Privacy Policy

Notice of Privacy Practices

As Required by the Privacy Regulations Created as a Result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA)

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU (AS A PATIENT OF THIS PRACTICE) MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO YOUR INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION

PLEASE REVIEW THIS NOTICE CAREFULLY

General Information

SES Operating Corp. dba Harlem East Life Plan (HELP) is dedicated to maintaining the privacy of your Protected Health Information (PHI).  In conducting our business, we will create records regarding you and the treatment and services we provide you.  We are required by law to maintain the confidentiality of health information that identifies you.  We also are required by law to provide you with this notice of our legal duties and the privacy practices that we maintain concerning your PHI.  By federal and state law, we must follow the terms of the Notice of Privacy Practices that we have in effect at the time.

We realize that these laws are complicated, but we must provide you with the following important information:

A. How we may use and disclose your PHI
B. Use of your PHI in Special Circumstances
C. Your Privacy Rights
D. HELP’s obligations concerning the use and disclosure of your PHI
E. Complaints and Questions

The terms of this notice apply to all records containing your PHI that are created or retained by our practice.  We reserve the right to revise or amend this Notice of Privacy Practices.  Any revision or amendment to this notice will be effective for all your records that HELP created or maintained in the past and for any of your records that we may create or maintain in the future.  Our practice will post a copy of our current Notice in our offices in a visible location at all times, and you may request a copy of our most current Notice at any time.

If you have any questions about this policy and/or HIPAA related concerns, contact HELP’s Compliance Officer, Erika Donovan Estades who can be reached at 212-876-2300 at ext. 163.

A. How We May Use and Disclose Your Protected Health Information (PHI)

The following examples illustrate some of the ways HELP may use and disclose your Protected Health Information (PHI) after you sign our authorization form. You may revoke your authorization at any time except to the extent that HELP has already relied on your authorization.  This list is not meant to be exhaustive.

  1. Treatment.  HELP may use your PHI to treat you.  For example, we may ask you to have laboratory tests (such as blood or urine tests), and we may use the results to help us treat you.  Many of the people who work for HELP may use or disclose your PHI in order to treat you or to assist others in your treatment.
  2. Payment.  Our practice may use and disclose your PHI in order to bill and collect payment for the services you receive from us.  For example, we may contact your health insurer to certify that you are eligible for benefits, and we may provide your insurer with details regarding your treatment to determine if your insurer will pay for your treatment.  Also, we may use your PHI to bill you or people that are responsible directly for services and items.
  3. Health Care Operations.  HELP may use and disclose your PHI to evaluate the quality of care you received from us, or to conduct cost-management and business planning activities. This may include:
    • Appointment Reminders.  Our practice may use and disclose your PHI to contact you and remind you of an appointment.
    • Treatment Options.  Our practice may use and disclose your PHI to inform you of potential treatment options or alternatives.
    • Health-Related Benefits and Services.  Our practice may use and disclose your PHI to inform you of health-related benefits or services that may be of interest to you.
    • Release of Information to Family/Friends.  With your authorization, our practice may release your PHI to a friend or family member that is involved in your care, or who assists in taking care of you.
    • Emergencies.  HELP may use or disclose your PHI in an emergency treatment situation.  If this happens, a HELP staff member will try to obtain your consent as soon as possible after the delivery of treatment; if HELP has attempted to obtain your consent unsuccessfully, he or she may still use or disclose your PHI to treat you if we determine that it is in your best interest based on our professional judgment.
    • Communication Barriers.  HELP may use and disclose your PHI for interpretation purposes if a staff member has attempted to obtain consent from you but is unable to because of communication barriers and HELP reasonably concludes that you have chosen to be assisted by an interpreter, from your willingness to continue the encounter using the interpreter, from your willingness to continue the encounter using the interpreter, and reasonably infers that you do not object to HELP’s use or disclosure of your PHI under the circumstances.
  4. Disclosures Required by Law.  HELP will use and disclose your PHI when we are required to do so by federal, state, or local law.
  5. Business Associates. We work with trusted partners who help us provide your care and handle administrative services like billing and medical records. These partners are required by law to protect your health information just as we do. We share information only when necessary with:
    • Billing companies and transcription services
    • Healthcare networks (Independent Practice Associations/IPAs)
    • Secure regional health systems (RHIOs) that connect your providers
    • NY State mental health programs (like PSYCKES) for care coordination
    • Before sharing any information, we sign strict agreements requiring these partners to maintain your privacy at all times.
  1. Emails. We may use email to communicate with you, but we will never send unprotected emails containing your health information without your permission. If you choose to allow email communications, you can change your mind and withdraw this permission at any time.

