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 it carefully.

Client Privacy and Releases of Information

Professional ethical codes and state and federal laws consider the personal information discussed in therapy to be confidential. All information gathered in therapy, including the fact that you have come to the Purdue University Northwest Counseling Center (PNWCC) is held in strict confidence. No information is released to university officials, faculty members, parents, or outside agencies without written authorization from you.

Certain obligations arise from legislation and statutes that apply to psychologists and other mental health clinicians. The PNWCC complies with all applicable laws and professional standards relating to the privacy of patient information. The Health Insurance Portability and Accountability Act (HIPAA) does not apply to the PNWCC, however, we are dedicated to maintaining our clients privacy by adhering to the following procedures:

• Confidentiality/privilege: All information concerning use of our services is protected under Indiana law. This describes the legal issue of privileged communication. Part of our professional duty and relationship with you includes that we work to protect the confidentiality of students seeking services at PNWCC. Confidential information will not be released without valid written consent from you except under the following circumstances:
  • We are obligated by law to report suspected child abuse and neglect to the Department of Children’s Services.
  • We are obligated by law to report suspected elder abuse or neglect to the Department of Human Services.
  • We are obligated to take appropriate action if a client represents a threat of harm to self or others, and to take any necessary action to prevent such harm from occurring.
  • If a client is involved in court matters, we may be required to release the record per court order.

Clients Under 18 Years of Age

In Indiana a child 18 and over may consent to treatment. For students under the age of 18 years, issues of confidentiality and privilege are somewhat different from those of students over the age of 18. Unless an individual under 18 years of age is emancipated, they do not own privilege. While they can expect that we will maintain their confidentiality, they need to be informed that their parent, guardian or custodian bears the legal right to request information concerning the student’s treatment.

Securing client information:

1. No student files or identifying information should remain unattended or left in non-secure areas.
2. All client records are the property of the PNWCC. We function as the custodians of student health records.
3. All computers should be shut-down at the end of the work day or upon leaving the office for an extended period of time.
4. Audio and video recordings of therapy sessions are confidential and should remain in a secure storage area when not in use.  They are not considered part of the client record.
5. Recordings should be erased after supervision.
6. No recordings should be removed from the PNWCC without the client’s consent for educational use by a PNWCC trainee.

Requests for Release of Information from Other Agencies

Requests for release of information from other agencies will only be honored following a PNWCC Provider’s facilitation of informed consent and a signed release of information form, requesting information from the PNWCC.  These requests should be handled in a timely manner. The client’s mental health clinician or supervisor is responsible for evaluating the request and submitting the appropriate information.

When neither the mental health clinician nor the supervisor is available, the Executive Director should handle these requests. Usually, a summary will suffice. When confidential records are released, stamp all pages with the red “Confidential” stamp located at the clerical staff’s desk.

Request to View Files

Students, or the parents or the legal guardians of students under 18 years of age, have the legal right to review their files and have a copy of its content, provided the information contained in the file is not harmful to them. When a client, parent or legal guardian of a minor, or former client requests to review the file, the following procedure should be followed:

1. The student, parent or legal guardian of a minor, must sign a “Request to Inspect, Copy or Summarize Mental Health Record” form (see Addendum S) which will be placed in the client’s file.   A session to review the file will be scheduled within 10 working days of receipt of the request.
2. The student, parent or legal guardian of a minor, must present positive identification, including picture ID.
3. Ideally, the student, parent or legal guardian of a minor, will schedule a time to review the file with the current or former mental health clinician.  If the clinician is no longer is on staff, the student will schedule an appointment with a senior staff member or the Executive Director.

Copies of Files

Following the presentation of a valid release of information or a court order, copies of the files will be released within 10 working days using a fee scale that is consistent with the Rules and Regulations of the Board of Examiners in Psychology. To protect confidentiality, proof of identification may be required. When outside agents (e.g., FBI) request to review the file, the following procedure must be used:

1. The agent must provide a signed release of information form correctly identifying the student and the Counseling Center or the student’s therapist.
2. The agent must sign the “Request to Inspect, Copy or Summarize Mental Health Record” form (see Addendum S), which will be placed in the client’s file.
3. The agent must schedule a time to review the file with a senior staff member or Executive Director.

Client’s Requests Concerning Tapes of Sessions

Clients have the right to decline taping at any time and they have the right to request that material be erased. Recordings of sessions are the property of the PNWCC, are not part of the client record, and are not to be given to clients.

