Privacy Practices

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Privacy Practices

EFFECTIVE DATE OF THIS NOTICE: February 1, 2023

Privacy Policy and Notice of Health Information Practices

(Aligned with HIPAA and CMS Policies and Procedures)

Effective Date

This Notice is effective as of February 1, 2023, and was last updated on November 20, 2025. Future updates will be posted and communicated as required.

Introduction

Gemini Counseling Services, LLC (“Gemini Counseling,” “we,” “our,” or “us”) is committed to protecting the privacy and security of your health information in full compliance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and applicable Centers for Medicare & Medicaid Services (“CMS”) regulations. This Privacy Policy and Notice of Health Information Practices (“Notice”) describes our legal duties, privacy practices, and your rights regarding the use and disclosure of your Protected Health Information (“PHI”). This Notice applies to all records created or maintained by Gemini Counseling in connection with your care and services. Please review this Notice carefully and retain it for your records.

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

I. Our Commitment to Your Health Information

Your health information and the details of your health care are personal. At Gemini Counseling Services, LLC, we are devoted to preserving the privacy of your health information. We maintain a record of the care and services you receive, which is essential for delivering high-quality care and complying with legal requirements. This notice applies to all records generated by this mental health care practice and outlines how we may use and disclose your health information. It also explains your rights regarding your health information and our obligations in managing its use and disclosure.

We are required by law to ensure that your protected health information ("PHI") is kept private.
We must provide you with notice of our legal duties and privacy practices related to your health information.
We follow the terms outlined in the current notice.
We reserve the right to change the terms of this notice, and such changes will apply to all the health information we have about you. The updated notice will be available upon request, in our office, and on our website.

II. How We May Use and Disclose Your Health Information

The following categories describe the various ways in which we may use and disclose your health information. While not every specific use or disclosure is listed, all permitted actions fall within these categories.

For Treatment, Payment, or Health Care Operations: Federal privacy regulations allow health care providers to use or disclose your personal health information without written authorization for activities related to treatment, payment, or health care operations. For example, we may consult with other licensed health care providers about your condition to assist in diagnosis and treatment. These disclosures are not subject to the minimum necessary standard, as providers may need access to your complete record to provide effective care. "Treatment" includes coordination and management of care with third parties, consultations between providers, and referrals from one provider to another.
Lawsuits and Disputes: If you are involved in a lawsuit, we may disclose health information in response to a court or administrative order. We may also disclose health information about your child in response to a subpoena, discovery request, or other lawful process, provided efforts have been made to notify you or to obtain an order protecting the requested information.

III. Uses and Disclosures Requiring Your Authorization

Psychotherapy Notes: We maintain psychotherapy notes as defined by 45 CFR § 164.501. Any use or disclosure of these notes requires your authorization except in the following circumstances:
For our use in treating you.
For training or supervising mental health practitioners.
For our use in defending ourselves in legal proceedings initiated by you.
For investigations by the Secretary of Health and Human Services regarding HIPAA compliance.
As required by law, limited to legal requirements.
For health oversight activities pertinent to the originator of the notes.
For duties performed by a coroner authorized by law.
To help prevent a serious threat to the health and safety of others.

Marketing Purposes: We will not use or disclose your PHI for marketing purposes.

Sale of PHI: We will not sell your PHI in the regular course of business.

IV. Uses and Disclosures Not Requiring Your Authorization

Subject to certain legal limitations, we may use and disclose your PHI without your authorization for the following reasons:

When required by state or federal law, ensuring compliance with relevant legal requirements.
For public health activities, such as reporting suspected child, elder, or dependent adult abuse, or to prevent or reduce a serious threat to health or safety.
For health oversight activities, including audits and investigations.
For judicial and administrative proceedings, such as responding to court or administrative orders. Our preference is to obtain your authorization beforehand.
For law enforcement purposes, including reporting crimes on our premises.
To coroners or medical examiners performing duties authorized by law.
For research purposes, including comparing mental health outcomes of different therapies.
For specialized government functions, such as military missions, protecting the President, intelligence operations, or safety in correctional institutions.
For workers' compensation purposes, as required by law. We prefer to obtain your authorization but may disclose your PHI to comply with workers' compensation laws.
For appointment reminders and information about health-related benefits or services, including treatment alternatives and other services we offer.

