Privacy Policy

NOTICE OF PRIVACY PRACTICES

Effective Date: February 16, 2026

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

I. MY PLEDGE REGARDING HEALTH INFORMATION

I understand that health information about you and your health care is personal, and I am committed to protecting that information.

I create a record of the care and services you receive from me. I need this record to provide you with quality care and to comply with certain legal requirements. This Notice applies to all of the records of your care generated by JP Psychotherapy LLC.

I am required by law to:

• Ensure that Protected Health Information (“PHI”) that identifies you is kept private;

• Provide you with this Notice of my legal duties and privacy practices regarding health information;

• Follow the terms of this Notice currently in effect;

• Notify you in the event of a breach of unsecured PHI; and

• Comply with applicable federal and Massachusetts privacy and data security laws.

Massachusetts law may provide greater privacy protections for mental health information than federal law. When state law is more protective, I will follow Massachusetts law.

I maintain administrative, physical, and technical safeguards to protect your information, including compliance with Massachusetts data security regulations.

I may change the terms of this Notice at any time. The revised Notice will apply to all PHI I maintain and will be available upon request, in my office, and on my website.

II. PROTECTED HEALTH INFORMATION (“PHI”)

PHI includes information that identifies you and relates to your past, present, or future physical or mental health condition, the provision of health care, or payment for health care.

III. HOW I MAY USE AND DISCLOSE YOUR PHI

The following categories describe the different ways I may use and disclose health information without your written authorization.

A. Treatment, Payment, and Health Care Operations

I may use and disclose PHI without your authorization for:

Treatment: Providing, coordinating, or managing your health care and related services. For example, consulting with another provider about your care.

Payment: Activities to obtain reimbursement for services provided.

Health Care Operations: Activities that support quality, training, licensing, accreditation, and business operations.

Disclosures for treatment purposes are not limited to the “minimum necessary” standard because providers need access to complete information to deliver effective care.

B. Required or Permitted by Law

I may use or disclose PHI when required by state or federal law, including reporting abuse or neglect or complying with a court order. In Massachusetts, a subpoena alone may not be sufficient to compel release of psychotherapy records; I will assert applicable privileges and seek your authorization whenever possible consistent with Massachusetts law.

C. Public Health and Safety

I may disclose PHI for public health activities, such as reporting disease, preventing injury, reporting adverse events, or to avert a serious threat to health or safety of a person or the public.

D. Health Oversight Activities

I may disclose PHI for audits, investigations, inspections, or licensure actions.

E. Judicial and Administrative Proceedings

I may disclose PHI in response to a court or administrative order. For subpoenas or discovery requests, I will assert appropriate privileges or seek your authorization unless not legally required to do so.

F. Law Enforcement and Other Government Functions

I may disclose PHI for law enforcement purposes, to coroners or medical examiners, to military authorities, or for other specialized government functions as required by law.

G. Appointment Reminders and Health-Related Benefits or Services

I may use and disclose PHI to contact you about appointment reminders or to inform you about treatment alternatives or health-related benefits and services.

IV. SPECIAL PROTECTIONS FOR SUBSTANCE USE DISORDER (SUD) RECORDS

If I create, receive, maintain, or transmit records related to diagnosis, treatment, or referral for treatment of a substance use disorder, those records may be protected under federal law (42 U.S.C. § 290dd-2 and 42 C.F.R. Part 2) as well as HIPAA.

These records have heightened confidentiality protections:

• I will not disclose SUD records without your written consent, except as permitted by law.

• SUD records generally may not be used in civil, criminal, administrative, or legislative proceedings without your specific written consent or a qualifying court order.

• If SUD records are disclosed with your consent, the recipient may redistribute them only as permitted by applicable law.

If you do not receive SUD treatment from this practice, the protections in this section may not apply to your care.

V. CERTAIN USES AND DISCLOSURES REQUIRE YOUR WRITTEN AUTHORIZATION

Psychotherapy Notes

I do maintain psychotherapy notes. Any use or disclosure of these notes requires your written authorization except for:

• My use in treating you;

• Training or supervision of mental health practitioners;

• My use to defend myself in legal proceedings you initiate;

• Use by government agencies to investigate HIPAA compliance;

• As required by law to avert a serious threat to health or safety.

Marketing Purposes

I will not use or disclose your PHI for marketing without your authorization.

Sale of PHI

I do not sell your PHI.

You may revoke any authorization in writing at any time, except to the extent that I have already acted in reliance on it.

VI. USES AND DISCLOSURES THAT DO NOT REQUIRE AUTHORIZATION

Without your written authorization, I may use or disclose PHI as permitted or required by law, including:

• To public health authorities for disease control or safety;

• For health oversight activities;

• For judicial and administrative proceedings;

• For law enforcement purposes;

• To coroners or medical examiners;

• For research under applicable safeguards;

• For workers’ compensation compliance;

• For appointment reminders or treatment alternatives.

VII. USES AND DISCLOSURES WITH OPPORTUNITY TO OBJECT

I may provide PHI to a family member, friend, or other person you identify as involved in your care or payment for care unless you object. In emergency situations, I may use professional judgment to decide what is in your best interest.

VIII. YOUR RIGHTS WITH RESPECT TO YOUR PHI

You have the following rights:

Right to Request Restrictions

You may request limits on how I use or disclose PHI for treatment, payment, or health care operations. I am not required to agree, except when you request a restriction on disclosure to a health plan for services you paid for out-of-pocket in full.

Right to Confidential Communications

You may request that I contact you in a specific way or at a specific location. I will accommodate reasonable requests.

Right to Inspect and Copy PHI

You may inspect and receive a copy of your medical record (excluding psychotherapy notes) in paper or electronic form. I will respond within 30 days and may charge a reasonable, cost-based fee.

Right to an Accounting of Disclosures

You may request a list of certain disclosures of your PHI made during the past six years.

Right to Request Amendment

You may request corrections to your PHI. I may deny your request but will provide a written explanation.

Right to a Paper or Electronic Copy of this Notice

You may request a paper copy of this Notice at any time, even if you have previously agreed to receive it electronically.

IX. COMPLAINTS

If you believe your privacy rights have been violated, you may:

Contact:
Jennifer Pugh, LICSW
JP Psychotherapy LLC
781-474-2258
jennifer@jppsych.com

You also may file a complaint with:

• The U.S. Department of Health and Human Services Office for Civil Rights; and

• The Massachusetts Office of the Attorney General.

I will not retaliate against you for filing a complaint.

X. ACKNOWLEDGMENT

Your use of services and/or treatment constitutes acknowledgment that you have received this Notice of Privacy Practices as required by federal and Massachusetts law.