1 About this notice and our responsibilities
This notice applies to protected health information maintained by TeleHeadache LLC in providing TeleHeadache clinical services, including the work of its authorized clinicians, workforce, and service providers acting on its behalf. It does not make independent pharmacies, insurers, or outside healthcare providers part of our practice; they may provide their own notices.
We are required by law to protect the privacy of your protected health information, provide this notice of our legal duties and privacy practices, follow the notice currently in effect, and notify affected individuals following a breach of unsecured protected health information as required by law. We maintain safeguards for health information and restrict access according to job responsibilities and applicable requirements. We apply the minimum-necessary standard where the law requires it; that standard has exceptions, including certain treatment disclosures.
Our Privacy Policy describes broader website and platform information practices. This notice governs protected health information when the documents differ. A more protective applicable federal or state law also governs, including the special restrictions described below.
Back to top ↑2 Your rights at a glance
You can request access to your records, seek an amendment, request confidential communications, ask for restrictions, request an accounting of certain disclosures, obtain a paper copy of this notice, act through an authorized personal representative, and make a privacy complaint. Contact the Privacy Officer using the details at the end of this notice for help exercising these rights. You do not need an active paid membership to make a records or privacy request.
Back to top ↑3 Inspect or obtain your health records
You may ask to inspect or obtain an electronic or paper copy of health information in the records we use to make decisions about you. This generally includes clinical and billing records and can extend beyond the information currently displayed in your portal. Contact the Privacy Officer to identify the records and delivery method you want. We may request a written request and appropriate identity verification without imposing unreasonable barriers.
We will act within the period required by law, generally no later than 30 calendar days after receipt. If HIPAA permits and we need one extension of up to 30 additional days, we will explain the reason and completion date in writing within the original period. Any applicable shorter legal requirement controls. We will provide the requested format if readily producible, or agree with you on an available alternative. A summary replaces records only with your agreement and any required agreement about its fee.
Any fee for your own copy will be limited to the reasonable costs permitted by applicable law. We will not withhold records because you owe money for care. Limited legal exceptions may permit denial of some information; a written denial will explain the reason, any available independent review, and complaint options. We will provide the portions to which you remain entitled.
Back to top ↑4 Request correction or amendment
If information we use to make decisions about you appears inaccurate or incomplete, request an amendment in writing and explain the correction sought. We will respond within 60 days unless a permitted extension applies. An extension of up to 30 additional days requires written notice within the original period explaining the delay and completion date.
We may deny a request for a reason allowed by law, such as finding the information accurate and complete or determining that its available original author should address it. If denied, you may submit a written statement of disagreement for inclusion with the affected record as required by law. Our response will explain that process and complaint options. An amendment usually adds or links corrected information; it does not erase a properly maintained clinical history.
Back to top ↑5 Request confidential communications
You may ask us to contact you through an alternative method or at a different address, such as a particular telephone number or mailing destination. We will accommodate reasonable requests. We may ask you to submit the request in writing, specify the alternative, and explain how payment will be handled when relevant. You need not tell us why you want confidential communications.
Tell us if messages or voicemail at your usual contact details could create a privacy concern. We will explain available alternatives and any practical limits. Independently operated pharmacies, insurers, and other providers require their own contact-preference requests.
Back to top ↑6 Request limits on use or disclosure
You may request restrictions on how we use or disclose information for treatment, payment, or healthcare operations, or what we share with someone involved in your care. We generally are not required to agree, except for the paid-in-full health-plan restriction below. We will explain our response. If we agree, we will follow the restriction subject to applicable legal exceptions, such as certain emergency-treatment needs.
If you or someone other than your health plan pays us in full for a healthcare item or service, you may ask us not to disclose information solely about that item or service to your health plan for payment or healthcare operations. We must honor that request unless disclosure is required by law. Ask before information is submitted whenever possible.
TeleHeadache membership is cash-pay, while a pharmacy may separately process medication benefits. A restriction requested from us does not automatically prevent a pharmacy from billing insurance for medication. Let us know if you need help understanding those separate disclosures, and communicate any restriction request directly to the relevant provider or pharmacy.
