Policies and Procedures

It’s my goal to provide psychological services that meet the highest ethical, legal, and professional standards. As part of providing you with the best possible care, I want to ensure that you are fully informed about my policies and procedures and that all of your questions or concerns have been answered to your satisfaction. Please click on the following links for information about specific policies and procedures. If you have any questions, please call me at (254) 751-1550.

Texas HIPAA Privacy Notice
NOTICE OF PSYCHOLOGISTS’ POLICIES AND PRACTICES TO PROTECT THE PRIVACY OF YOUR HEALTH INFORMATION

This notice describes how psychological and medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Uses and Disclosures for Treatment, Payment, and Health Care Operations
Waco Psychological Associates (WPA) may use or disclose your protected health information (PHI) for treatment, payment, and health care operations purposes with your consent. To help clarify these terms, here are some definitions. PHI refers to information in your health record that could identify you. Treatment is when WPA provides, coordinates, or manages your health care and other services related to your health care. An example of treatment would be when WPA consults with another health care provider, such as your family physician or another psychologist. Payment is when WPA obtains reimbursement for your healthcare. Examples of payment are when WPA discloses your PHI to your health insurer to obtain reimbursement for your health care or to determine eligibility or coverage. Health care operations are activities that are related to the performance and operation of WPA practice. Examples of health care operations are quality assessment and improvements activities, business-related matters such as audits and administrative services, and case management and care coordination. Use applies only to activities within WPA (office, clinic, practice group, etc.), such as sharing, employing, applying, utilizing, examining, and analyzing information that identifies you. Disclosure applies to activities outside of WPA (office, clinic, practice group, etc.), such as releasing transferring, or providing access to information about you to other parties.

Uses and Disclosures Requiring Authorization
WPA may use or disclose PHI for purposes outside of treatment, payment, and health care operations when your appropriate authorization is obtained. An authorization is written permission above and beyond the general consent that permits only specific disclosures. In those instances when WPA is asked for information for purposes outside of treatment, payment, and health care operations, WPA will obtain an authorization from you before releasing this information. WPA will also need to obtain an authorization before releasing your psychotherapy notes. “Psychotherapy notes” are notes WPA have made about our conversation during a private, group, joint, or family counseling session, which WPA have kept separate from the rest of your medical record. These notes are given a greater degree of protection than PHI. You may revoke all such authorizations (of PHI or psychotherapy notes) at any time, provided each revocation is in writing. You may not revoke an authorization to the extent that WPA the authorization was obtained as a condition of obtaining insurance coverage, and the law provides the insurer the right to contest the claim under the policy.

Uses and Disclosures with Neither Consent nor Authorization
WPA may use or disclose PHI without your consent or authorization in the following circumstances:

Child Abuse: If WPA has cause to believe that a child has been, or may be, abused, neglected, or sexually abuse, WPA must make a report of such within 48 hours to the Texas Department of Protective and Regulatory Services, the Texas Youth Commission, or to any local or state law enforcement agency.

Adult and Domestic Abuse: If WPA has cause to believe that an elderly or disabled person in a state of abuse, neglect, or exploitation, WPA must immediately report such to the Department of Protective and Regulatory Services.

Health Oversight: If a complaint is filed against WPA with the Texas State Board of Examiners of Psychologist, they have the authority to subpoena confidential mental health information from me relevant to that complaint.

Judicial or Administrative Proceedings: If you are involved in a court proceeding and a request is made for information about your diagnosis, and treatment and the records thereof, such information is privileged under state law, and WPA will not release information, without written authorization from you or your personal or legally appointed representative, or a court order. You will be informed in advance if this is the case.

Serious Threat to Health or Safety: If WPA determines that there is a probability of imminent physical injury by you to yourself or others, or there is a probability of immediate mental or emotional injury to you, WPA may disclose relevant confidential mental health information to medical or law enforcement personnel.

Patient’s Rights and Psychologist’s Duties

Patient’s Rights

Right to request Restrictions: You have to the right to request restrictions on certain uses and disclosures of protected health information about you. However, WPA is not required to agree to a restriction you request.

