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 THIS NOTICE CAREFULLY. 

This Notice of Privacy Practices describes the privacy practices of Multi-Service Eating Disorders Association (“MEDA”, “we” or “us”), including:

• MEDA healthcare professionals and clinicians that are allowed to enter or access information in your medical record;
• MEDA personnel with access to your medical or billing records or health information about you; and
• Any of our volunteers or trainees that are authorized to help you while you are a patient at MEDA.

Your health record contains personal information about you and your health.  This information about you that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services is referred to as Protected Health Information (“PHI”).  This Notice of Privacy Practices describes how we may use and disclose your PHI in accordance with applicable law, including the Health Insurance Portability and Accountability Act (“HIPAA”), regulations promulgated under HIPAA including the HIPAA Privacy and Security Rules, and the National Association of Social Workers Code of Ethics.  It also describes your rights regarding how you may gain access to and control your PHI.

I. Our Privacy Obligations

We are required by law to maintain the privacy of PHI and to provide you with notice of our legal duties and privacy practices with respect to PHI. We are required to abide by the terms of this Notice of Privacy Practices.  We reserve the right to change the terms of our Notice of Privacy Practices at any time.  Any new Notice of Privacy Practices will be effective for all PHI that we maintain at that time. We will provide you with a copy of the revised Notice of Privacy Practices by sending a copy to you in the mail upon request or providing one to you at your next appointment.

II. How We May Use And Disclose Health Information About You

a.  Permissible Uses and Disclosures Without Your Written Authorization

This Section II.a describes circumstances in which we may use and disclose your PHI without your written authorization as permitted by HIPAA; however, applicable law and ethical standards may impose special restrictions on our use and disclosure of your PHI and require your authorization or prior consent, particularly where your PHI is considered Highly Confidential Information (as defined in Section II.b below).  As social workers licensed in Massachusetts, it is our practice to adhere to more stringent privacy requirements for disclosures without an authorization or prior consent.  In certain situations described in Section II.b below, we must obtain your written authorization in order to use and/or disclose your PHI.

For Treatment.  We may use and disclose your PHI to provide treatment and other related services to you – for example, to provide, coordinate, or manage your health care treatment and related services.  This includes consultation with clinical supervisors or other MEDA team members.  We may use your information to direct or recommend alternative treatments, therapies, health care providers, or settings of care to you or to describe a health-related product or service.  We may disclose PHI to any other consultant only with your prior consent.

For Payment.  We may use and disclose PHI so that we can receive payment for the treatment services provided to you.  This will only be done with your prior consent.  Examples of payment-related activities are: (i) making a determination of eligibility or coverage for insurance benefits, (ii) processing claims with your insurance company, (iii) reviewing services provided to you to determine medical necessity, or (iv) undertaking utilization review activities.  If it becomes necessary to use collection processes due to lack of payment for services, we will only disclose the minimum amount of PHI necessary for purposes of collection.

For Health Care Operations.  We may use or disclose, as needed, your PHI in order to support our business activities including, but not limited to, quality assessment activities, employee review activities, licensing, training or teaching purposes for MEDA trainees, and conducting or arranging for other business activities.  For example, we may share your PHI with third parties that perform various business activities (e.g., billing or typing services) provided we have a written contract with the business that requires it to safeguard the privacy of your PHI.

Required by Law.  Under the law, we must disclose your PHI to you upon your request, as discussed in additional detail at Section III.  In addition, we may use and disclose your PHI when required to do so by any applicable federal, state or local law, including for example, when we must make disclosures to the Secretary of the Department of Health and Human Services for the purpose of investigating or determining our compliance with the requirements of the Privacy Rule.

Child Abuse or Neglect. We may disclose your PHI to a state or local agency that is authorized by law to receive reports of child abuse or neglect.

Judicial and Administrative Proceedings. We may disclose your PHI pursuant to a subpoena (with your written consent), court order, administrative order or similar process.

Deceased Patients.  We may disclose PHI regarding deceased patients as mandated by state law—such as to a coroner or medical examiner—or to a family member or friend that was involved in your care or payment for care prior to death, based on your prior consent. A release of information regarding deceased patients may be limited to an executor or administrator of a deceased person’s estate or the person identified as next-of-kin.  PHI of persons that have been deceased for more than fifty (50) years is not protected under HIPAA.

Medical Emergencies.  We may use or disclose your PHI in a medical emergency situation to medical personnel only in order to prevent serious harm. Our staff will try to provide you a copy of this notice as soon as reasonably practicable after the resolution of the emergency.

Family Involvement in Care.  We may disclose information to close family members or friends directly involved in your treatment based on your consent or as necessary to prevent serious harm.

Health Oversight.  If required, we may disclose PHI to a health oversight agency for activities authorized by law, such as audits, investigations, and inspections. Oversight agencies seeking this information include government agencies and organizations that provide financial assistance to the program (such as third-party payors based on your prior consent) and peer review organizations performing utilization and quality control.

Law Enforcement.  We may disclose PHI to a law enforcement official as required by law, in compliance with a subpoena (with your written consent), court order, administrative order or similar document, for the purpose of identifying a suspect, material witness or missing person, in connection with the victim of a crime, in connection with a deceased person, in connection with the reporting of a crime in an emergency, or in connection with a crime on the premises.

Specialized Government Functions.  We may review requests from U.S. military command authorities if you have served as a member of the armed forces, authorized officials for national security and intelligence reasons and to the Department of State for medical suitability determinations, and disclose your PHI based on your written consent, mandatory disclosure laws and the need to prevent serious harm.

Public Health.  If required, we may use or disclose your PHI for mandatory public health activities to a public health authority authorized by law to collect or receive such information for the purpose of preventing or controlling disease, injury, or disability, or if directed by a public health authority, to a government agency that is collaborating with that public health authority.

