Emergency? Need Help Now? (802) 229-0591

Emergency? Need Help Now? (802) 229-0591

Notice of Privacy Practices & Social Media Policy

                                                                                       Effective date: April 1, 2016


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 our Privacy Officer at (802) 229-1399



This notice describes our practices and that of:


We understand that health information about you and your health is personal.  We are committed to protecting your privacy and health information about you.  We create a record of the care and services you receive at the Agency.  We need this record to provide you with quality care and to comply with certain legal requirements.  This notice applies to all of the records of your care generated by the Agency, whether made by Agency personnel or your personal doctor.  Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your health information created in the doctor’s office or clinic.

This notice will tell you about the ways in which we may use and disclose health information about you.  We also describe your rights and certain obligations we have regarding the use and disclosure of health information.

We are required by law to:



The following categories describe different ways that we use and disclose health information. 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.

For Treatment.  We may use or disclose health information about you to provide you with treatment or services.  This includes the potential sharing of information about you to doctors, nurses, clinicians, case managers, interns or other Agency personnel, or to people outside of the Agency who are involved in your care.  For example, a clinician might be treating you for a mental health problem and need to talk with one of our psychiatrists, another clinician, who has specialized training in a particular area of care.  We may also disclose information about you to people outside the Agency who are involved in your health care.

Electronic Exchange of Your Health Information-In some instances, we may transfer health information about you electronically to other health care providers who are providing you treatment or to the insurance plan providing payment for your treatment. Your health information may also be made available through the Vermont Health Information Exchange (“VHIE”). The VHIE is a health information network operated by VITL, Inc. and your treating health care providers may only access your health information through the VHIE if you have provided specific written consent for their access, unless you are in need of emergency treatment. For information about the VHIE, see www.vitl.net.” 

For Payment.  We may use and disclose health information about you so that the treatment and services you receive at the Agency may be approved by, billed to, and payment collected from a third party such as an insurance company.  For example, we may need to give your health plan information about counseling you received at the Agency so your health plan will pay us or reimburse you for a counseling session.  We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the service / treatment.

For Health Care Operations.  We may use and disclose health information about you for Agency operations.  These uses and disclosures are necessary to run the Agency and make sure that all individuals receiving services from us receive quality care.  For example, we may use health information to review our treatment and services and to evaluate the performance of our staff in serving you.  We may also combine health information about many consumers to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective.  We may also disclose information to doctors, nurses, clinicians, case managers, interns and other Agency personnel for review and learning purposes. 

We may also combine the health information we have with health information from other mental health agencies to compare how we are doing and see where we can make improvements in the services we offer.  We will remove information that identifies you from this set of health information so others may use it to study health care and health care delivery without learning who the specific consumers are.

Washington County Mental Health Services, Inc. is a Vermont designated Community Mental Health Agency and is obligated under our contracts with various departments within the Vermont Agency of Human Services to provide certain services.  As a result, these Departments may access health information related to these contracted services for the purpose of obtaining treatment for clients, making payment or for its health care operations.  Washington County Mental Health Services, Inc. contracts and participates in one or more Accountable Care Organization (ACO) which assists it in evaluating and coordinating care to patients.

Appointment Reminders.  We may use and disclose information to contact you as a reminder that you have an appointment.

Alternative Treatment and Benefits and Services.  We may use and disclose information about you in order to obtain and recommend to you other treatment options and available services as well as other health-related benefits or services.

Fundraising Activities.  Should the need arise where information about you or where your participation is desired for the Agency’s fundraising activities, the Agency would obtain your authorization.  No information would be released for this purpose without your authorization

Research.  Under extremely limited circumstances, we may use and disclose health information for research purposes.  For example, a research project may involve comparing the health and recovery of all consumers who received one medication to those who received another, for the same condition.  All research projects are subject to a special approval process.  This process evaluates a proposed research project and its use of health information, trying to balance the research needs with consumer’s need for privacy of their health information.  Before we use or disclose health information for research, the project will have been approved through this research approval process.  We may, however, disclose health information about you to people preparing to conduct a research project; for example, to help them look for consumers with specific health needs, so long as the health information they review does not leave the Agency.  We will always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care at the Agency.

As Required by Law.  We will disclose medical information about you when required to do so by federal, state or local law.  In Vermont, this would include: victims of child abuse; the abuse, neglect or exploitation of vulnerable adults; or where a child under the age of sixteen is a victim of a crime; and firearm-related injuries.  Under certain circumstances, the Departments within the Vermont Agency of Human Services who we contract with are mandated to access health information in order to carry out their responsibilities.