***Student/Client Roles for Making Progress in Counseling

1. Scheduling, attending and actively engaging in the counseling process
2. Following treatment recommendations: compliance with treatment: i.e. (all may not apply)
   1. Supplemental Instruction (SI), tutoring, and/or academic coaching
   2. Self-care: healthy diet, exercise, sleep hygiene
   3. Collaboration with advisors and professors (office hours meetings, email)
   4. Engaging auxiliary offices: DOS, PAC, Financial Aid, Career Center
   5. Psychotropic medication referral and compliance with medication treatment
3. Implementing changes discussed in counseling in daily life
4. Other treatment options may apply as counseling is based on individual needs

Release of Information

Use the Authorization for “Release of Information” form whenever any information is to be released about the content of sessions or files.

A release of information must be signed in order to acknowledge that the student has an appointment at the PNWCC or has been seen.

If the student agrees to sign the release form, they have the right to limit the type of information that is released.

The student also has the right to revoke the “Release of Information” form at any time by making such a request in writing.

Whenever a student was referred by another person or agency, it is appropriate to determine through the informed consent process with the student if the person or agency can be notified that the student kept the appointment by facilitating a “Release of Information” form.  This is especially important when the student was referred by faculty or staff members.

Information regarding the areas of alcohol and drugs or communicable diseases including HIV/AIDS requires the student to indicate on the “Release of Information” if they are wanting that specific information released.  A general release is not sufficient to allow for the release of such information.

***PNWCC collaboration with PNW Accessibility Center (PAC)

See Student/Client role for making progress in Counseling above.

1. Referral between PNWCC and PAC requires the client to initial on the “Release of Information” form for bi-directional communication between each office.
   1. This will be facilitated through the informed consent process initiated by the PNWCC.
2. Documentation is required to establish appropriate academic accommodations within the PAC.
3. Generally, attending counseling sessions ranging between 4-6 sessions will provide necessary evaluative information to make appropriate suggestions for accommodations and supports to meet your educational endeavors at PNW
   1. Provisional accommodations through the PAC may be provided for the semester in which you begin the PNWCC assessment process for identifying and receiving the PNWCC Request for Accommodation Letter
   2.  Regular attendance in counseling sessions is needed to establish a treatment plan that may include academic accommodations that are provided by PNW PAC will be recommended as necessary on a case-by-case basis.

**NOTE: Students must follow PAC established protocols to receive PAC accommodations and support.

4. Psychological assessment referrals may be made as necessary for diagnostic clarity

Optional Rules For NOPP

Faxing and Emailing Rule

When you request us to fax or email your Protected Health Information (PHI) as an alternative communication, we may agree to do so, but only after having treating Provider or Executive Director review that request. It must be confirmed that the fax number or email address is correct before sending the message.  We will use a fax cover sheet so the PHI is not the first page to print out (because unauthorized persons may view the top page); and we will attach an appropriate confidentiality notice to the message.

Practice Transition Rule

In the event that Clinical Services provided by the PNWCC must be transmitted to another mental health providing entity, our patient records (including but not limited to your PHI) may be disclosed and physical custody may be transferred to the purchasing healthcare provider, but only in accordance with the law. The healthcare provider who is the new records owner will be solely responsible for ensuring privacy of your PHI after the transfer and you agree that we will have no responsibility for (or duty associated with) transferred records.  Before we transfer recorders, our Privacy Officer will obtain a Business Associate Agreement from the new service provider and review your PHI for super-confidential information (i.e. communicable disease records), which will not be transferred without your express written authorization (indicated by your initials on our Consent form).

Inactive Patient Records

We will retain your records for seven years from your last treatment or examination and may destroy your records after that time (but records of inactive minor patients will not be destroyed before the child’s eighteenth birthday). We will do so only in accordance with the law (i.e. in a confidential manner).

What I Need to Know for Progress in Counseling

Missed and Cancelled/Rescheduled Appointments

1. You will be allotted (3) cancellation/no-show/rescheduled appointments each semester. A referral list of mental health resources within the Northwest Indiana area will be provided to you to utilize these services for the remainder of the present semester should suspension of services due to non-attendance be implemented.
2. If you are an existing client, you are expected to arrive on-time to your scheduled appointment, if you are more than 5 minutes late, you may be asked to reschedule to a subsequent week.
3. If you are a new client, you are expected to arrive 5 – 10 minutes before your in-person appointment or to have logged into Doxy.me and performed your pre-call check to ensure connectivity.

Excluded Services

1. Assessments/Evaluations to be used in court proceedings or other litigation (e.g., competency evaluations, custody evaluations.)
2. Any services that are court-ordered or a requirement of adjudicated legal sanctions.
3. Services that are directed as mandatory from other areas/persons of the University.
4. Services in which the PNWCC would need to be the primary coordinator for extensive inter-agency case management.
5. Interviews for papers, (any #) sessions for course credit, and/or inventories/assessments for course credit; any other utilization of PNWCC staff/resources for University Course credit.
6. Longer-term treatment services or specialized clinical services.
7. Students who are actively engaged in psychological counseling with another provider.
8. Letters to document student’s request for comfort or service animal.
9. Letters for application for a license to carry firearms.
10. Medical and pre-surgical assessment for various procedures that require psychological reports. (Gastric bypass surgery, gender confirmation surgery, hormone replacement therapy)
11. Psychological assessments at the PNWCC may be limited to the testing protocol owned by the PNWCC and the availability of a PNWCC Indiana licensed Psychologist.  If there is benefit from additional assessment, referral to outside qualified providers will be provided.

