Patient Rights and Notices

Purpose of Notice

Under the federal health care privacy regulations pertaining to the Health Insurance Portability and Accountability Act of 1996 set forth at 45 CFR Parts 160 and 164 (the “Privacy Regulations”), Institute of Contextual Health (“the Practice”) is required to protect the privacy of your individually identifiable health information, which includes information about your health history, symptoms, test results, diagnoses, treatment, and claims and payment history.

The Practice provides physical therapy, occupational therapy, and physician services (rheumatology and general internal medicine). This Notice applies to protected health information collected or maintained by the Practice across all of these services.

We are also required to provide you with this Notice of Protected Health Information Practices regarding our legal duties, policies, and procedures to protect and maintain the privacy of your health information (“the Notice”). We will not use or disclose your health information except as provided for in this Notice. However, we reserve the right to change the terms of this Notice and make new notice provisions for all your health information that we maintain.

Permitted Uses and Disclosures of Your Health Information

Treatment, Payment, and Health Care Operations. We may use and disclose your protected health information for treatment, payment, and health care operations as permitted by federal law.

Treatment. We are permitted to use your health information in the provision and coordination of your health care. We may disclose information contained in your medical record to your primary health care provider, consulting providers, and to other health care personnel who have a need for such information for your care and treatment. For example, your physical therapist may disclose your health information when consulting with our Medical Director or with an external physician regarding your medical condition.

Payment. We are permitted to use your health information for the purposes of determining coverage, billing, claims management, medical data processing, and reimbursement. This information may be released to an insurance company, third-party payer, or other authorized entities involved in the payment of your medical bill and may include copies or portions of your medical record which are necessary for payment of your account. For example, a bill sent to your insurance company may include information that identifies you, your diagnosis, and the procedures and supplies used in your treatment.

Health Care Operations. We are permitted to use and disclose your health information during the Practice's routine health care operations, including, but not limited to, quality assurance, utilization reviews, medical reviews, auditing, accreditation, certification, licensing, or credentialing activities and for education purposes.

Uses and Disclosures with Patient Authorization. Under the Privacy Regulations, we can use and disclose your health information for purposes other than treatment, payment, or health care operations with your written authorization. For example, with your authorization we can provide your name and medical condition to companies who might be able to provide you useful items or services. Under the Privacy Regulations, you may revoke your authorization; however, such revocation will not have any effect on uses or disclosures of your health information prior to our receipt of the revocation.

Uses and Disclosures with Patient Opportunity to Verbally Agree or Object. We may disclose your health information without written authorization to a family member, close personal friend, or another person identified by you when the information is directly relevant to that person's involvement in your care. You must be notified in advance and have the opportunity to verbally agree or object.

Uses and Disclosures Without an Acknowledgement, Authorization or Opportunity to Verbally Agree or Object. Under the Privacy Regulations, we are permitted to use or disclose your health information without your consent, authorization, or the opportunity to verbally agree or object with regard to the following:

• Uses and Disclosures Required by Law. We will disclose your health information when required to do so by law.
• Public Health Activities. We may disclose your health information for public health reporting, reporting of communicable diseases and vital statistics, and similar other circumstances.
• Abuse and Neglect. We may disclose your health information if we have a reasonable belief of abuse, neglect, or domestic violence.
• Regulatory Agencies. We may disclose your health information to a health care oversight agency for activities authorized by law, including, but not limited to, licensure, certification, audits, investigations, and inspections. These activities are necessary for the government and certain private health oversight agencies to monitor the health care system, government programs, and compliance with civil rights.
• Judicial and Administrative Proceedings. We may disclose health information in judicial and administrative proceedings, as well as in response to an order of a court, administrative tribunal, or in response to a subpoena, summons, warrant, discovery request, or similar legal request.
• Law Enforcement Purposes. We may disclose your health information to law enforcement officials when required to do so by law.
• Coroners, Medical Examiners, Funeral Directors. We may disclose your health information to a coroner or medical examiner. This may be necessary, for example, to determine a cause of death. We may also disclose your health information to funeral directors, as necessary, to carry out their duties.
• Research. Under certain circumstances, we may disclose your health information to researchers when their clinical research study has been approved by an institutional review board that has reviewed the research proposal and provided that certain safeguards are in place to ensure the privacy and protection of your health information. Current research activity at the Practice consists of retroactive chart history review and outcome measure tracking; you may withdraw from research participation at any time without affecting your clinical care.
• Threats to Health and Safety. We may use or disclose your health information if we believe the disclosure is necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public.
• Military/Veterans. If you are a member of the armed forces, we may disclose your health information as required by military command authorities.
• Workers' Compensation. We may disclose your health information to the extent necessary to comply with laws relating to workers' compensation or other similar programs.
• Marketing. We will not use or disclose your protected health information for marketing purposes without your written authorization, except for face-to-face communications or promotional gifts of nominal value as permitted by law.
• Appointment Reminders. We may use and disclose your health information to remind you of an appointment for treatment and medical care at our practice.
• Other Uses and Disclosures. In addition to the reasons outlined above, we may use and disclose your health information for other purposes permitted by the Privacy Regulations.