To Avert a Serious and Imminent Threat to Health or Safety.  We may use and disclose health information about you when necessary to prevent a serious and imminent 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 health information about you as required by military command authorities.

Workers’ Compensation.  We may release health information about you as authorized for workers’ compensation or similar programs as authorized by Vermont law.  These programs provide benefits for work-related injuries or illnesses.

Public Health Risks.  We may disclose health information about you for public health activities.  These activities generally include the following:

Health Oversight Activities.  We may disclose health information to a health oversight agency, such as the Vermont Agency of Human Services Departments who we contract with, for activities authorized by law.  These oversight activities include, but are not limited to, 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.

Legal Proceedings and Disputes.  If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order.

Public Health Officials and Funeral Home Directors.  We may release information to a coroner or medical examiner.  This may be necessary, for example, to identify a deceased person or determine the cause of death.  We may also release health information to funeral directors thereby permitting them to carry out their duties.

Individuals in Custody.  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release health information about you to the correctional institution or law enforcement official pertaining to care provided while you are in custody.  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.



Other uses and disclosures of health information not covered by this notice or the laws that apply to us will be made only with your written authorization.  Examples of this may include disclosures to lawyers, employers, the Vermont Office of Disability Determination Services or others who you know, but whoare not involved in your care.  Additionally, uses and disclosures of protected health information for our fundraising activities, marketing purposes, and disclosures that constitute a sale of protected health information require authorization. Also, Psychotherapy notes maintained by your treating provider can only be disclosed with your written authorization.  If you provide us permission to use or disclose health information about you, you may revoke that permission, in writing, at any time.  If you revoke your permission, we will no longer use or disclose health information about you for the reasons covered by your written authorization.  You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the services that we provided to you.

Community Health Teams / Community Care Collaboratives: These teams were created under the Vermont Blueprint for Health and are designed to create alliances between healthcare providers, local and state agencies and community support organizations who are committed to improving quality of life through coordination of services.  These services may be financial, physical, emotional or educational in nature.   Your treating health care providers may only share your health information with a CHT / CCC if you have provided specific written consent for sharing.  



Any assistance (physical, communicative, etc.) you need to exercise your rights will be provided to you by the Agency.

You have the following rights regarding information we maintain about you:

Right to Review and Copy.  You have the right to review and copy health information that may be used to make decisions about your care.  This may include both health and billing records.

To review and copy health information that may be used to make decisions about you, you must submit your request in writing to our Records Department.  If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request.  If you seek an electronic copy in a specific form or format of any portion of your electronic health record, and the Agency is unable to readily produce the copy in that form or format, we will work with you to provide an alternative form or format for the electronic copy.

We may deny or limit access to your request to inspect and copy in certain very limited circumstances.  If you are denied or limited access to health information, you may request that the decision be reviewed.  Another health care professional chosen by the Agency will review your request and the denial.  The person conducting the review will not be the person who denied your request.  We will comply with the outcome of the review.

Right to Amend.  If you feel that health information 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 or for the Agency.

To request an amendment, your request must be made in writing and submitted to our Records Department.  In addition, you must provide a reason that supports your request.

We may deny your request for an amendment if it is not in writing or does not include a reason to support that request.  In addition, we may deny your request if you ask us to amend information that:

Right to an Accounting of Disclosures.  You have the right to request an “accounting of disclosures.”  This is a list of the disclosures we made of health information about you which were required by law and/or were not authorized by you.

To request this list or accounting of disclosures, you must submit your request in writing to our Records Department.  Your request must state a time period, which may not be longer than six years.  Your request should indicate in what form you want the list (for example, on paper, electronically).  The first list you request within a 12-month period will be free.  For additional lists, we may charge you for the costs of providing the list.  We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions.  You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment or health care operations.   We are not required to agree to your request unless your request is to limit disclosures to a health plan for the purpose of carrying out payment or health care operations that are not otherwise required by law and you or someone on your behalf other than your health plan has paid for those services in full at the time the health services are provided.  However, if we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.

You also have the right to request a limit on the health information we disclose about you to someone who is involved in your care or the payment for your care, like a family member.  For example, you could ask that we not use or disclose information about a counseling session you received.

To request restrictions, you must make your request in writing to our Records Department.  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, for example, disclosures to your spouse.