Types of Student Needs Generally Referred Off-Campus

1. Current life endangering symptoms of an eating disorder.
2. The student has been diagnosed with a form of psychosis that needs an elevated level of care and/or manifests impairment with reality testing (e.g., cannot differentiate between reality and fantasy, experiences delusions, hallucinations or paranoia).
3. Severe mental illness, which is best treated through ongoing long-term treatment, based on the judgment of either; the PNWCC mental health clinician, the Executive Director, or both.
4. History of sexual offenses/violence.
5. The student currently appears to be incapable of exercising a reasonable level of judgment and self-care that would permit them to function both productively and autonomously in the college environment.
6. The student presents an imminent danger to self or others that cannot be mitigated in weekly therapy (e.g., a student who articulates a determination to kill themselves, a student who lacks control of violent impulses, a student who is experiencing hallucinations that the mental health clinician determines could be threatening to self or others, or a student who is unable to care for themself).
7. Court-ordered treatment
8. A student whose behavior creates a hostile working environment at the PNWCC, affecting staff and/or other students (e.g., a student who is grossly verbally abusive and/or threatening towards staff).
9. Students who indicate they are only interested in some sort of documentation for release from contracts (e.g. residence life, food services, academic requirements). 

Limitations to Scope of Services

When certain concerns are present, the PNWCC may choose to refer out to other providers or refuse treatment. This decision may be based on the presence of a single criteria or a combination of several, and it is made after discussion and consultation with the Quality Assurance Committee. It may be determined a student’s presentation falls under the limitations of the scope of services provided by the PNWCC in the circumstances listed below. Additionally, if during the course of treatment, a student’s condition changes or deteriorates, this policy may be enacted at that time.

Details On Limitations to Scope of Services

1. Student presents with chronic imminent danger to self or others (e.g., chronically has a plan and intent to kill themselves and prior services have not helped curb this presentation, a student is experiencing hallucinations and is unable to take care of themselves).
2. Any services that are court-ordered, forensically oriented, or a requirement of adjudicated legal sanctions (e.g., child custody disputes, divorce proceedings, forensic evaluations, anger management, fit for duty, or to return to campus activities).
3. Services required or directed from other area/persons of the university (e.g., students referred as a requirement for cases of conduct at the university, interviews for papers, use of services for course credit). The following cases are exceptions: assessment of imminent threat to self and/or others, and two-session substance screening appointments as required by the PNW Athletic Department Policy following the current NCAA policy regarding a failed drug test(s).
4. Treatment for a student who needs more intensive and extensive treatment than can be provided by the PNWCC (e.g., long-term care, multiple weekly appointments, frequent between-sessions support, disorders in which the student is experiencing active unmanaged psychosis, treatment for an eating disorder of a moderate to advanced stage that requires closely coordinated medical, nutritional, and psychiatric care; treatment for a substance addiction of a moderate to advanced stage that requires sessions more than once per week, drug testing, regular medical monitoring, inpatient or residential care, detoxification, or is at-risk to live in residence halls or attend classes).
5. Services in which the PNWCC would need to be the primary coordinator for extensive inter-agency case management.
6. Treatment for a student actively engaged in psychological treatment with another provider or has exhibited symptoms better addressed by engaging in long-term therapy.
7. Services in which the student has sought counseling but is nevertheless fundamentally unwilling to address the disorder in question (e.g., student’s attendance is inconsistent and/or refusal to receive outside treatment as referred by the mental health clinician, including referral for medication consult/adherence).
8. Treatment for a student whose behavior creates a hostile working environment at the PNWCC, affecting staff and/or other students (e.g., a student who is verbally abusive to and/or threatens staff).
9. Services to document for the purposes of a letter to recommend a service, therapy, or emotional support animal.
10. Letters for application for a license to carry firearms.
11. Medical and pre-surgical psychological assessment for various medical procedures (e.g., gastric bypass surgery, gender confirmation surgery, hormone replacement therapy).
12. Other situations that are determined to be outside the scope of the services provided by the PNWCC or in which case the assigned mental health clinician determines the treatment would be detrimental to the client or to the proper functioning of the PNWCC.

Services are only available to currently enrolled students. The PNWCC does not serve:

• Newly enrolled incoming students prior to the first day of each semester 
• Seniors who have graduated
• Alumni (beyond consultation to offer community referrals)
• Faculty, staff or parent (beyond consultation)