Back to top ↑7 Request an accounting of disclosures
You may request a list of certain disclosures made during a period of up to six years before your request. Specify the period desired. The accounting includes disclosures covered by applicable law, with the recipient, information disclosed, date, and purpose or other required description. It generally excludes treatment, payment, and healthcare operations, disclosures to you, disclosures under your authorization, and other legal exceptions.
We will act within 60 days. If permitted and needed, one extension of up to 30 days requires written notice explaining the reason and completion date. One accounting in a 12-month period is free. Before charging a permitted fee for another accounting in that period, we will explain the fee and allow you to withdraw or modify the request.
Back to top ↑8 Copies, representatives, and complaints
You may obtain a paper copy of this notice promptly on request even if you receive it electronically. You may also ask for an accessible format or help understanding it.
A person legally authorized to act as your personal representative may exercise rights within that authority. We verify identity and authority. Being a spouse, caregiver, emergency contact, or person paying a bill does not by itself establish unrestricted access. Exceptions may apply when recognizing a representative could expose you to abuse, neglect, or endangerment, consistent with law and professional judgment.
You may complain to our Privacy Officer or the U.S. Department of Health and Human Services Office for Civil Rights. You do not have to complain to us first, and we will not retaliate against you for exercising rights or filing a complaint. Contact details appear in Section 17.
Back to top ↑9 Uses for treatment, payment, and healthcare operations
Subject to applicable law, we use and disclose health information for the following purposes without a separate HIPAA authorization:
Treatment. Clinicians review your assessment, medication history, symptoms, and records to evaluate your headaches and plan care. We may coordinate with other treating clinicians and pharmacies. For example, we send an appropriate prescription and relevant clinical information to a pharmacy or consult with another treating clinician about a medication interaction. We may contact you about follow-up, refill needs, treatment alternatives, or relevant care services.
Payment. We use information to collect and document payment for services, manage billing questions, and support lawful medication-benefit coordination. For example, billing personnel may review a service record to resolve a charge, or we may send clinical information requested for a medication prior authorization, subject to applicable restrictions. This does not mean your membership is covered by insurance or that we routinely submit membership claims to an insurer.
Healthcare operations. We use information to operate the practice, review clinical quality and safety, credential or train personnel, conduct audits, investigate complaints, and manage legal and administrative functions. For example, a clinical supervisor may review a sample of assessments to evaluate care quality. Appropriate service providers may support these activities under agreements and legal requirements governing their access and use.
These categories do not override a stricter state-law authorization requirement, an agreed restriction, or the protections for specially protected records below.
Back to top ↑10 Your family, caregivers, and disaster communications
With your permission, or when you have an opportunity to object and do not, we may share information relevant to a family member's, friend's, or other person's involvement in your care or payment. Tell us whom you want involved and any limits. If you are unavailable or unable to express a preference, we may make a legally permitted disclosure that professional judgment finds to be in your best interest.
We may share appropriate information for lawful disaster-relief notification and coordination. These permissions do not give another person access to your full record or override restrictions that require a separate written authorization.
Back to top ↑11 Other legally permitted or required disclosures
Each purpose below is subject to the conditions in applicable law; this notice does not give a requester unrestricted access.
Public health and safety. We may make legally authorized reports to public-health authorities, report adverse medication reactions or product problems, assist with recalls, and report suspected abuse, neglect, or domestic violence under the applicable rules. We may disclose information to prevent or lessen a serious and imminent threat when law and professional standards permit.
Health oversight. We may provide information to authorized agencies conducting lawful inspections, audits, licensing reviews, investigations, or other oversight of healthcare and regulatory programs.
Legal requirements and proceedings. We disclose information when required by applicable law, including required access by HHS for privacy compliance. We may respond to a valid court or administrative order, or another lawful process satisfying the applicable notice, authorization, protective-order, and confidentiality requirements. A subpoena alone is not sufficient when the law requires more. The Part 2 limitations in Section 13 apply to protected substance-use-disorder records and testimony about them.
Law enforcement and government functions. Limited disclosures may be permitted for specified law-enforcement purposes; workers' compensation and similar programs; authorized military, national-security, intelligence, or protective functions; or legally permitted health and safety needs concerning a person in lawful custody. We evaluate the particular legal conditions before disclosing.