B. USE AND DISCLOSURE OF YOUR PHI IN SPECIAL CIRCUMSTANCES

  1. Public Health.  HELP may disclose your PHI to public health authorities that are authorized by law to collect information for the purpose of public health.  The disclosure will be made for the purposes of controlling disease, injury or disability or preventing death.  Example include but are not limited to:
    • Maintaining vital records, such as births and deaths;
    • Reporting child abuse or neglect;
    • Preventing or controlling disease, injury or disability;
    • Notifying a person regarding potential exposure to a communicable disease
    • Notifying a person regarding a potential risk for spreading or contracting a disease or condition
    • Reporting adverse medical events including reactions to drugs or problems with products or devices
    • Notifying individuals if a product or device they may be using has been recalled
    • Notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance
  2. Health Oversight Activities.  HELP may disclose your PHI to a health oversight agency for activities authorized by law.  Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.
  3. Lawsuits and Similar Proceedings.  HELP may use and disclose your PHI in response to a court   or administrative order in compliance with federal regulations as stated in 42 C.F.R. Part 2.
  4. Law Enforcement.  We may release PHI when applicable legal requirements are met for law enforcement purposes to investigate a crime that has occurred and other disclosures to law enforcement based on court order, warrant, summons, subpoena or similar legal process or in an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identify or location of the perpetrator).
  5. Deceased Patients.  Our practice may release PHI to a medical examiner or coroner to identify a deceased individual or to identify the cause of death.  If necessary, we also may release  information in order for funeral directors to perform their jobs.
  6. Serious Threats to Health or Safety.  HELP may use and disclose your PHI when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public.  Under these circumstances, we will only make disclosures to a person or organizations able to prevent the threat.
  7. National Security.  HELP may disclose your PHI to federal officials for intelligence and national security activities authorized by law.  We also may disclose your PHI to federal officials in order to protect the President, other officials or foreign heads of state, or to conduct investigations.
  8. Inmates.  HELP may disclose your PHI to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official.  Disclosure for these   purposes would be necessary: (a) for the institution to provide health care services to you, (b) for the safety and security of the institution, and/or (c) to protect your health and safety or the health and safety of other individuals.
  9. Workers’ Compensation.  Our practice may release your PHI for workers’ compensation and similar programs as authorized by law.
  10. Serious Threats:  Your PHI may be used or disclosed by us if we, in good faith, believe that the use and disclosure is necessary to prevent or lessen a serious and imminent threat to the health and safety of a person or the public and the disclosure is made to a person(s) reasonably able to prevent or lessen the threat.
  11. Required Uses and Disclosures.  Under the law, we must make disclosures to you and when required to the Secretary of the Department of Health and Human Services to investigate or determine compliance with the requirements of Section 164.500 et seq.

C. YOUR PRIVACY RIGHTS
You have the following rights regarding the PHI that we maintain about you:

  1. Confidential Communications.  You have the right to request that HELP communicate with you about your health and related issues.  In order to request a type of confidential communication,  you must make a written request to SES Operating Corp d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163 specifying the requested method of contact, or the location where you wish to be contacted.  Our practice will accommodate reasonable requests.  You do not need to give a reason for your request.
  2. Requesting Restrictions.  You have the right to request a restriction in our use or disclosure of your PHI for treatment, payment or health care operations.  Additionally, you have the right to request that we restrict our disclosure of your PHI to only certain individuals involved in your care or the payment for your care, such as family members and friends.  We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you.  In order to request a restriction in our use or disclosure of your PHI, you must make your request in writing to SES Operating Corp. d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163.  Your request must describe in a clear and concise fashion:
    • the information you wish restricted;
    • whether you are requesting to limit HELP’s use, disclosure or both; and
    • to whom you want the limits to apply.
  1. Inspection and Copies.  You have the right to inspect and obtain a copy of the PHI that may be used to make decisions about you, including patient medical records and billing records, but not including to the following:
    • Psychotherapy notes: recorded by a health care provider who is a mental health professional documenting/analyzing the contents of conversation during a private counseling session or a group and that are separated from the medial record;
    • Information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding;
    • PHI that is subject to a law that prohibits access to it;
    • PHI from an entity other than HELP obtained under a promise of confidentiality when the access requested would be likely to reveal the source of the information.