Right to Request Confidential Communications.  You have the right to request that we communicate with you about health 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.  To request confidential communications, you must make your request in writing to our Records Department.  We will not ask you the reason for your request.  We will accommodate all reasonable requests.  Your request must specify how or where you wish to be contacted.

Right to a Paper Copy of This Notice.  You have the right to a paper copy of this notice.  You may ask us to give you a copy of the current notice at any time.   To obtain a paper copy of this notice, contact the Agency Privacy Officer at (802) 229-1399.

Security of Health Information.  

We have in place appropriate safeguards to protect and secure the confidentiality of your health information.  Due to the nature of community based human service practices, Agency representatives may possess your health information outside of the Agency.  In these cases, Agency representatives will ensure the security and confidentiality of the information in a manner that meets Agency policy, State and Federal Law.

Specific requirements for electronic notice: A covered entity that maintains a web site that provides information about the covered entity’s customer services or benefits must prominently post its notice on the web site and make the notice available electronically through the web site. 



We reserve the right to change this notice.  We reserve the right to make the revised or changed notice effective for health information we already have about you as well as any information we receive in the future.  We will post a copy of the current notice in all Agency facilities.  The notice will contain an effective date.  Should we make a material change to this notice, we will, prior to the change taking effect, publish an announcement of the change at every Agency facility.



If you believe your privacy rights have been violated, you may file a complaint with the Agency or with the Secretary of the Department of Health and Human Services.  To file a complaint with the Agency, call (802) 229-1399 and ask to speak with our Privacy Officer.  All complaints must be submitted in writing.  Complaint forms are available at each location including the reception area at the Agency’s main office.  You will not be penalized for filing a complaint.

The Secretary of the Department of Health and Human Services can be contacted through their regional office at Office of Civil Rights, U.S. Department of Health and Human Services, Government Center, J.F. Kennedy Federal Building – Room 1875, Boston, Massachusetts 02203, voice phone (800) 368 1019, fax (617) 565-3809, TDD (800) 537 7697.




We welcome and encourage open discussion on Washington County Mental Health’s social media sites – including but not limited to our Twitter, Facebook, LinkedIn and YouTube pages  – and look forward to any comments, stories and experiences you want to share.

We make reasonable efforts to monitor participation to ensure that comments are respectful.  We will remove offensive comments, and will make an attempt to reach out to you privately in an attempt to have a conversation about any issue you may have with a post, a WCMHS staff, or our agency generally. Please remember that information posted on any of our social media platforms shouldn’t be considered clinical or medical advice and shouldn’t replace a consultation with a health care professional.

Please remember that once you post something online, there’s the potential for anyone to read your words, even years from now. Therefore, we suggest that you take a moment to consider adding a comment when posting personal information or other comments on any of our social media sites and that you not disclose personal identifiable information like your location, medical or treatment history or status, financial information, etc.

That’s the plain English version. Here it is in legal language:

BY POSTING ON THE WASHINGTON COUNTY MENTAL HEALTH SOCIAL MEDIA SITE YOU AGREE TO THESE TERMS. Washington County Mental Health (WCMHS) has opened publicly facing pages on social media sites for viewing content and/or videos and posting comments about WCMHS. These social media sites include but are not limited to various blogs, bulletin boards, networks, multi-media and news media sites or other user generated content sites (“Social Media Sites”). By accessing, viewing and/or posting any content related directly or indirectly to WCMHS on any Social Media Site on the internet, you accept, without limitation or qualification, the following terms of use. If you do not agree to the terms of this Policy, you may not view or post any content to any Social Media Site on the internet. Your use of Social Media Sites is acceptance of this Policy and has the same effect as if you had actually physically signed an agreement.

