PRIVACY NOTICE
Notice of Privacy Practices
Last Updated: September 8, 2025
At Positive Synergy, we are committed to protecting the privacy and confidentiality of your/your children’s personal health information. This notice explains how we may use and disclose your/your children’s health information, your rights regarding that information, and our obligations under federal and state law.
This notice is provided in accordance with federal law, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and Massachusetts state law, including Massachusetts General Laws Chapter 111, Sections 70E and 70F, which provide additional protections for certain kinds of health and mental health information.
Our legal duty, as required by law, is to maintain the privacy of your Protected Health Information (PHI), to provide you with this notice of our legal duties and privacy practices with respect to your PHI, and to abide by the terms of this notice currently in effect. We will not release personally identifiable information about you without your permission, unless the release is to provide service you expect from us or is otherwise in accordance with the law. Even when allowed, use and disclosure are limited to the minimum amount reasonably necessary for the intended task.
How We May Use and Disclose Your PHI
Protected Health Information (PHI) means individually identifiable health information that we create or receive, including information about your past, present, or future physical or mental health condition; the provision of health care; or the payment for health care services.
As a provider of ABA services, we are a covered entity under HIPAA. A covered entity means that Positive Synergy is an organization that transmits any health information in electronic form in connection with a HIPAA transaction.
Except when prohibited by state or federal laws, we may use and disclose your PHI for treatment, payment and health care operations. We do not need to ask for your specific permission to do these following things, explained below:
Treatment
We may use and disclose your PHI to provide, coordinate, or manage your ABA therapy and related services. For example, we may share information with your child’s physician or other health care providers, other covered entities, involved in your child’s care.
Payment
We may use and disclose your PHI to obtain payment for services provided, including billing and collection activities, and to determine eligibility for benefits.
Healthcare Operations
We may use and disclose your PHI for our operations, including quality assessment and improvement activities, training of staff, and accreditation activities.
Required by Law
We may disclose your PHI when required to do so by federal, state, or local law, including reporting abuse, neglect, or domestic violence, and responding to public health threats.
Public Health Activities
We may disclose your PHI to public health authorities for purposes related to disease prevention, injury reporting, and public health surveillance.
Health Oversight Activities
We may disclose your PHI to health oversight agencies for activities authorized by law, such as audits, investigations, and inspections.
Judicial and Administrative Proceedings
We may disclose your PHI in response to a court or administrative order, subpoena, discovery request, or other lawful process.
Law Enforcement
We may disclose your PHI to law enforcement officials for purposes such as identifying or locating a suspect, fugitive, material witness, or missing person.
To Avert a Serious Threat to Health or Safety
We may use or disclose your PHI when necessary to prevent a serious threat to your health and safety or the health and safety of others.
Workers’ Compensation
We may disclose your PHI as authorized by and to the extent necessary to comply with laws relating to workers’ compensation or similar programs.
Other Uses with Authorization
All other uses or disclosures not described in this Notice will require written authorization. You may revoke this authorization at any time in writing.
Your Rights Regarding Your Health Information
You have the following rights in regards to your PHI. You should submit any requests to exercise these rights in writing to the program providing you services. Written requests should identify the information to be restricted, the type of restriction being requested, and to whom the limits should apply.
Right to Inspect and Copy: You may request to review or obtain a copy of your or your child’s health record.
Right to Amend: You may request that we correct your record if you believe it is incomplete or incorrect.
Right to an Accounting of Disclosures: You may ask for a list of certain disclosures we have made of your PHI.
Right to Request Restrictions: You may ask us not to use or share certain information. We are not always required to agree, but we will consider your request.
Right to Confidential Communications: You may request that we contact you in a specific way (for example, only by mail or at work instead of home).
Right to a Paper Copy of This Notice: You may request a paper copy at any time, even if you have agreed to receive it electronically.
Right to Breach Notification: You will be notified if your PHI is improperly accessed or disclosed in a way that compromises its security or privacy.
Right to Complain: If you believe your privacy rights have been violated, you may file a complaint with us or with the U.S. Department of Health and Human Services, Office for Civil Rights. Filing a complaint will not affect your care or result in retaliation.
To file a complaint, contact:
Positive Synergy and/or Office for Civil Rights
Privacy Office U.S Department of Health & Human Services
1573 Fall River Ave 15 New Sudbury Street, Room 1875
Seekonk, MA 02771 Boston, MA 02203
(508) 216-2696 (617) 565-1340; TDD: (800) 537-7697
https://www.hhs.gov/ocr
Rights to Amend
Positive Synergy reserves the right to change our privacy practices and the notice at any time. Any changes will apply to PHI we already hold, as well as new information we receive in the future. We will post the current notice in our office and on our website. You may request a copy at any time.
Contact Information
For more information about this notice or your privacy rights, please contact:
Privacy Officer
Positive Synergy
1573 Fall River Ave, Seekonk, MA 02771
(508) 216-2696
operations@psaba.org