Uses and Disclosures to Business Associates. We may disclose your protected health information to Business Associates that perform services on our behalf. Business Associates are required by law and contract to safeguard your information. A Business Associate is defined under the Privacy Regulations as an individual or entity under contract with us to perform or assist us in a function or activity which requires the use of your health information. Examples of business associates include, but are not limited to, consultants, accountants, lawyers, medical transcriptionists, third-party billing companies, and electronic medical record (EMR) vendors. We require all Business Associates to protect the confidentiality of your health information.

Patient Rights

Although your medical record is our property, you have the following rights concerning your medical record and health information:

• Right to Request Restrictions on the Use and Disclosure of Your Health Information. You have the right to request restrictions on the use and disclosure of your health information for treatment, payment, and health care operations. However, we are not required to agree with such a request. If, however, we agree to the requested restriction, it is binding on us.
• Right to Inspect and Copy Your Health Information. You have the right to inspect and copy your own health information upon request. However, we are not required to provide you access to all the health information that we maintain. For example, this right does not extend to psychotherapy notes, information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative proceeding, or subject to or exempt from Clinical Laboratory Improvements Amendments of 1988. Access may also be denied if disclosure would reasonably endanger you or another person.
• Right to Verbally Object. You have the right to verbally object to certain disclosures that are routinely made for treatment, payment, or healthcare operations or for other purposes without an Authorization. For example, we are required to give you an opportunity to object to the sharing of your health information with a person or family member accompanying you for treatment.
• Right to Seek an Amendment of Your Health Information. You have the right to request an amendment of your health information. If we disagree with the requested amendment, we will permit you to include a statement in the record. Moreover, we will provide you with a written explanation of the reasons for the denial and the procedures for filing appropriate complaints and appeals.
• Right to an Accounting of Disclosure of Your Health Information. You have the right to receive an accounting of disclosures made by us of your health information within six (6) years prior to the date of your request. The accounting will not include disclosures related to treatment, payment, or health care operations; disclosures made to you; disclosures made pursuant to a valid authorization; disclosures permitted by law; or disclosures to persons involved in your care. The accounting of disclosures shall include the date of each disclosure, name and address of the person or organization who received your health information, a brief description of the information disclosed, and the purpose for the disclosure.
• Right to Confidential Communications. You have the right to receive confidential communications of your health information by alternative means or alternative locations. For example, you may request that we only contact you at work or by mail.
• Right to Revoke Your Authorization. You have the right to revoke a validly executed authorization for the use or disclosure of your health information. However, such revocation will not have any effect on uses or disclosures prior to the receipt of the revocation.
• Right to Notification of a Breach. You have the right to be notified following a breach of your unsecured protected health information as required by law.
• Right to Receive Copy of this Notice. You have the right to receive a copy of this Notice.

Contact Information and How to Report a Privacy Rights Violation

If you have questions and would like additional information regarding the uses and disclosures of your health information, you may contact our Privacy Officer at info@contextualhealth.org or 616-855-0540.

The Practice has established an internal complaint process for reporting privacy rights violations. If you believe that your privacy rights have been violated, you may file a complaint with us by contacting our Privacy Officer at info@contextualhealth.org or 616-855-0540. All complaints must be submitted to the Practice in writing at: Institute of Contextual Health, Attn: Privacy Officer, 5429 Northland Dr. NE, Suite A, Grand Rapids, MI 49525.

You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights. Complaints may be filed electronically at hhs.gov/ocr/privacy/hipaa/complaints.

There will be no retaliation for filing a complaint.

Effective Date: November 1, 2026.