Right to Receive Confidential Communications by Alternative Means and Alternative Locations: You have the right to request and receive confidential communications of PHI by alternative means and at alternative locations. (For example, you may not want a family member to know that you are seeing someone at WPA, and upon request WPA will send your bills to another address)

Right to Impact and Copy: You have the right to inspect or obtain a copy (or both) of PHI and psychotherapy notes in WPA mental health and billing records used to make decisions about you for as long as the PHI is maintained in the record. WPA may deny your access to PHI under certain circumstances, but in some cases you may have this decision reviewed. On your request, WPA will discuss with you the details of the request and denial process.

Right to an Amend: You have the right to request an amendment of PHI for as long as the PHI is maintained in the record. WPA may deny your request. On your request, WPA will discuss with you the details of the amendment process.

Right to an Accounting: You generally have the right to receive an accounting of disclosures of PHI for which you have neither provided consent nor authorization (as described in Section 3 of this Notice). On your request, I will discuss with you the details of the accounting process.

Right to a Paper Copy: You have the right to obtain a paper copy of the notice from WPA upon request, even if you have agreed to receive the notice electronically.

Psychologist’s Duties

WPA Privacy Officer is Roderick Hetzel, Ph.D.

WPA is required by law to maintain the privacy of PHI and to provide you with a notice of WPA legal duties and privacy practices with respect to PHI.

WPA reserves the right to change the privacy policies and practices described in this notice. Unless WPA notifies you of such changes, however, WPA is required to abide by the terms currently in effect. If WPA revises policies and procedures, WPA will provide you written notification by mail.

Questions or Complaints
If you have questions about this notice, disagree with a decision I make about access to your records, or have other concerns about your privacy rights, you may contact Rod Hetzel, PhD at (254) 751-1550. If you believe that your privacy rights have been violated and wish to file a complaint with my office, you may send your written complaint to Rod Hetzel, PhD at Waco Psychological Associates, 8401 Old McGregor Rd, Waco, TX 76712. You may also file a complaint to the Texas State Board of Examiners of Psychologists or the U.S. Department of Health and Human Services. I can provide you with the appropriate address upon request. You have specific rights under the Privacy Rule. I will not retaliate against you for exercising
your right to file a complaint.

Confidentiality
Your privacy and confidentiality are very important to me. All of your information (including the fact that you are my patient, your diagnosis, what we discuss in session, etc.) will be protected according to the highest legal and ethical standards. I will not release information about you to anyone without your written consent.

You should know, however, that there are some legal limitations to confidentiality. According to Chapter 611 of the Texas Health and Safety Code and Chapter 261 of the Texas Family Code, I may be legally required to disclose confidential information without your consent in the following circumstances:

  • If I determine that there is a probability of imminent physical injury by you to yourself or others, or if there is a possibility of imminent mental or emotional injury to you, I may disclose relevant confidential information to appropriate authorities
  • If I have cause to believe that a child has been, or may be, abused or neglected, I must make a report of such to appropriate authorities.
  • If I have cause to believe that an elderly or disabled person has been, or may be, abused or neglected, I must make a report of such to appropriate authorities.
  • If you are involved in a court proceeding and a request is made for information about your diagnosis and treatment, such information is privileged under state law and will not be released without written consent from you or your legally-appointed representative, or a court order. You will be informed in advance if this is the case.
  • If a complaint is filed with the Texas State Board of Examiners of Psychologists, they have the authority to subpoena confidential information from me relevant to that complaint.

It is noteworthy that the parent or legal guardian of a minor is responsible for acting in the best interest of the minor with regarding to releasing confidential information. The Texas Health and Safety Code specifies a few other judicial proceedings and situations in which confidential information can or must be released. Also, relevant information about you also may be released to your insurance company if you ask us to file on your behalf.

During your first session, we will review your rights to confidentiality as well as the limitations to confidentiality. I want to ensure that any questions or concerns you have about this important topic are addressed to your satisfaction. If you have additional questions or concerns about confidentiality during the course of therapy, I hope you will discuss them with me. This is an important part of your ongoing consent to treatment, and I will always be willing to talk with you about it.

