to third parties for marketing purposes.
EFFECTIVE DATE OF THIS NOTICE
This Notice went into effect on 05/24/22.