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The Cook Counseling Center values the privacy of its clients and the confidentiality of the personal and health information entrusted to us.  In order to protect this privacy we have policies and procedures to limit disclosures of personal information to those minimally necessary for the medical care of the client, those for which the client has given permission, and/or those required by law or public safety. 

A.  Potential disclosures of an individual's information include:

1.  Treatment.  Counseling information may need to be shared with Cook Counseling Center counselors, psychologists, staff psychiatrists and trainees in counseling, psychology and psychiatry as well as physicians, nurses and other allied health professionals at Schiffert Health Center in order to provide effective and efficient care. 

2.   Billing.  If a client misses an appointment without a 12-hr. advance notice,  a $25.00 fee is charged.  The charge is forwarded to the University's Accounts Receivable Office and a statement is sent to the client. Billing information may contain personal information to include name, student-identification number, and date of service.  The client bill appears as a "Medical Clinic Charge" without the medical diagnoses or procedures.  Bills are mailed by the Accounts Receivable Office to the address provided by the student. No third party billing through insurance companies is provided.

3.  Oversight activities.  Oversight includes internal and external audits, chart reviews, investigations, licensures, and inspections required for compliance with government, university, and accreditation programs and laws as well as the Counseling Center's quality assurance/risk management programs.  Only the minimal necessary information will be released and it will usually be of a general/composite nature.  However, on occasion, reviews will involve sighting of individual information by the auditor, accreditation examiner, or qualified professional.  All individuals performing these reviews, audits, and accreditation visits will be required to agree with and sign the non-disclosure confidentiality standards of the Counseling Center before being allowed access.

4.     Public health and safety.  Personal counseling and health information may be disclosed to the proper authorities to report intent to harm self or others, deaths, certain infectious diseases, occupational injuries and diseases, child or incapacitated adult abuse/neglect, problems with medications and other products as required by law to prevent/control disease, injury or disability to the client or to others.

5.     Legal requirements.  Counseling information may be disclosed as required by court or administrative order, subpoena, discovery request, or other lawful process.       

6.     Contacts.  The client may be contacted by Cook Counseling Center to provide appointment reminders or other information of health-related benefits or services that may be of interest to the patient.

7.     Other uses.  Uses and disclosures of health and personal information other than described above will be made only with the client's (your) written authorization.  Such authorization when given may be revoked in writing by the patient (you) at any time.

B.  The client also has certain rights.  These include:

1.   The right to inspect and obtain copies of counseling records.  Any such requests must be made in writing by the client utilizing the Cook Counseling Center authorization for release information form or in the case of information to be released to another health care provider the form provided by that provider.  A cost-based fee may be charged for copying counseling records.  Cook Counseling Center may deny, in writing, the release or viewing of personal counseling information if the Administration of the Center determines that the release of the information may be harmful to the client or another person.  When such a request is denied the client may request in writing a review of the denial by the Assistant Vice President for Student Affairs that oversees Cook Counseling Center.

2.  The right to request amendments of counseling information.  Such requests must be made in writing to the Director of Cook Counseling Center.  Such requests will be reviewed and may be denied.  If denied, a written denial and its reasons will be provided to the client and he/she has to the right to submit a rebuttal and request for review of such denial by the Assistant Vice President for Student Affairs. 

3. The right to receive an accounting of any disclosures of protected information made after 12 August, 2002.

4.  The right to request limits on the amount or types of counseling information released.  Such requests must be made in writing to the Director of Cook Counseling Center.  Cook Counseling Center may not agree with this request when it is felt to be in the client’s best interest to release the information and/or when such a release is mandated by the uses outlined in section A. above.

5.    The right to request that communications between the client and Cook  Counseling Center be kept confidential. 

C.   Duties of Cook Counseling Center.

1.     Maintaining privacy.    Cook Counseling Center is required by law to maintain the privacy of protected counseling information and to provide and abide by this notice of its legal duties and privacy practices.

 D. Effective date and changes. This notice is effective from  August 24, 2003 and is posted in the Counseling Center waiting area and made available to all clients during on-line check-in.  Copies of the notice may be obtained by requesting them at the reception desks. Cook Counseling Center reserves the right to make changes to this notice and/or its policies without notification other than posting or making available copies of revised notices in locations as described above.  Such changes, if and when made, will become effective for all of the client information that CCC maintains.

E.  Information and complaints. Clients may file complaints regarding the security and/or privacy of their personal counseling information with either of the following:

Christopher Flynn, Ph.D.	Charles Anderson, Ph.D.
Director	Associate Director
240 McComas Hall	240 McComas Hall
Virginia Tech	Virginia Tech
Blacksburg, VA. 24061-0108	Blacksburg, VA. 24061-0108
flynnc@vt.edu	anderso@vt.edu

     Additionally, clients may file formal complaints about possible violations of the privacy rules with the United States Department of Health and Human Services at:

Office for Civil Rights

U. S. Department of Health and Human Services

200 Independence Avenue, S. W.

Room 509F, HHH Building

Washington, DC  20201

OR

OCR Hotlines-Voice:    1-800-368-1019

 revised 10.24.06 mrg