  1. If you are a WCMHS employee you must adhere to the WCMHS SOCIAL MEDIA POLICY.
  2. You must be at least 18 years old to post any content on any Social Media Site.
  3. You are prohibited from posting any content that is personal health information including client images on any Social Media Site. You are also prohibited from using the Social Media Site to provide clinical advice or commentary by non-WCMHS providers or to use the Social Media Site to make, recommend or increase referrals to providers who are not employed by WCMHS.
  4. As a guest posting content to any Social Media Site on the internet, you agree that you will not: violate any local, state, federal and international laws and regulations, including but not limited to copyright and intellectual property rights laws regarding any content that you send or receive via this Policy; transmit any material (by uploading, posting, email or otherwise) that is unlawful, disruptive, threatening, profane, abusive, harassing, embarrassing, tortuous, defamatory, obscene, libelous, or is an invasion of another’s privacy, is hateful or racially, ethnically or otherwise objectionable as solely determined in WCMHS’s discretion; impersonate any person or entity or falsely state or otherwise misrepresent your affiliation with a person or entity; transmit any material (by uploading, posting, email or otherwise) that you do not have a right to make available under any law or under contractual or fiduciary relationships; transmit any material (by uploading, posting, email or otherwise) that infringes any patent, trademark, trade secret, copyright or other proprietary rights of any party; transmit (by uploading, posting, email or otherwise) any unsolicited or unauthorized advertising (including advertising of non WCMHS services or products), promotional materials, “junk mail,” “spam,” “chain letters,” “pyramid schemes” or any other form of solicitation; transmit any material (by uploading, posting, email or otherwise) that contains software viruses, worms, disabling code, or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment; harass another; or collect or store, or attempt to collect or store, personal data about third parties without their knowledge or consent; or to share confidential pricing information of any party.
  5. WCMHS reserves the right to monitor, prohibit, restrict, block, suspend, terminate, delete, or discontinue your access to any Social Media Site, at any time, without notice and for any reason and in its sole discretion. WCMHS may remove, delete, block, filter or restrict by any other means any materials in WCMHS’s sole discretion. You understand and agree that WCMHS may disclose your communications and activities with WCMHS in response to lawful requests by governmental authorities, including Patriot Act requests, judicial orders, warrants or subpoenas, or for the protection of WCMHS rights. You agree that in the event that WCMHS exercises any of its rights hereunder for any reason, WCMHS will have no liability to you.
  6. By posting any content on any Social Media Site, you grant to WCMHS the irrevocable right to reproduce, distribute, publish, display such content and the right to create derivative works from your content, edit or modify such content and use such content for any WCMHS purpose.
  7. You shall defend, indemnify, and hold WCMHS and its corporate affiliates and their respective officers, directors, employees, contractors, agents, successors and assigns harmless from and against, and shall promptly reimburse them for, any and all losses, claims, damages, settlements, costs, and liabilities of any nature whatsoever (including reasonable attorneys’ fees) to which any of them may become subject arising out of, based upon, as a result of, or in any way connected with, your posting of any content to a Social Media Site, any third party claims of infringement or any breach of this Policy.
  8. YOU EXPRESSLY ACKNOWLEDGE THAT YOU ASSUME ALL RESPONSIBILITY RELATED TO THE SECURITY, PRIVACY, AND CONFIDENTIALITY RISKS INHERENT IN SENDING ANY CONTENT OVER THE INTERNET. By its very nature, a website AND THE INTERNET cannot be absolutely protected against intentional or malicious intrusion attempts. WCMHS does not control the THIRD PARTY SITES AND THE Internet over which you may choose to send confidential personal or health information OR OTHER CONTENT and, therefore, WCMHS DOES NOT WARRANT ANY SAFEGUARD AGAINST ANY such interceptions or compromises to your information. When posting any content on an internet site, you should think carefully about your own privacy in disclosing detailed or private information about yourself and your family. FURTHERMORE, WCMHS DOES NOT ENDORSE ANY PRODUCT, SERVICE, VIEWS OR CONTENT DISPLAYED ON THE SOCIAL MEDIA SITE.
  9. You agree that any claim or dispute relating to your posting of any content on a Social Media Site on the internet shall be construed in accordance with the laws of the State of Vermont without regard to its conflict of law’s provisions and you agree to be bound and shall be subject to the exclusive jurisdiction of the local, state or federal courts located in Washington County, Vermont.
  10. You may not provide any content to a Social Media Site that contains any product or service endorsements or any content that may be construed as political lobbying, solicitations or contributions or use the Social Media Site to link to any sites or political candidates or parties or use the Social Media Site to discuss political campaigns, issues or for taking a position on any legislation or law.
  11. THIS POLICY MAY BE UPDATED AT ANY TIME WITHOUT NOTICE, AND EACH TIME A USER ACCESSES A SOCIAL NETWORKING SITE, THE NEW POLICY WILL GOVERN, USAGE, EFFECTIVE UPON POSTING. To remain in compliance, WCMHS suggests that you review the Policy, as well as the other website policies, at regular intervals. By continuing to post any content after such new terms are posted, you accept and agree to any and all such modifications to this Policy.

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