V. Uses and Disclosures Requiring an Opportunity to Object

We may disclose your PHI to family members, friends, or others involved in your care or payment for your care, unless you object in whole or in part. In emergency situations, consent may be obtained retroactively.

VI. Your Rights Regarding Your PHI

The Right to Request Limits: You may request that we not use or disclose certain PHI for treatment, payment, or health care operations. We are not required to agree to your request if it may affect your health care.
The Right to Request Restrictions for Out-of-Pocket Payments: You can request restrictions on disclosures of PHI to health plans if you have paid for a health care item or service out-of-pocket in full.
The Right to Choose Communication Methods: You may ask us to contact you through specific means (e.g., home or office phone, or mail sent to a different address), and we will honor all reasonable requests.
The Right to Access Your PHI: You may request an electronic or paper copy of your medical record and other information we have about you, excluding psychotherapy notes. We will provide the copy or a summary (if you agree) within 30 days of a written request and may charge a reasonable, cost-based fee.
The Right to an Accounting of Disclosures: You may request a list of instances in which we have disclosed your PHI for reasons other than treatment, payment, health care operations, or disclosures made with your authorization. We will respond within 60 days, providing disclosures from the past six years unless you request a shorter period. The first list is free; additional requests within the same year may incur a reasonable fee.
The Right to Correct or Update PHI: If you believe your PHI contains errors or missing information, you may request corrections or additions. If we deny your request, we will provide a written explanation within 60 days.
The Right to a Copy of This Notice: You may request a paper or electronic copy of this notice at any time, even if you previously agreed to receive it by email.

VII. Changes to Our Privacy Practices

We reserve the right to update this Privacy Policy at any time. Should we make changes, we will post updates to this Privacy Policy and other appropriate locations to keep you informed about the information we collect, how we use it, and under what circumstances it may be disclosed. If material changes are made, we will notify you here, by email, or via a notice on our homepage at least thirty (30) days prior to the changes taking effect.

VIII. Correcting, Updating, and Removing Personal Information

You may modify, update, or deactivate your account information, or opt out of communications from us at any time. Please email contact@geminicounseling.org or send a written letter to Gemini Counseling Services, 1750 Delta Waters Rd Ste 102 PMB 330, Medford, OR 97504. We will respond to your request within thirty (30) days.

IX. Contact Information

If you have questions about this Privacy Policy, the practices of this site, our services, or your dealings with us, please contact us by email at contact@geminicounseling.org or by regular mail at Gemini Counseling Services, 1750 Delta Waters Rd Ste 102 PMB 330, Medford, OR 97504.

Informed Consent for Therapy Services

I. General Information and Therapeutic Relationship

This document establishes the framework and mutual expectations for our professional engagement.

I am a Licensed Clinical Social Worker authorized to provide therapy services in the states of Oregon and Utah.

The therapeutic relationship operates on both a professional and contractual basis. It is essential that we reach a mutual understanding of the functions and expectations of our relationship.

Please address any questions or concerns regarding these policies or the therapeutic process directly with me, particularly those that may affect session continuity.

II. Availability and Communication Protocol

Availability:

Office hours are dependent on the scheduled appointment calendar; drop-in appointments are not offered.

Days of Service and Standard Hours

Tuesday - Friday 10:00 am – 6:30 pm ( Requests for appointments beyond these hours will be reviewed on a case-by-case basis).

Saturday 9:00 AM – 3:00 PM ( Requests for appointments beyond these hours will be reviewed on a case-by-case basis).

Out of Office- Sunday & Monday - Emails and text messages are monitored only occasionally. Responses will occur the following workday (usually Tuesday unless otherwise specified).

