Privacy Policy

True Pathways Therapy, LLC is committed to the principles of protecting the privacy of patients’ personal and medical information. In addition, both the Massachusetts and the Federal Government’s laws require True Pathways to maintain the privacy of all patients’ personal and medical information. This privacy policy notice describes how patients’ personal and medical information (“Patient Information”) is collected, used, disclosed, and protected, and how patients may access their medical information. In the event that the following policy is changed or amended, you will be notified.

This notice is effective as of: 06/20/2024

Collection of Patient Information

We do not collect any personally identifiable Patient Information about you unless you voluntarily submit such information to us, by, for example, filling out a survey or registration form, or during treatment.

Uses and Disclosures for Treatment, Payment, and Health Care Operations.

True Pathways may use or disclose Patient Information for treatment, payment, and health care operations purposes, so long as you consent to receive evaluation or treatment services from True Pathways. 

“Treatment,” means when a clinician provides, coordinates, or manages your health care and other services related to your health care.  An example of treatment would be when a clinician consults with another health care provider, such as your family physician. 

“Payment,” means when a clinician obtains reimbursement for your healthcare.  Examples of payment are when True Pathways discloses Patient Information to a health insurer to obtain reimbursement for the patient’s health care or to determine eligibility or coverage.

“Health care operations,” means activities that relate to the performance and operation of True Pathways. Examples of health care operations are quality assessment and improvement activities, business-related matters such as audits and administrative services, case management and care coordination, conducting training and educational programs or accreditation activities.

Uses and Disclosures of Patient Information Requiring Authorization

The following uses and disclosures of your Patient Information may only be carried out with your prior, written authorization. You may revoke that authorization at any time in writing, unless True Pathways has relied on such authorization or if the authorization was obtained as a condition of obtaining insurance coverage. Uses and Disclosures requiring your writing authorization include, but are not limited to:

-       Instances where True Pathways is asked for Patient Information for purposes outside of treatment, payment, and health care operations.

-       A release of any documents related to treatment that are not part of your patient file.

-       Any use of Patient Information for the purposes of fundraising.

-       Any sale of Patient Information or commercial transaction.

Uses and Disclosures with Neither Consent nor Authorization

True Pathways may use or disclose Patient Information without your consent or authorization in the following circumstances:

-       Public Health and Safety Issues: True Pathways can share health information about you for certain situations such as:

o   Preventing disease;

o   Helping with product recalls;

o   Reporting adverse reactions to medications;

o   Reporting suspected abuse, neglect, or domestic violence; or

o   Preventing or reducing a serious threat to anyone’s health or safety

-       Research: True Pathways can use or disclose your information for health research.

-       Compliance with the Law: True Pathways will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that True Pathways is complying with federal privacy law.

-       Respond to Organ and Tissue Donation Requests: True Pathways can share health information about you with organ procurement organizations.

-       Work with a Medical Examiner or Funeral Director: True Pathways can share health information with a coroner, medical examiner, or funeral director when an individual dies.

-       Address Workers’ Compensation, Law Enforcement, and Other Government Requests: True Pathways can use or disclose health information about you:

o   For workers’ compensation claims;

o   For law enforcement purposes or with a law enforcement official;

o   With health oversight agencies for activities authorized by law; or

o   For special government functions such as military, national security, and presidential protective services.

-       Respond to Lawsuits and Legal Actions: True Pathways can share health information about you in response to a court or administrative order, or in response to a subpoena.

-       Serious Threat to Health or Safety – If you communicate to clinic personnel an explicit threat of imminent serious physical harm or death to identifiable victim(s), and we believe you may act on the threat, we have a legal duty to take the appropriate measures to prevent harm to that person(s) including disclosing information to the police and warning the victim.  If we have reason to believe that you present a serious risk of physical harm or death to yourself, we may need to disclose information in order to protect you.  In both cases, we will only disclose what we feel is the minimum amount of information necessary.

Protection of Patient Information

True Pathways has implemented the following protections and procedures to help protect the Patient Information that you provide to us.

-       True Pathways’ site has industry standard security measures in place to protect the loss, misuse and alteration of the information under our control. While there is no such thing as “perfect security” on the Internet, we will take all reasonable steps to insure the safety of your personal information.

-       True Pathways treats all your health information as confidential.

-       True Pathways states confidentiality policies and practices in our clinic staff handbooks, as well as disciplinary measures for privacy violations.

-       True Pathways restricts access to your health information to only those clinical staff who need to know your Patient Information in order to provide services to you.

-       True Pathways only discloses the health information necessary for an outside service company to perform its function on the clinic’s behalf and such companies have by contract agreed to protect and maintain the confidentiality of your health information.

-       True Pathways maintains physical, electronic, and procedural safeguards to comply with federal and state regulations guarding your health information.

-       True Pathways will always ask for separate, written authorization for any disclosures not covered above.

-       True Pathways will inform you promptly if a breach occurs that may have compromised the privacy or security of your information.

Access to Patient Information

Patients have a right to access, inspect, and copy all Patient Information provided to True Pathways. Patients may ask in writing to see or receive, in electronic or physical copy, any and all Patient Information that True Pathways has on said patient. True Pathways will attempt to furnish you with such records within thirty (30) days of such requests. A reasonable fee may be charged for copying or, if necessary, redacting the record.

You have the right to request in writing an amendment of your health information for as long as PHI records are maintained.  The request must identify which information is incorrect and include an explanation of why you think it should be amended.  If the request is denied, a written explanation stating why will be provided to you.  You may also make a statement disagreeing with the denial, which will be added to the information of the original request.  If your original request is approved, we will make a reasonable effort to include the amended information in future disclosures.  Amending a record does not mean that any portion of your health information will be deleted.

Certain exceptions apply to your access to Patient Information that True Pathways possess. Such exceptions include but are not limited to:

-       True Pathways is not required to provide you with access to psychotherapy notes, however, True Pathways will provide you with a summary of said notes upon request. If after receiving the summary you want access to the entire record, then, at your request, True Pathways will provide it to your attorney or to another psychotherapist you select;

-       True Pathways may refuse to provide you access to information compiled for use in a civil, criminal, or administrative action or proceeding;

-       True Pathways is not required to provide you access to Patient Information that is subject to the Clinical Laboratory Improvements Amendments of 1988

Financial Information

No financial transactions are to be carried out on this website. As such, your financial information will not be stored on this website. All online financial transactions with True Pathways shall be carried out on Ivypay or via therapy notes patient portal, both HIPAA compliant platforms.

Questions and Complaints

For questions regarding this Privacy Notice, please contact Aida Cajdric-Vrhovac, Ph.D. at aidacajdricvrhovac@outlook.com. If you are concerned or believe that your privacy rights have been violated, please contact Aida Cajdric-Vrhovac, Ph.D. at aidacajdricvrhovac@outlook.com. You may also make a complaint in writing to the U.S. Department of Health and Human Services Office for Civil Rights. For the address, please contact Aida Cajdric-Vrhovac, Ph.D. at aidacajdricvrhovac@outloook.com.