Public Safety.  We may disclose your PHI if necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.  If information is disclosed to prevent or lessen a serious threat it will be disclosed to a person or persons reasonably able to prevent or lessen the threat, including the target of the threat. 

Research.  PHI may only be disclosed after a special approval process or with your authorization.

Fundraising.  We may send you fundraising communications at one time or another to support our charitable activities.  You have the right to opt out of such fundraising communications with each fundraising request you receive.  In connection with any fundraising, we may disclose to MEDA fundraising staff or to third parties that perform fundraising business activities on our behalf, for which we have a written contract with such business that requires it to safeguard the privacy of your PHI, your demographic information (such as your name, address and phone number).  If you wish to make a tax-deductible contribution now or do not want to receive any fundraising requests in the future, you may contact our Privacy Office at meda@medainc.org.

Verbal Permission.  We may also use or disclose your information to family members that are directly involved in your treatment with your verbal permission.

b. Uses and Disclosures Requiring Your Written Authorization

Uses and disclosures not specifically permitted by applicable law will be made only with your written authorization, which may be revoked at any time, except to the extent that we have already made a use or disclosure based upon your authorization.  For any purpose other than the ones described above in Section II.a, we only use or disclose your PHI when you give us your written authorization (or prior consent, as applicable), including for: (i) uses and disclosures of psychotherapy notes, which are separated from the rest of your medical record, except for use by the mental health professional who created the notes to provide treatment to you, for our mental health training programs or to defend ourselves in a legal action or other proceeding brought by you; (ii) uses and disclosures of PHI for Marketing purposes, as defined by HIPAA, including subsidized treatment communications; (iii) disclosures that constitute a sale of PHI; and (iv) other uses and disclosures not described in this Notice of Privacy Practices.

Further, federal and Massachusetts state law require special privacy protections for certain categories of  health information (“Highly Confidential Information”), including Alcohol and Drug Abuse Treatment Program records and other health information that is given special privacy protection under state or federal laws other than HIPAA.  In order for us to disclose any Highly Confidential Information for a purpose other than those permitted by law, we must obtain your authorization or prior consent, as applicable.

III. Your Rights Regarding Your PHI

You have the following rights regarding PHI we maintain about you.  To exercise any of these rights, please submit your request in writing.

For Further Information; Complaints.  If you desire further information about your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to your PHI, you may contact our Privacy Office.  You may also file written complaints with the Office for Civil Rights of the U.S. Department of Health and Human Services.  Upon request, the Privacy Office will provide you with the correct address for the Director.  We will not retaliate against you if you file a complaint with us or the Director.

Right of Access to Inspect and Copy.  You have the right, which may be restricted only in limited circumstances, to inspect and copy PHI that is maintained in a “designated record set”. A designated record set contains mental health/medical and billing records and any other records that are used to make decisions about your care.  Your right to inspect and copy PHI will be restricted only in those situations where there is compelling evidence that access would cause serious harm to you or if the information is contained in separately maintained psychotherapy notes.  We may charge a reasonable, cost-based fee for copies.  If your records are maintained electronically, you may also request an electronic copy of your PHI.  You may also request that a copy of your PHI be provided to another person.

Right to Amend.  If you feel that the PHI we maintain about you is incorrect or incomplete, you may ask us to amend the information although we are not required to agree to the amendment.  We will otherwise comply with your request unless we believe that the information that would be amended is accurate and complete or other special circumstances apply.  If we deny your request for amendment, you have the right to file a statement of disagreement with us.  We may prepare a rebuttal to your statement and will provide you with a copy.  Please contact our Privacy Office if you have any questions.

Right to an Accounting of Disclosures.  You have the right to request an accounting of certain of the disclosures that we make of your PHI.  We may charge you a reasonable fee if you request more than one accounting in any 12-month period.

Right to Request Restrictions.  You have the right to request a restriction or limitation on the use or disclosure of your PHI for treatment, payment, or health care operations.  We are not required to agree to your request unless the request is to restrict disclosure of PHI to a health plan for purposes of carrying out payment or health care operations, and the PHI pertains to a health care item or service that you paid for out of pocket. In that case, we are required to honor your request for a restriction.

Right to Request Confidential Communication.  You have the right to request that we communicate with you about health matters in a certain way or at a certain location.  We will accommodate reasonable requests.  We may require information regarding how payment will be handled or specification of an alternative address or other method of contact as a condition for accommodating your request.  We will not ask you for an explanation of why you are making the request.

Breach Notification. If there is a Breach of Unsecured PHI (as defined by HIPAA) concerning you, we are required to notify you of such a Breach of Unsecured PHI, including what happened and what you can do to protect yourself.

Right to a Copy of this Notice.  You have the right to a paper copy of this Notice of Privacy Practices.

IV. Privacy Office

You may contact the Privacy Office at: meda@medainc.org

V.  Complaints

If you believe we have violated your privacy rights, you have the right to file a complaint in writing with https://www.mass.gov/how-to/file-a-complaint-against-a-division-of-professional-licensure-licensee or you may call a DPL Investigator at 617-727-7406.  We will not retaliate against you for filing a complaint.

 VI. Effective Date and Duration of This Notice

Effective Date.  This Notice is effective on November 21, 2025.

Right to Change Terms of this Notice.  We may change the terms of our Notice of Privacy Practices at any time.  If we change our Notice of Privacy Practices, we may make the new notice terms effective for all your PHI that we maintain, including any information created or received prior to issuing the new notice.  If we change this Notice of Privacy Practices, we will post the new notice in our waiting room and on our Internet site at https://www.medainc.org/notice-of-privacy-practices/.  You also may obtain any new notice by contacting the Privacy Office.