      You must submit your request in writing to SES Operating Corp. d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163 in order to inspect and/or obtain a copy of your PHI.  HELP may charge a fee for the costs of copying, mailing, labor and supplies associated with your request. HELP may deny your request to inspect and/or copy in certain limited circumstances; however, you may request a review of our denial.  Another licensed health care professional chosen by us will conduct reviews.
  1. Amendment.  You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for our practice.  To request an amendment, your request must be made in writing and submitted to SES Operating Corp. d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163.  You must provide us with a reason that supports your request for amendment.  HELP will deny your request if you fail to submit your request (and the reason supporting your request) in writing.  Also, we may deny your request if you ask us to amend information that is in our option:  a) accurate and complete; b) not part of the PHI kept by or for HELP; c) not part of the PHI which you would be permitted to inspect and copy; or d) not created by HELP unless the individual or entity that created the information is not available to amend the information.
  2. Accounting of Disclosures.  All of our patients have the right to request an “accounting of   disclosures”.  An “accounting of disclosures” is a list of certain non-routine disclosures HELP has made of your PHI for non-treatment or operations purposes.  Use of your PHI as part of the routine patient care at HELP is not required to be documented.  For example, the doctor sharing information with the nurse or the billing department using your information to file your insurance claim.  In order to obtain an accounting of disclosures, you must submit your request in writing to SES Operating Corp. d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163.  All requests for an “accounting of disclosures” must state a time period, which may not be longer than six (6) years from the date of disclosure and may not include dates before April 14, 2003.  The first list you request within a 12-month period is free of charge, but HELP may charge you for additional lists within the same 12-month period.  HELP will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.
  3. Right to a Paper Copy of This Notice.  You are entitled to receive a paper copy of our notice of privacy practices.  You may ask us to give you a copy of this notice at any time.  To obtain a paper copy of this notice, contact SES Operating Corp. d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163.
  4. Right to File a Complaint.  If you believe your privacy rights have been violated, you may file a complaint with HELP or with the Secretary of the Department of Health and Human Services.  To file a complaint with HELP, contact SES Operating Corp. d/b/a Harlem East Life Plan, 2369 Second Avenue, New York, New York 10035, (212) 876-2300 ext. 163.  All complaints must be submitted in writing.  You will not be penalized for filing a complaint.
  5. Right to Provide Authorization for Other Uses and Disclosures.  HELP will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law.  Any authorization you provide to us regarding the use and disclosure of your PHI may be revoked at any time in writing.  After you revoke your authorization, we will no longer use or disclose your PHI for the reasons described in the authorization.  Please note, we are required to retain records of your care.

D. HELP’s OBLIGATIONS CONCERNING THE USE AND DISCLOSURE OF YOUR PHI

  1. Maintain Confidentiality
    • HELP is required by law to maintain the privacy and security of your PHI.
  2. Provide this Notice and Follow the Notice Terms
    • HELP must provide this Notice of Privacy Practices explaining how your PHI may be used/disclosed, your privacy rights, HELP’s legal duties.
    • HELP must follow the duties and privacy practices described in this notice.
  3. Notice of Breach
    • HELP must let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
  4. Limit Uses/Disclosures
    • HELP will not use/share your PHI other than as described in the Notice or as otherwise permitted by law unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

E. COMPLAINTS AND QUESTIONS

  1. If you have any questions or complaints regarding this notice, you may contact HELP’s Compliance Officer Erika Donovan Estades at (212) 876-2300, ext. 163 or visit 2369 Second Ave, New York, NY, 10035 or;

  2. Contact the Office for Civil Rights at:
    Office for Civil Rights
    U.S. Department of Health and Human Services
    200 Independence Avenue, S.W.
    Washington, D.C. 20201
    Phone: 202-619-0257
    Toll Free: 1-877-696-6775
    OCR Hotline-Voice: 800-368-1019

  3. HELP will not retaliate against you for filing a complaint and will continue to treat you.

Rev. June 2025