Privacy Policy

VISTA HILL
NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL (CLINICAL) INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

This client notice “Notice” describes the privacy practices of Vista Hill service operations that are considered covered entities under HIPAA (defined below). It explains how health information about you may be used and disclosed, and your rights regarding Protected Health Information (PHI) and / or Substance Use Disorder (SUD) records.

Vista Hill programs and services that produce, share and maintain PHI and / or SUD records follow the terms of this Notice. In addition, these entities, sites and locations may share protected health information (PHI) and / or SUD records with each other for treatment, payment or health care operations purposes described in this notice.

If you have any questions about this notice ask your staff, program manager, or call 858.514.5100 to leave a message for the Vista Hill Privacy Officer or email [email protected] and enter “Privacy Matter” into the subject field.

Our Pledge Regarding Protected Health Information (PHI)

We understand that information about you and your health is personal and we are committed to safeguarding it. Protected Health Information (“PHI”) is any information related to your clinical treatment services that is produced, shared or maintained in any manner by our organization. We may create and maintain a record of the treatment services you receive in our programs that are covered by one or both federal laws: Health Insurance Portability and Accountability Act of 1996 or HIPAA, and 42 CFR Part 2, pertaining to Substance Use Disorders. We are obligated to generate clinical records to provide you with quality care and to comply with these and other certain legal requirements. This Notice applies to all of the clinical records of your treatment services generated by the clinical staff.

Important Note: You may ask for a paper or electronic copy of this Notice of Privacy Practices at any time from your program staff or by contacting the Privacy Officer (contact details are in the opening paragraphs on page one).

Our Responsibilities
This Notice will tell you about the ways in which we may use and disclose Protected Health Information (PHI) about you. We also describe your rights and certain obligations we have regarding the use and disclosure of PHI.

We are required by law to:

  • Maintain the privacy of your PHI and SUD records;
  • Ensure that PHI that identifies you is kept private (with certain exceptions);
  • Follow the terms of this Notice that is currently in effect
  • Notify you following a breach of your PHI and / or SUD records

While providing clinical treatment to you, our employees, contracted professionals, volunteers, student trainees, and all other health care professionals and support staff affiliated with Vista Hill follow this Notice.

How We May Use and Disclose Clinical or Health Information About You

The following categories describe different ways that we use and disclose protected health information (PHI). For each category of uses or disclosures, we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will generally fall within one of the categories. There may be some uses and disclosures that require your specific authorization.

Treatment. We may use PHI and / or SUD records about you to provide or coordinate your clinical treatment and services. We may disclose PHI and / or SUD records about you to internal clinical staff. For example, a therapist or counselor may share information with their clinical supervisor regarding you for treatment planning purposes. We may also disclose your PHI and/or SUD records to other Vista Hill clinical programs, other healthcare providers, doctors, therapists, nurses, technicians, students, clinical personnel, or other health care facilities or entities for treatment, care coordination or quality improvement activities.

Payment. We may use and disclose PHI and / or SUD records about you so that the treatment and services you receive at our programs may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to provide your health plan with clinical information about services you received so we may obtain reimbursement for the services.

Health Care Operations. We may use and disclose your PHI and / or SUD records about you for health care operations. These uses and disclosures are necessary to operate our programs and make sure that all of our clients receive quality care. For example, we may use PHI and / or SUD records to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also perform quality assurance activities or disclose information to clinical and non-clinical personnel for review and learning purposes, billing and appointment scheduling. For improvements in the care and services we offer, we may share deidentified information for research study purposes.

We may also disclose your PHI and / or SUD Records to other health care providers when such PHI and / or SUD Records are required for them to treat you, obtain payment for services you receive, or conduct certain health care operations. For example, we will share your PHI and / or SUD records with an ambulance company so their personnel can evaluate you, provide lifesaving services and transport to a hospital emergency department.

Appointment Reminders. We may use and disclose limited information to contact you as a reminder that you have an appointment for treatment or program services.