Response Time: Important messages will receive a response typically provided within 48 hours.

Crisis/Imminent Danger: For immediate support, utilize crisis lines

Jackson County Crisis Line: 541-774-8201
Helpline 541-779-4357
National Crisis Line: 988

If in imminent danger:

call 911, or go to the nearest emergency room

Communication Methods

Texts: Use texts exclusively for urgent logistical matters (e.g., running late, rescheduling, shifting to telehealth). Do not share clinical or therapeutic content via text.
Emails: Responses are typically provided within 48 hours. Please use "URGENT" in the subject line for time-sensitive inquiries.
Phone Calls: Email or text is the preferred method for requesting a phone conversation due to limited real-time availability. Callback times may vary.
Social media: To protect your privacy and the integrity of the therapeutic boundaries, client requests on any social media platform are not accepted.At Gemini Counseling Services, we believe that strength training is for everyone. Our women-only strength training classes are designed to help you build lean muscle and increase your metabolism, so you can achieve your fitness goals and feel confident and strong.

III. The Therapeutic Process

Voluntary Participation: Taking part in therapy is completely your choice.
Provider Role: My role is to offer support and use my professional skills to help you better understand and clarify your personal goals.
Effectiveness/Benefits: Therapy offers numerous advantages, such as enhanced coping skills, greater self-awareness, symptom alleviation, and improved overall well-being. The effectiveness of therapy is closely linked to client engagement in the process.
Risks/Challenges: Sessions may require exploring or recalling challenging experiences or emotions, which can elicit significant emotional responses including anger, sadness, or anxiety. You may feel uncomfortable emotions, face tough topics, or notice a temporary rise in distress as we work through issues.
Risks/Challenges: Sometimes sessions involve discussing or remembering difficult experiences or feelings, which can cause strong emotional reactions like anger, sadness, or anxiety. As we address certain issues, you might encounter uncomfortable emotions, face challenging topics, or experience a temporary increase in distress.

Outcome Disclaimer: Please note that there are no guarantees regarding particular outcomes or changes in behavior or circumstances. Each person's progress varies, and positive results cannot be assured. Openly sharing your experience helps us effectively address any concerns or challenges together.

IV. Financial and Billing Policies

Insurance Billing: Insurance claims will be submitted via the provider’s electronic health record (EHR) system.
Client Responsibility: The client is responsible for all costs determined by their insurance agreement, including any deductible, co-payment, or co-insurance.
Financial Liability: The client is ultimately responsible for full payment if a claim is denied by the insurance provider or if insurance information is not provided at the first session.
Payment Methods: Payments are accepted via cash, check, or credit/debit card.
Returned Checks: The client is responsible for any returned check fees, up to $100.
Credit Card Processing: Stripe is the designated credit card processing company. Invoicing will utilize your name, date of service, and email address.
Cash payment (out of Pocket): Individual sessions are $125, but I highly recommend billing your insurance.

V. Appointment and Cancellation Policy

This policy applies to both telehealth and in-person visits.

Late Arrival Policy:

A 15-minute grace period is extended for all appointments. If you arrive 15 minutes or more after your scheduled appointment time, your appointment will be automatically canceled and will need to be rescheduled.

Cancellation Policy:

While I do not charge a cancellation fee, I kindly ask that you notify me of any cancellations as soon as possible.

VI. Confidentiality and Disclosure

HIPAA Compliance: This practice adheres to the Health Insurance Portability and Accountability Act (HIPAA), ensuring the confidentiality and security of your Protected Health Information (PHI). You retain the right to access, request corrections to your records, receive notices regarding PHI use, request restrictions on disclosure, and file complaints with the Oregon Board of Social Workers.
Clinical Records: Session details and materials remain confidential unless a signed Release of Information (ROI) form is provided. Please notify the provider in advance of any ROI request to allow for a discussion regarding potential impacts on your care.
Consultation: Consultations with other professionals may occur to ensure the highest quality of treatment. Client-identifying information will be removed to preserve confidentiality during these consultations.

