NOTICE OF PRIVACY PRACTICES
Effective Date of this Notice: October 8, 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.
My Pledge Regarding Your Health Information
I understand that information about you and your health care is personal. I am committed to protecting the privacy and security of your Protected Health Information (PHI).
I create and maintain records of the care and services you receive from me. I need these records to provide you with quality care and to meet applicable legal and professional requirements.
This Notice explains how I may use and disclose your health information, your rights regarding your health information, and my responsibilities regarding the privacy of your information.
I am required by law to:
Maintain the privacy and security of your PHI.
Provide you with this Notice describing my legal duties and privacy practices regarding your PHI.
Follow the terms of the Notice currently in effect.
Notify you as required by law if a breach occurs that compromises the privacy or security of your unsecured PHI.
Follow applicable federal and Michigan laws that provide additional protections for your health information.
I may change the terms of this Notice. Changes may apply to all PHI I maintain about you, including information collected before the change. The current Notice will be available upon request and on my website.
How I May Use and Disclose Your Health Information
Your health information is confidential. I will use or disclose your PHI only as permitted or required by applicable federal and Michigan law. Some uses and disclosures are permitted without your written authorization under Health Insurance Portability and Accountability Act (HIPAA).
Michigan law provides additional confidentiality protections for communications and information shared between a licensed professional counselor and client. Therefore, a disclosure that may be permitted under HIPAA may still require your consent under Michigan law.
Treatment: I may use or disclose your PHI as permitted by law to provide, coordinate, or manage your health care.
For example, I may communicate with another health care provider involved in your care when permitted by applicable law.
Payment: I may use or disclose your PHI as permitted by law to obtain payment for services or to address billing and insurance matters.
For example, I may provide information to your health insurance plan when necessary to process a claim or determine benefits.
Health Care Operations: I may use or disclose your PHI as permitted by law for certain health care operations necessary to operate my practice, such as billing activities, compliance, quality improvement, and other administrative functions permitted by law. I may also consult with other qualified health care professionals or participate in clinical supervision regarding your care when permitted by applicable law. When reasonably possible, I will limit information shared during consultation or supervision to information that is not reasonably identifiable to you.
Because Michigan law provides additional protections for communications between licensed professional counselors and clients, I will not assume that a disclosure permitted under HIPAA is automatically permitted under Michigan law. When Michigan law requires your consent, I will obtain the required consent before making the disclosure unless another legal exception applies.
Other Uses and Disclosures Permitted or Required by Law
I may use or disclose your PHI without your written authorization only when the disclosure is permitted or required by applicable law.
Depending on the circumstances and applicable legal requirements, this may include disclosures:
Required by federal or Michigan law.
For certain public health activities, including reporting certain communicable diseases or suspected abuse or neglect when reporting is required by law.
For certain health oversight activities, such as audits or investigations.
In connection with certain judicial or administrative proceedings when applicable legal requirements are met.
To law enforcement when disclosure is permitted or required by law.
To coroners or medical examiners when permitted or required by law.
For workers' compensation purposes when permitted or required by law.
For certain research purposes when permitted by applicable law.
For certain specialized government functions when permitted or required by law.
When necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public, when permitted by law.
For appointment reminders and, when permitted by law, information about treatment alternatives or health-related services or benefits that I provide.
The existence of a legal exception does not mean that I will automatically disclose your information whenever a request is made. I will evaluate requests for your information based on the applicable federal and Michigan confidentiality requirements and will disclose only the information I am permitted or required to disclose.
Uses and Disclosures That Require Your Authorization
Certain uses and disclosures of PHI require your written authorization under federal law and/or applicable Michigan law.
Psychotherapy Notes: I do not maintain psychotherapy notes as that term is defined under HIPAA, 45 CFR § 164.501. My clinical documentation, including progress notes and other records maintained as part of your medical record, is not considered "psychotherapy notes" simply because it contains information about your therapy sessions.
Marketing: I will not use or disclose your PHI for marketing purposes when your written authorization is required by law.
Sale of PHI: I will not sell your PHI when your written authorization is required by law.
Other Uses Requiring Authorization: For uses or disclosures of your PHI that are not otherwise permitted or required by law, I will obtain your written authorization before making the disclosure.