Fundraising. Vista Hill will not use or disclose your health information for fundraising purposes unless you have signed a specific release to authorize such use.

Special Situations

As Required By Federal or State Law. We will disclose PHI and / or SUD records about you when required to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety. We may also use and disclose PHI about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.

Military and Veterans. If you are a member of the armed forces, we may release PHI and / or SUD records if required by military command authorities.

Public Health Risks. We may disclose PHI and / or SUD records about you for public health activities. These activities generally include the following:

  • To prevent or control disease, injury or disability
  • To report births and deaths
  • To report the abuse or neglect of children, elders and dependent adults
  • To report reactions to medications or problems with products
  • To notify people of recalls of products they may be using
  • To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
  • To notify emergency response employees regarding a possible exposure to HIV/AIDS to the extent necessary to comply with state and federal laws.

Victims of Abuse, Neglect or Domestic Violence. To notify the appropriate government authority if we reasonably believe a client has been the victim of abuse, neglect or domestic violence.

Health Oversight Activities. We may disclose PHI to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Lawsuits and Disputes. If you are involved in a lawsuit or a dispute, PHI and / or SUD records, or testimony relaying the content of such records, will not be used or disclosed in any civil, administrative, criminal, or legislative proceedings against you unless based on your specific written consent or a court order. If PHI and / or SUD records about you is requested by another party in a subpoena, discovery request, or other lawful process, can only be released if formal effort has been made to inform you in a legal notice about the records only request and you have not filed a formal objection with the court.

Law Enforcement. We may release PHI and / or SUD records information if asked to do so by a law enforcement official:

  • In response to a court order, subpoena, warrant, summons or similar process
  • To identify or locate a suspect, fugitive, material witness, or missing person
  • To identify the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s authorization
  • About the death we believe may be the result of criminal conduct
  • Criminal conduct at the program or facility
  • Emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.

Coroners, Medical Examiners and Funeral Directors. We may disclose PHI and / or SUD records health information to a coroner or medical examiner. This may be necessary for example, to identify a deceased person or determine the cause of death.

National Security and Intelligence Activities. We may disclose PHI and / or SUD records information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law. This may include PHI and / or SUD records for the protection of federal and state elective constitutional officers and their families.

Protective Services for the President and Others. We may disclose PHI and / or SUD records information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.

Inmates. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release PHI and / or SUD records information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Your Rights Regarding Health Information About You
You have the following rights under HIPAA and 42 CFR Part 2 regarding PHI and / or SUD records and information we maintain about you. This section explains your rights and some of our responsibilities to help you.

Obtain a Copy of Your PHI and / or SUD records. You have the right to request your PHI and/or SUD records by completing a valid release of information form submitted to your program manager, director or Privacy Officer. Disclosed documents may be in paper form or electronic format with a charge for copying, mailing and supplies. In certain circumstances, psychotherapy notes or SUD counseling notes may be excluded. Further exclusion may be for treatment records no longer in our possession due to a schedule of record retention.

Right to Inspect and Copy. You have the right to inspect and obtain a copy of your PHI and / or SUD records that may be used to make decisions about your care. Usually, this includes medical and possibly billing records but may exclude psychotherapy notes and SUD counseling notes and sometimes other mental health and SUD documentation.

To inspect PHI and / or SUD records that may be used to make decisions about you, you must submit your request in writing to your program director or manager as a current client or to the Vista Hill Privacy Officer, as a past client. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to PHI and / or SUD records, you may request that the denial be reviewed.

Right to Amend. You have the right to request that we amend the PHI and / or SUD records we keep about you in your clinical and billing records. If you feel that PHI and / or SUD records we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by Vista Hill.

