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.

This Notice of Privacy Practices describes the privacy practices of Quit Genius Medical, P.A., Quit Genius Medical, P.C., Quit Genius Medical of Kansas, P.A., and Quit Genius Medical of New Jersey, P.C. (“we” or “us”). We are an organized health care arrangement that jointly participates in numerous activities, including assessment and improvement of our health care services. We provide a platform and services for treating individuals with substance use management challenges through a combination of any or all of the following depending on the program and the individual’s needs: digital content and other engagement tools, coaching programs, cognitive behavioral therapy, and medication assisted treatment, which are delivered via the Quit Genius mobile application (our “App”), our website (available at www.pelagohealth.com ), connected devices, chat sessions, live virtual telephone or video sessions, and in certain cases in person meetings. This notice applies to our physicians, counselors and other personnel who provide services to you.

Please note: we are in the process of rebranding from “Quit Genius” to “Pelago”, a process which will complete this Fall 2023. During this transition period you may see or hear references to both brand names, including below. Each is a brand name under which the entities named above do business. The entities are the same entities regardless of which brand name they use.

For information about how we collect, use, and share personal information other than protected health information, please see our privacy policy at https://www.pelagohealth.com/privacy. This Notice of Privacy Practices supplements and is in addition to that privacy policy.

We understand that your health information is personal and we are committed to protecting and respecting your privacy. We are required by law to maintain the privacy and security of your protected health information. We will let you know if an event occurs that compromises the privacy or security of your information. We must follow the duties and privacy practices described in this notice and give you a copy of it.

We typically use or share your health information in the following ways:

• Treat you: We can use your health information and share it with other health care professionals who are treating you. For example, a doctor treating you for an injury asks another doctor about your overall condition.
• Run our organization: We can use and share your health information to run our practices, improve your care, and contact you when necessary. For example, we use health information about you to manage your treatment and services.
• Bill for your services: We can use and share your health information to bill and get payment. For example, we give information about you to your health insurance plan so it will pay for your services.

How else can we use or share your health information?

• We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes.
• Help with public health and safety issues: We can share health information about you for certain situations such as: (1) preventing disease; (2) helping with product recalls; (3) reporting adverse reactions to medications; (4) reporting suspected abuse, neglect, or domestic violence; and (5) preventing or reducing a serious threat to anyone’s health or safety.
• Do research: We can use or share your information for health research.
• Comply with the law: We 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 we’re complying with federal privacy law.
• Respond to organ and tissue donation requests: We can share health information about you with organ procurement organizations.
• Work with a medical examiner or funeral director: We 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: We can use or share health information about you: (1) for workers’ compensation claims; (2) for law enforcement purposes or with a law enforcement official; (3) with health oversight agencies for activities authorized by law; (4) for special government functions such as military, national security, and presidential protective services.
• Respond to lawsuits and legal actions: We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Uses and Disclosures Requiring Your Authorization

For any purpose other than the ones described above, we only use or share your protected health information when you give us your written authorization.

• Marketing: We must obtain your written authorization prior to using your protected health information for purposes that are marketing under HIPAA. We may market to you in a face-to-face encounter and give you promotional gifts of nominal value without obtaining your written authorization.
• Sale of protected health information: We will not make any disclosure of protected health information that is a sale of protected health information under HIPAA without your written authorization.

You may cancel your authorization, except to the extent that we have relied upon it, by delivering a cancellation notice to the office identified below.

If you have received treatment, diagnosis, or referral for treatment from our drug or alcohol use programs, the confidentiality of drug or alcohol use records is protected by federal law (at 42 U.S.C. § 290dd-2) and regulations (at 42 CFR part 2). As a general rule, we may not tell a person outside the programs that you participated in any of these programs, or share any information identifying you as an individual with substance misuse and/or an alcohol or drug use disorder, unless the disclosure has been made in either one or more of the following instances:

• authorized in writing;
• authorized by a court order;
• made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation purposes;
• made in connection with treatment, payment, or health care operations.
• made to qualified service organizations that provide services to the program such as data processing, bill collecting, medical staffing or other professional services;
• made to report suspected child abuse or neglect; or
• made to report a crime or a threat to commit a crime on program premises or against program personnel.

A violation by us of the federal law and regulations governing drug or alcohol abuse is a crime. Suspected violations may be reported to the United States Attorney in the district where the violation occurs.

In many circumstances, we are required to provide more restrictive treatment to the following types of information: genetic testing information, information on persons with developmental disabilities, information concerning HIV/AIDS testing, and alcohol and drug use treatment (see above).

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

• Get a copy of your medical and billing records: You can ask to see or get an electronic or paper copy of your medical and billing records that we have about you. Ask us how to do this. We will provide a copy or summary of your health information. We may charge a reasonable, cost-based fee.
• Ask us to correct your medical or billing records: You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this. We may say “no” to your request, but we’ll tell you why in writing.
• Request confidential communications: You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address by emailing us at privacy@pelagohealth.com[insert procedure]. We will say “yes” to reasonable requests.
• Ask us to limit what we use or share: You can ask us not to use or share certain health information (1) for treatment, payment, or health care operations, (2) to a family member, other relative, or other person involved with your care or with payment related to your care, or (3) to notify or assist in the notification of the person regarding your location and general condition. We are not required to agree to your request, and we may say “no,” for example, if it would affect your care. If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purposes of payment or our operations with your health insurer or other health plan. We will say “yes” unless a law requires us to share that information.
• Get a list of those with whom we’ve shared information: You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why. We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make pursuant to an authorization form that you signed). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
• Get a copy of this privacy notice: You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
• File a complaint if you feel your rights are violated: You can complain if you feel we have violated your rights by contacting us using the information below. You can also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights. If you ask, we can provide contact information for the Office for Civil Rights. We will not retaliate against you for filing a complaint.

We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website.

Email:
privacy@pelagohealth.com

Address:
Quit Genius Medical
Attn: Privacy and Compliance
1632 1st Avenue #20163
New York, NY 10028

Telephone:
+1 877-349-7755