Notice of Privacy | Community Support Services

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.

If you have any questions about this notice, please contact:

Community Support Services Privacy Officer
150 Cross Street, Akron, OH 44311
Email: PrivacyOfficer@cssbh.org
Telephone: 330-253-9557 or 800-268-0014 ext. 604

COMMUNITY SUPPORT SERVICES

NOTICE OF PRIVACY PRACTICES

Effective Date: September 15, 2026

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. THIS NOTICE ALSO DESCRIBES SPECIAL PROTECTIONS THAT APPLY TO YOUR MENTAL HEALTH AND SUBSTANCE USE DISORDER RECORDS. PLEASE REVIEW IT CAREFULLY.

1. Contact Information

If you have questions about this Notice, our privacy practices, or wish to exercise any of the rights described below, please contact our Privacy Officer:

Title: Privacy Officer

Address: Community Support Services Inc, Attn: Privacy Officer, 150 Cross Street, Akron, Ohio 44311

Phone: 330-253-9557

Email: PrivacyOfficer@cssbh.org

2. Your Rights Regarding Your Health Information

You have the following rights with respect to the health information we maintain about you. To exercise any of these rights, please submit a request to our Privacy Officer using the contact information above.

Get an electronic or paper copy of your medical record. You may ask to see or receive an electronic or paper copy of your medical record and other health information we maintain about you, including records subject to 42 CFR Part 2 (substance use disorder records). We will provide a copy, or a summary if you agree, usually within 30 days of your request (we may take one 30-day extension if we notify you in writing why). We may charge a reasonable, cost-based fee. If we maintain an Electronic Health Record, you have a right to an electronic copy of your record in the form and format you request, if readily producible.

Ask us to correct your medical record. You may ask us to correct health information about you that you believe is incorrect or incomplete. We may deny your request, but if we do, we will explain why in writing, generally within 60 days.

Request confidential communications. You may ask us to contact you in a specific way (for example, a cell phone rather than a home phone) or to send mail to a different address. We will accommodate all reasonable requests.

Ask us to limit what we use or share. You may ask us not to use or share certain health information for treatment, payment, or health care operations. We are not required to agree, and we may decline if the limitation could affect your care. If you pay out-of-pocket in full for a service or item, you may ask us not to share information about that service with your health insurer for payment or operations purposes, and we will agree unless a law requires the disclosure.

Get a list of those with whom we've shared your information. You may request an accounting of disclosures we have made of your health information for up to six years before your request, including to whom and why. This accounting does not include disclosures for treatment, payment, or health care operations (unless we use an Electronic Health Record, in which case you may request an accounting of treatment, payment, and operations disclosures made in the preceding three years), and does not include certain other disclosures described by law. The first accounting in any 12-month period is free; we may charge a reasonable, cost-based fee for additional requests. You also have the right to receive an accounting of disclosures of your electronic Part 2 records made in the three years before your request, and to request a list of disclosures made by any intermediary during that same period.

Get a copy of this Notice. You may request a paper or electronic copy of this Notice at any time, even if you agreed to receive it electronically.

Choose someone to act on your behalf. If you have a personal representative — such as someone with medical power of attorney or a court-appointed guardian — that person may exercise your rights and make decisions about your health information once we verify their authority. Special rules apply to a minor's own consent-based records; see Section 5.

File a complaint if you believe your rights have been violated. You may file a complaint with our Privacy Officer using the contact information above, or with the U.S. Department of Health and Human Services Office for Civil Rights by mail (200 Independence Avenue, S.W., Washington, D.C. 20201), phone (1-877-696-6775), or online at www.hhs.gov/hipaa/filing-a-complaint/index.html. Complaints involving substance use disorder records protected by 42 CFR Part 2 may also be filed with the Office for Civil Rights, which has enforcement authority over Part 2. We will not retaliate against you in any way for filing a complaint.

3. Your Choices

For certain health information, you may tell us your preference for how we share it. Where you have a clear preference, we will follow your instruction. Mental health records receive heightened confidentiality protection under Ohio law (Ohio Rev. Code § 5122.31), and we apply your instructions strictly with respect to those records.

Family and friends. You may direct us to share information with family members, close friends, or others involved in your care or payment for care. If you are unable to state a preference (for example, in an emergency), we may share information if we believe it is in your best interest, or to lessen a serious and imminent threat to health or safety.

Disaster relief. You may tell us whether to include your information in disaster relief efforts.

Fundraising. We may contact you about fundraising efforts, but you may opt out of future contact at any time. If your records are protected under 42 CFR Part 2, we will provide clear advance notice and obtain your choice before using your information for fundraising.

We will never use or share the following without your explicit written authorization, which you may revoke in writing at any time (except to the extent we have already acted on it):

Marketing purposes, or the sale of your information.

Psychotherapy notes. Psychotherapy notes are the personal notes of a mental health professional analyzing a conversation during a counseling session, kept separate from the rest of your clinical record (which contains diagnoses, treatment plans, progress notes, and billing information). Most uses and disclosures of psychotherapy notes require your written authorization.

Substance use disorder records (42 CFR Part 2). We will not use or disclose records of the identity, diagnosis, prognosis, or treatment of a substance use disorder maintained in connection with a Part 2 program for marketing purposes, and we will not sell such records, without your written consent.

4. Our Uses and Disclosures

We typically use and share your health information, including SUD and mental health information where permitted, in the following ways. Where 42 CFR Part 2 or Ohio Rev. Code § 5122.31 impose stricter rules, we follow the stricter rule.