You may revoke an authorization in writing at any time, except to the extent that I have already relied on the authorization or taken action based on it.
Substance Use Disorder Records
Certain records relating to substance use disorder diagnosis, treatment, or referral may be protected by additional federal confidentiality requirements under 42 CFR Part 2.
If I create or maintain records that are subject to Part 2, those records may have additional protections and restrictions regarding their use and disclosure. I will comply with applicable federal and Michigan requirements governing such records.
For records subject to Part 2, certain uses and disclosures that HIPAA would otherwise permit may require your consent. Part 2 records generally may not be used or disclosed, or used to provide testimony, in a civil, criminal, administrative, or legislative proceeding against you unless you provide specific written consent or a court order meeting applicable Part 2 requirements.
If your information is protected by Part 2, you may have additional rights regarding the use and disclosure of those records, including rights concerning consent and certain disclosures.
If I ever use or disclose Part 2 records for fundraising purposes, I will provide a clear and conspicuous opportunity for you to opt out before such use or disclosure.
Disclosures to Family, Friends, or Others Involved in Your Care
I may disclose limited PHI to a family member, close personal friend, or another person you identify as being involved in your care or payment for your care when permitted by applicable law. When required by law, I will provide you with an opportunity to agree or object before making such a disclosure. In an emergency, I may make a disclosure when permitted by law if I determine that doing so is appropriate under the circumstances.
Your Rights Regarding Your Health Information
You have the following rights regarding your PHI, subject to applicable federal and Michigan law:
Right to Request Restrictions: You have the right to request a restriction or limitation on the PHI I use or disclose for treatment, payment, or health care operations. I am not required to agree to your request, except as required by law.
Right to Request a Restriction for Services Paid Out of Pocket: If you pay for a health care service or item completely out of pocket and request that the information relating to that service or item not be disclosed to your health plan for payment or health care operations purposes, I will comply with your request when required by HIPAA.
Right to Request Confidential Communications: You have the right to request that I communicate with you about your health information in a particular way or at a particular location. I will accommodate reasonable requests as required by law.
Right to Inspect and Obtain a Copy of Your Health Information: You have the right to inspect and obtain a copy of PHI contained in your designated record set, subject to applicable federal and Michigan law. I will respond to your request within the timeframe required by applicable law. A reasonable cost-based fee may apply when permitted by law.
Right to Request an Amendment: If you believe information in your records is incorrect or incomplete, you may request an amendment to your health information. I may deny your request in certain circumstances permitted by law. If your request is denied, I will provide you with information about your rights regarding the denial, including your right to submit a statement of disagreement when applicable.
Right to an Accounting of Disclosures: You have the right to request an accounting of certain disclosures of your PHI made by me, subject to applicable federal and Michigan law. The accounting generally covers disclosures made during the six years preceding your request, unless a shorter period is requested or a different period is required by applicable law. If your information is protected by 42 CFR Part 2, additional accounting rights may apply.
Right to Choose a Personal Representative: You may choose a person to act on your behalf regarding your health information when permitted by law. If someone has legal authority to act as your personal representative, I will verify that person's authority before allowing them to exercise your rights or make decisions regarding your health information.
Right to Obtain a Copy of This Notice: You have the right to receive a paper or electronic copy of this Notice at any time.
Michigan Privacy Protections
As a licensed professional counselor in Michigan, I am subject to Michigan laws that protect the confidentiality of communications and information shared between a licensed professional counselor and client. I will protect your confidential information in accordance with applicable federal and Michigan law. I will not disclose confidential information simply because a disclosure may be permitted under HIPAA. When your consent is required by applicable law, I will obtain the appropriate consent before disclosing your information unless another legal exception applies.
Breach Notification
If a breach of your unsecured PHI occurs that requires notification under applicable law, I will notify you as required by law.
Questions and Complaints
If you have questions about this Notice or believe your privacy rights have been violated, you may contact:
Create Wellness Counseling LLC
Courtney Thurston, MA, LPC, ATR
Email: courtney@createwellnesscounseling.com
Phone: 734-627-7614
You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights.
You will not be retaliated against for filing a privacy complaint.