To request an amendment, your request must be made in writing and submitted to the Vista Hill Privacy Officer, contact information is described on page one. In addition, you must provide the reason(s) that supports your request. We may deny your request for an amendment if it is not in writing or does not include the reason(s) to support the request or other reasons. Some examples are below:

  • The information in the record was not created by us
  • We believe the information you wish to amend is accurate, current, and complete without your requested amendment
  • The information is not part of the PHI maintained for the organization
  • The information is part of an electronic record system under ownership and control of a governmental agency

Even if we deny your request for amendment, you have the right to submit a written addendum, not to exceed 250 words, with respect to any item or statement in your record you believe is incomplete or incorrect. If you clearly indicate in writing that you want the addendum to be made part of your clinical record we will file with your records and include it whenever we make an authorized disclosure.
Right to an Accounting of Disclosure. You have the right to request a record of the disclosures of your PHI and / or SUD Records in paper or electronic form. The accounting of disclosures we have made of PHI and / or SUD records about you do not include those made for own legal uses for treatment, payment or health care operations, disclosures excluded by law or those you or your legal representative have authorized.

To request an accounting of disclosures, you must submit your request by email or written communication to the program manager, director or the Vista Hill Privacy Officer. Your request must state a time period which may not be longer than three (3) years. We may charge you for the costs of providing the list. We will notify you of the cost involved that will be charged to you. You may choose to withdraw or modify your request at that time before any further costs are incurred.

Right to Request Restrictions. You have the right to request a restriction or limitation on the PHI and / or SUD records we use or disclose about you for treatment payment or health care operations.

However, we are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you with access to emergency treatment. To request restrictions, you must make your request in writing to the Vista Hill Privacy Officer. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.

Right to Request Confidential Communications. You have the right to request that we communicate with you about PHI and / or SUD record matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. You must make your request for confidential communications in writing to your therapist/counselor or case manager or director. We will not ask you the reason for your request. We will accommodate reasonable requests. Your request must specify how or where you wish to be contacted.

Right to Revoke Your Authorization. You may revoke your authorization for us to use and disclose your PHI and / or SUD records at any time by submitting a request in writing to the appropriate office or department.

If you revoke your permission, this will stop any further use or disclosure of your PHI and / or SUD records for the purposes covered by your written authorization, except if we have already acted in reliance on your permission. We are unable to take back any disclosures we have already made with your permission or lawful disclosure, and we are required to retain our records of the care that we provided to you.

Right to a Copy of This Notice. You have the right to obtain a paper or electronic copy of this notice and may ask your program staff for a copy at any time. Even if you have agreed to receive this notice electronically or review in paper format, you are still entitled to a paper copy of this notice.

You may obtain a copy of this notice at our website: www.vistahill.org. To request a paper or electronic copy, either call 858.514.5100, or email [email protected]. entering “Notice of Privacy Practices Copy Request” into the subject line.

Changes to this Notice of Privacy Practices
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for PHI and / or SUD records we already have about you as well as any information we receive in the future. We will post a current copy of the current notice in our program sites that produce and maintain PHI and / or SUD records. Each time you register or are admitted to our programs for treatment or health care services, we will offer you a copy of the current notice in effect.

Breach Notification
We will notify you in the event of a breach (as defined by HIPAA) of your PHI and/or SUD Records.

Complaints
If you believe your privacy rights have been violated, you have several ways to file a complaint:

  • Send a letter addressed to Secretary of the U.S. Department of Health and Human Services, Office of Civil Rights, 200 Independence Ave. SW., Wahington, DC 20201
  • Call 1-877-696-6775 (Office of Civil Rights)
  • Visit https://www.hhs.gov/hipaa/filing-a-complaint/index.html.
  • Submit it written form addressed to: Vista Hill Privacy Officer, 8910 Clairemont Mesa Blvd., San Diego, CA 92123. In the subject line enter “Privacy Complaint”.

You will not be penalized for filing a complaint. Violation of federal law and regulations for SUD records is a crime (42 CFR 2.22 (a)(2)(b)(2)).
End of Vista Hill Notice of Privacy Practice

End of Vista Hill Notice of Privacy Practice

Effective Date: March 2026