To treat you. We may use and share your health information with other professionals who are treating you. Example: a clinician coordinates your care with a prescribing psychiatrist within our organization or an outside provider.

To run our organization. We may use and share your health information to operate our practice, support quality improvement, train staff, and manage our business.

To bill for our services. We may use and share your health information to bill and receive payment from health plans or other payers. Example: we submit billing information to your health insurer to obtain payment for services provided to you.

Beginning with the compliance date of the 2024 revisions to 42 CFR Part 2 (February 16, 2026), federal law permits us to ask you to sign a single, unified consent authorizing future uses and disclosures of your substance use disorder records for treatment, payment, and health care operations, similar to a standard HIPAA authorization. You decide whether to sign that consent, you may limit its scope, and you may revoke it in writing at any time. Absent your consent (or another exception permitted by law), we will not use or disclose records that identify you as having or having had a substance use disorder.

5. Special Protections for Behavioral Health, Substance Use Disorder, and Ohio Law

Because we provide behavioral health and substance use disorder services, your records receive protections beyond standard HIPAA rules:

42 CFR Part 2 — Substance Use Disorder Records

Records we maintain that document the diagnosis, treatment, or referral for treatment of a substance use disorder are protected under federal Part 2 regulations, as revised April 16, 2024, to align more closely with HIPAA while preserving Part 2's core protections. Under Part 2:

We may obtain a single consent from you authorizing future uses and disclosures of your SUD records for treatment, payment, and health care operations, rather than a separate consent for each disclosure.

A recipient of your Part 2 records who is a HIPAA-covered entity or business associate may redisclose the information only as permitted by HIPAA and consistent with the consent you provided.

Your SUD records may not be used or disclosed in a civil, criminal, administrative, or legislative proceeding against you unless you provide written consent, or a court issues a specialized order after notice and an opportunity for you (or the record holder) to be heard, together with a subpoena. A general authorization or an ordinary subpoena is not sufficient.

You may revoke your consent in writing at any time, except to the extent we have already relied on it.

Violations of Part 2 may be investigated and penalized by the HHS Office for Civil Rights, which now has explicit enforcement authority and may impose civil monetary penalties, consistent with HIPAA enforcement.

As required by federal law: 42 CFR Part 2 prohibits unauthorized use or disclosure of your substance use disorder records. Federal law and regulations protect the confidentiality of substance use disorder records maintained by this program. Information disclosed without your consent may not be used to initiate or substantiate any criminal charges against you, or to conduct a criminal investigation of you, except as authorized by a court order.

Ohio Mental Health Confidentiality — Ohio Rev. Code § 5122.31

Under Ohio law, all clinical records, certificates, and information identifying a current or former mental health patient are strictly confidential. We limit disclosure of mental health records without your explicit consent, subject only to the specific exceptions set out in Ohio law (for example, continuity of care between treating providers, or statutorily authorized oversight). For substance use disorder records, if your file contains records from other providers, we will re-disclose those other providers’ records only if your written authorization expressly authorizes both disclosure of our records and re-disclosure of the other providers’ records.

Ohio Minor Consent Laws

In Ohio, a minor age 14 or older may independently consent to a limited course of outpatient mental health evaluation or treatment, and a minor of any age may independently consent to substance use disorder treatment. Where a minor has consented to their own care under these provisions, the privacy rights associated with that specific treatment belong to the minor, and we will not share those records with a parent or guardian without the minor's authorization, except as otherwise required or permitted by law.

Ohio HIV/AIDS Confidentiality

Information regarding HIV testing, HIV status, or an AIDS diagnosis is subject to heightened confidentiality under Ohio law. We will not disclose HIV or AIDS-related information without your specific, separate written authorization, unless disclosure is required under Ohio public health reporting laws.

6. Other Permitted or Required Disclosures

Subject to the limitations described in Section 5, we are permitted or required by law to share your information in the following circumstances without your written authorization:

Public health and safety. To help prevent disease, report reactions to medications, support product recalls, report suspected child abuse, elder abuse, neglect, or domestic violence as required under Ohio mandatory-reporting law, and to prevent or reduce a serious and imminent threat to someone's health or safety.

Health oversight and research. To support health oversight activities authorized by law, or to conduct health research under an applicable regulatory exception.

Law enforcement and legal proceedings. In response to a valid court order and, where SUD or mental health records under Part 2 or Ohio Rev. Code § 5122.31 are involved, only to the extent those laws' stricter requirements are also satisfied.

To comply with the law. We will share information about you when required by state or federal law.

7. Our Responsibilities

We are required by law to maintain the privacy and security of your protected health information.

We will let you know promptly if a breach occurs that may have compromised 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 will not use or share your information other than as described here unless you tell us, in writing, that we may do so. If you give us written permission, you may revoke it in writing at any time, except to the extent we have already relied on it.

8. Breach Notification

We are required by law to maintain the privacy and security of your protected health information. If a breach of your unsecured protected health information occurs, including an unauthorized use or disclosure of information protected by HIPAA or 42 CFR Part 2, we will notify you without unreasonable delay and in no case later than 60 days after discovery, as required by the HITECH Act and applicable Part 2 breach-notification requirements.

9. Changes to the Terms of This Notice

We may change the terms of this Notice at any time, and any changes will apply to all information we already have about you, as well as information we receive in the future. We will post the current Notice in our office and on our website, and you may request a copy at any time using the contact information in Section 1.

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