After death and donation. We may provide relevant information to authorized organ-procurement organizations or to coroners, medical examiners, and funeral directors for their lawful functions. Information about a deceased person remains protected for the period and under the conditions required by law.
Research. Information may be used or disclosed for research with required authorization or under a legally permitted process, such as an approved waiver or properly deidentified information. Where Florida or other applicable law requires written permission or protects particular records more strictly, we follow that requirement. Receiving care does not automatically enroll you in a study.
Back to top ↑13 Substance use disorder and other specially protected records
If we receive or maintain substance-use-disorder patient records protected by 42 CFR Part 2, additional rules apply. Those records, and testimony relaying their contents, will not be used or disclosed in civil, criminal, administrative, or legislative investigations or proceedings against you unless you provide the required specific written consent, or a qualifying court order authorizes the use or disclosure after the required notice and opportunity to be heard. A court order authorizing disclosure must also be accompanied by a subpoena or other legal requirement compelling disclosure before the records are disclosed. A general treatment consent does not supply consent for proceedings against you.
Other uses and redisclosures of Part 2 records must follow the applicable Part 2 permission or consent and HIPAA requirements. Separately maintained substance-use-disorder counseling notes have additional consent protections. This notice does not represent that every reference to alcohol, substance use, or medication use is automatically a Part 2 record, or that TeleHeadache operates a Part 2 program.
Additional federal or state protections may apply to genetic, HIV, mental-health, psychotherapy, reproductive, and other sensitive information. We follow applicable protections and obtain any additional authorization required. Clinically relevant pregnancy or reproductive information is protected medical information; this notice does not promise immunity from every legally authorized disclosure.
Back to top ↑14 Florida patient record protections
Where Florida law applies, practitioner records and patient communications are confidential. Subject to legal exceptions, records may be furnished or discussed with you, your legal representative, and healthcare practitioners or providers involved in your care or treatment; furnishing records or discussing your condition with others generally requires written authorization unless a specific legal exception permits it.
Florida also restricts use of patient information for solicitation or marketing without a specific written release or authorization. Requests connected with litigation must satisfy Florida's applicable process and notice requirements in addition to federal protections. We do not treat a broad statement about “healthcare operations” as permission to bypass these protections.
You may request records relating to your examination or treatment. Applicable access requirements include timely provision, and access must not be conditioned on paying an outstanding bill for services. Where more than one privacy law applies, we follow the requirements that govern the particular information and request.
Back to top ↑15 Electronic care, communication, and membership closure
Our practice may communicate through the patient portal and other authorized channels. Tell us about confidential-contact needs. We may send appointment, refill, or message-availability notices; such notices can reveal your relationship with the practice even without clinical details. A third party you choose to receive records may operate under different privacy protections.
Ending membership does not remove records that must be retained or terminate your lawful access and privacy rights. Records remain subject to applicable protection after services end. The Telehealth Informed Consent addresses clinical consent and the limitations of remote care; it is separate from this notice.
Back to top ↑16 Changes to this notice
We reserve the right to revise this notice and, as permitted by law, apply the revised practices to information we already maintain as well as information received later. We will not implement a material change before the revised notice's effective date unless the law requires otherwise. The revised notice will be posted at /notice-of-privacy-practices and available upon request, with any other distribution required by law.
We may ask you to acknowledge receiving this notice. Acknowledgment documents receipt; it is not an agreement to waive rights or authorize every use. If you decline to acknowledge receipt, we will document our efforts and the reason when available. Refusing acknowledgment does not by itself bar otherwise available treatment.
Back to top ↑17 Contact us or file a complaint
Privacy Officer — TeleHeadache LLC
Email: admin@teleheadache.com
Telephone: (888) 973-7174
Contact the Privacy Officer to ask a question, request records, exercise a right, or report a concern. For a complaint, describe what happened, when it occurred, and a safe way to contact you. We can arrange a secure method to provide sensitive details.
You may also complain to the U.S. Department of Health and Human Services, Office for Civil Rights, including about applicable HIPAA or Part 2 protections. Instructions are available at hhs.gov/hipaa/filing-a-complaint. You may write to 200 Independence Avenue SW, Washington, DC 20201, or call 1-877-696-6775 for assistance. We will not retaliate against you for filing a complaint.
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