Polices & Disclosures

4. Clinical Notice of Privacy Practices

Telehealth-Only Clinical Services

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN ACCESS THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This Notice applies only to clinical counseling and assessment services provided by Jennifer Romero in her capacity as a licensed clinical social worker. It does not apply to consulting or advisory services provided to organizations.

Our Legal Duty

We are required by law to:

• Maintain the privacy and security of your Protected Health Information ("PHI")

• Provide you with this Notice of our legal duties and privacy practices

• Follow the terms of this Notice currently in effect

• Notify you if a breach occurs that may have compromised your PHI

We reserve the right to change the terms of this Notice and make the new provisions effective for all PHI we maintain. Updated notices will be posted on our website.

How We May Use and Disclose Your Protected Health Information

Protected Health Information (PHI) includes information that identifies you and relates to your health condition, treatment, or payment for services.

We may use or disclose your PHI without your written authorization for the following purposes:

• Treatment: To provide, coordinate, or manage your healthcare services.

• Payment: To obtain reimbursement for services provided, including submitting claims to insurance companies.

• Health Care Operations: For activities necessary to operate the practice, including quality assessment, compliance, licensing, and credentialing.

• As Required by Law: When required by federal, state, or local law.

• Public Health and Safety: To report abuse, neglect, domestic violence, or when necessary to prevent a serious threat to health or safety.

• Health Oversight Activities: For audits, investigations, inspections, and licensure actions.

• Judicial and Administrative Proceedings: In response to a court order, subpoena, or other lawful process.

• Law Enforcement: As permitted or required by law.

• Workers' Compensation: As authorized by applicable law.

Uses and Disclosures Requiring Your Written Authorization

We will not use or disclose your PHI for the following without your written authorization:

• Psychotherapy notes (if maintained separately)

• Marketing purposes

• Sale of PHI

• Certain disclosures related to reproductive health care

You may revoke your authorization at any time in writing.

Special Protections for Substance Use Disorder Records (42 CFR Part 2)

If you receive services related to substance use disorder (SUD), federal law provides additional protections. Records of SUD diagnosis, treatment, or referral are protected under 42 CFR Part 2.

These records:

• May not be disclosed without your written consent except in limited circumstances permitted by law

• May not be redisclosed by recipients unless permitted by federal regulations

• Have heightened confidentiality protections beyond standard HIPAA protections

You have rights under Part 2 to receive a copy of your SUD records, request corrections, and file complaints for violations.

Reproductive Health Privacy Protections

Federal law prohibits the use or disclosure of PHI for the purpose of investigating or imposing liability on individuals for seeking, obtaining, providing, or facilitating lawful reproductive health care. Certain requests for reproductive health information may require a signed attestation confirming that the request is not for a prohibited purpose.

Your Rights Regarding Your PHI

You have the following rights:

• Right to Inspect and Receive a Copy: You may request access to your clinical records in electronic or paper format.

• Right to Request Amendment: If you believe information in your record is incorrect or incomplete, you may request an amendment.

• Right to Request Restrictions: You may request limits on how your PHI is used or disclosed. We are not required to agree to all requested restrictions, except where required by law.

• Right to Confidential Communications: You may request that we contact you at a specific phone number, email, or address.

• Right to an Accounting of Disclosures: You may request a list of certain disclosures made outside of treatment, payment, and operations.

• Right to a Paper Copy of This Notice: You may request a paper copy at any time, even if you received it electronically.

Telehealth and Electronic Communications

Telehealth

Because services are provided via telehealth, electronic communication carries some inherent risk. We use commercially reasonable safeguards to protect your information. You are responsible for maintaining privacy in your chosen telehealth location.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with Jennifer Romero at jenn@jromerointegrativesolutions.com. You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights (OCR). We will not retaliate against you for filing a complaint.

Effective Date: January 2026 We reserve the right to change this Notice and make the revised Notice effective for all PHI we maintain. Updated versions will be posted on our website. You will be asked to sign a written acknowledgment that you received this Notice at or before your first service encounter.