Mandated Exceptions to Confidentiality

Confidentiality may be legally overridden in the following circumstances:
A client threatens or attempts suicide or engages in actions posing a substantial risk of serious self-harm.
A client threatens serious bodily harm or death to another identifiable person.
Reasonable suspicion of physical, emotional, or sexual abuse or neglect of a minor (under 18).
Reasonable suspicion of abuse or neglect of an elderly individual.
Receipt of a legitimate subpoena or courtorder.
Therapy is court-ordered, or information is required for an expert report for an attorney.
An insurance company audit of client records requires disclosure.

VII. Professional Boundaries (Community Interactions)

Due to the nature of operating in the community, accidental encounters may occur. Your privacy is protected by the following guidelines:
You have the option to ignore me without concern of professional offense.
If you choose to acknowledge me, I will respond in a similar, brief manner.
You are permitted to approach me for casual conversation.

The provider is ethically and professionally prohibited from:

Acknowledging you first.
Engaging in discussions regarding your clinical difficulties outside of the office.
Introducing myself to anyone accompanying you.

VIII. Telehealth (Virtual) Sessions

Telehealth services involve the use of live audio and video communication for remote sessions.

Tuesdays are dedicated telehealth days, though any in-person session may be converted to a virtual session upon request.
Consent: Telehealth services are voluntary, and your consent can be withdrawn at any time.
Security: Internet-based communication is not entirely secure. Potential risks include interruptions, unauthorized access, and technical difficulties.
Privacy: Privacy and confidentiality laws apply. I will utilize a secure communication system (Google Meet, with a virtual waiting room) and take measures to ensure privacy on my end. The client is also responsible for securing their private environment during sessions.
Recording: Neither party will record or photograph the sessions without prior written consent from the other.
Technical Issues: If the connection drops, you should have an alternative phone line or pre-planned reconnection method. Sessions may shift to a phone call or be discontinued if the technology is deemed inadequate.
Liability: The therapist and practice will not be held liable if an outside party bypasses security measures and accesses personal information.
Emergency Protocol: In the event of an in-session emergency, the therapist may contact emergency services or your designated emergency contact.
Platform: The preferred platform is Google Meet. Clients receive the link via email/calendar invitation.

IX. Use of Artificial Intelligence (AI)

AI is utilized to enhance professional efficiency and documentation.

Function: AI enhances my work by drafting letters, suggesting professional document formats (e.g., accommodation letters), and assisting with the creation of well-organized case notes and treatment plans.
Oversight: All documents and notes generated with AI assistance are thoroughly reviewed, verified, and approved by the clinician to ensure accuracy, quality, and adherence to confidentiality standards. AI automation allows the clinician to concentrate more time and focus on direct client care.

X. Informed Consent and Your Rights

The decision to provide informed consent is entirely yours, and I fully respect your autonomy in making choices that feel appropriate for you. By signing the informed consent form, you acknowledge that you have been made aware of your rights, your responsibilities, and the overall nature of our collaborative work together.

Should you choose not to sign the informed consent form at this time, I will honor your decision without judgment. However, please understand that I will be unable to provide services until informed consent is granted. If, at any point in the future, you decide to proceed, I remain available to support you and move forward together.mental clarity, and boost your overall well-being.

Privacy Practices

Informed Consent for Therapy Services

I. General Information and Therapeutic Relationship

II. Availability and Communication Protocol

III. The Therapeutic Process

IV. Financial and Billing Policies

V. Appointment and Cancellation Policy

VI. Confidentiality and Disclosure

Mandated Exceptions to Confidentiality

VII. Professional Boundaries (Community Interactions)

The provider is ethically and professionally prohibited from:

VIII. Telehealth (Virtual) Sessions

IX. Use of Artificial Intelligence (AI)

X. Informed Consent and Your Rights

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