We also will discuss the details of maintaining your confidentiality in a small town like Waco. If we see each other outside of session, I generally will not acknowledge you unless you first acknowledge me. You are welcome to acknowledge me or not. If you choose to not acknowledge me, my feelings will not be hurt and it will not negatively impact your treatment in any way. If anyone asks to talk with me about you, I will not acknowledge that we have a professional relationship without first obtaining your written consent.

Please know that you are free to talk with others about your treatment if you so desire. Although you are not legally required to maintain confidentiality, I ask you to respect the privacy and confidentiality of other patients you see in my office. The use of cameras or recording devices, including those found on cell phones, is prohibited in or around the facility.

Insurance Coverage
As a courtesy to you, my office is happy to contact your insurance company to confirm your insurance coverage for mental health services. Please note that we are only conveying to you the information we are given by your insurance company. We strongly encourage you to call your insurance company directly to verify actual coverage, because you will be responsible for payment in the event of a discrepancy.

My office will automatically file all charges on your behalf with up to two insurance companies with whom you have coverage. Your insurance benefits will be paid according to your individual policy limitations.

Insurance is a contract between you and your insurance company. In most cases, we are not a party to this contract. We will inform you if we have a contract with your insurance company, and your claims will be handled according to the agreement. We are happy to file insurance claims as a courtesy to you, but will not be able to become involved in disputes between you and your insurance company other than to supply factual information as needed.

You are ultimately responsible for the timely payment on your account. We ask that you pay the co-payment at the time of each session. If you have any questions about your insurance coverage or account, please contact my business office. We are here to assist you in any way that we can!

Communication and Social Media

The most efficient and private way to contact me is (254) 751-1550. I will reply to your phone message in a timely manner. My practice does not have an after-hours emergency service, so if you think you may be experiencing a medical or psychological emergency, you should immediately call 911 or visit your local emergency room.

Website Contact Form and Email
My preference is for you to contact me by phone, but you are welcome to use my website contact form and/or email for administrative issues (such as changing appointment times). If you use my website contact form, an email will be generated and sent to me. Email may not be checked regularly, and therefore should not be used for issues that require a timely response. You should not use email to send personal content related to your treatment. All emails that I receive from you, and all emails that I send to you, will be printed out by me and, if applicable, scanned into your medical record.

I use ProtonMail as my email service provider. ProtonMail is a secure service that stores email on encrypted servers, transmits emails in encrypted format between ProtonMail servers and user devices, and offers an option for end-to-end encryption for those who use an email provider other than ProtonMail (such as Gmail, Yahoo, etc.).

If you want end-to-end email encryption and do not have your own ProtonMail account, you will need to request a passcode from me. Once I activate end-to-end encryption, all email that I send to you will contain a link which loads the encrypted message onto your browser, which you then can decrypt using the passcode.

For added security, email sent through ProtonMail will expire after a predetermined time set by me (the default is 1 week), at which point it will automatically and permanently be deleted from your inbox. Once an email has expired, you will not be able to retrieve it. If you desire to save an email, you will need to copy and paste the content before it expires.

I have chosen ProtonMail as my email service provider to protect your privacy and minimize the risk of email interception. Even with these precautions, you should know that your privacy and confidentiality cannot be guaranteed when you use email. Email may be stored in the logs of email and internet service providers or devices that transmit and receive the email, and may be vulnerable to interference by unauthorized persons.

For more information about ProtonMail’s security, please visit their website.

Social Media
I maintain professional social media accounts and a blog through my website. I use these services to post information about my practice as well as news and information about psychology, psychotherapy, mental health, and healthy relationships.

You are welcome to read the content I post on my professional social media accounts if it is of interest to you. Please know that I do not expect you to read my content and will never request that you interact with me on any social media platform.

You also should know that interactions on social media platforms are neither confidential nor secure. You may compromise your privacy by commenting on posts, making @replies, or otherwise interacting with me on social media platforms. It could create the possibility that these interactions would need to be documented and maintained in your chart, thus becoming part of your medical record. Additionally, I may not see, check, or read social media messages in a timely fashion.

Do not use any social media platform to send messages to me or to interact with me outside of session. As mentioned above, if you need to contact me between sessions, the best way to do so is by phone.

Friending or Connecting
I do not accept friend or connection requests from current patients. Adding current patients as friends or connections can compromise confidentiality and blur the boundaries of our professional relationship. If you have questions about this, please feel free to ask me during session where we can discuss them together.

Liking
You are welcome to use your own discretion in choosing whether to Like content I post on my professional social media accounts. I do not post anything that I would not want you to see. However, you should know that other people may be able to see that you have Liked my content, and may conclude that you are my patient.

If you choose to Like my content, please know that I will not respond to you on social media. If there are details you wish to share with me from your online life, I encourage you to share them with me during our sessions where we can discuss them together.

Following or Subscribing
You are welcome to use your own discretion in choosing whether to follow or subscribe to my professional social media accounts. I do not post anything that I would not want you to see. However, you should know that other people may be able to see that you have followed or subscribed to my account, and may conclude that you are my patient.

If you choose to follow or subscribe to my professional social media accounts, please know that I will not follow or subscribe to your accounts. I do not follow current patients on any social media platform. If there are details you wish to share with me from your online life, I strongly encourage you to share them with me during our sessions where we can discuss them together.

Use of Search Engines
It is not a regular part of my practice to search for patients on search engines or view your profile on social media platforms. Exceptions to this may be made during times of crisis, such as imminent risk of harm to yourself or others. These are extremely rare situations. If I ever resort to such means, I will discuss this with you during our next session.

Location-Based Services
If you used location-based services (LBS) on your mobile device, you may wish to be aware of the privacy issues related to using these services. I do not place my practice as a check-in location on various sites such as Foursquare, Gowalla, Loopt, etc. However, if you have GPS tracking enabled on your device, it is possible that others may conclude that you are my patient due to regular check-ins at my office. Please be aware of this risk if you are intentionally “checking in” from my office or if you have a passive LBS app enabled on your phone.

Business Review Sites
You may find my psychology practice on business review sites. Some of these sites include forums in which users rate their providers and add reviews. Many of these sites comb search engines for business listings and automatically add listings regardless of whether the business has added itself to the site. If you should find my listing on any of these sites, please know that my listing is not a request for a testimonial, rating, or endorsement from you as my patient. The American Psychological Association’s Ethics Code states under Principle 5.05 that it is unethical for psychologists to solicit testimonials: “Psychologists do not solicit testimonials from current therapy clients/patients or other persons who because of their particular circumstances are vulnerable to undue influence.” Of course, you have a right to express yourself on any site you wish. But due to confidentiality, I cannot respond to any review on any of these sites whether it is positive or negative. I urge you to take your own privacy as seriously as I take my commitment of confidentiality to you. You should also be aware that if you are using these sites to communicate indirectly with me about your feelings about our work, there is a good possibility that I may never see it.

If we are working together, I hope that you will bring your feelings and reactions to our work directly into the therapy process. This can be an important part of therapy, even if you decide we are not a good fit. None of this is meant to keep you from sharing that you are in therapy with me wherever and with whomever you like. Confidentiality means that I cannot tell people that you are my client and my ethics code prohibits me from requesting testimonials. But you are more than welcome to tell anyone you wish that I’m your therapist or how you feel about the treatment I provided to you, in any forum of your choosing.

If you do choose to write something on a business review site, I hope you will keep in mind that you may be sharing personally revealing information in a public forum. I urge you to create a pseudonym that is not linked to your regular email address or friend networks for your own privacy and protection. If you feel I have done something harmful or unethical and you do not feel comfortable discussing it with me, you can always contact the Texas State Board of Examiners of Psychologists, which oversees licensing, and they will review the services I have provided.

Conclusion
Thank you for taking the time to review my Communication and Social Media Policy. If you have questions or concerns about this policy, please bring them to my attention so that we can discuss them together.