Privacy Policy
NOVA ViA and NOVAViA.health
Effective Date: August 11, 2025
Last Updated: July 26, 2025
Table of Contents
- Introduction
- Scope of This Policy
- Protected Health Information (PHI)
- Special Protections for Substance Use Disorder Records
- How We Use and Disclose Your Health Information
- Your Rights Regarding Your Health Information
- Website and Digital Privacy
- Security Safeguards
- Business Associates
- Changes to This Policy
- Contact Information
Introduction
NovaVia (“we,” “us,” or “our”) is committed to protecting the privacy and confidentiality of your health information. This Privacy Policy describes how we collect, use, disclose, and safeguard your protected health information (PHI) in compliance with the Health Insurance Portability and Accountability Act (HIPAA), 42 CFR Part 2 federal regulations for substance use disorder treatment records, and other applicable privacy laws.
As a healthcare provider specializing in outpatient addiction treatment, we understand the sensitive nature of the information you share with us and are committed to maintaining the highest standards of privacy protection.
Scope of This Policy
This Privacy Policy applies to:
- All health information created, received, maintained, or transmitted by NovaVia
- Information collected through our website (novavia.health)
- Clinical services provided at our facilities
- Telehealth services (if applicable)
- Administrative and billing activities
- All NovaVia workforce members, contractors, and business associates
Protected Health Information (PHI)
What is PHI?
Protected Health Information includes any information we collect that could identify you and relates to:
- Your past, present, or future physical or mental health condition
- Healthcare services provided to you
- Payment for healthcare services
- Demographics and contact information
- Treatment plans and clinical notes
- Billing and insurance information
Categories of PHI We Collect:
- Demographic Information: Name, address, phone number, email, date of birth, Social Security number
- Health Information: Medical history, current symptoms, treatment plans, progress notes, diagnostic information
- Substance Use Information: Details related to alcohol or drug use, treatment history, assessment results
- Insurance Information: Insurance provider details, policy numbers, billing information
- Emergency Contacts: Information about individuals to contact in case of emergency
- Legal Information: Court orders, legal documentation (when applicable)
Special Protections for Substance Use Disorder Records
42 CFR Part 2 Protections
Records related to substance use disorder diagnosis, treatment, or referral are protected by federal regulations (42 CFR Part 2) that provide stricter confidentiality protections than HIPAA. These protections apply to all our substance use disorder treatment records.
Key Protections Include:
- Written Consent Required: We cannot disclose substance use disorder records without your written consent, except in very limited circumstances
- Criminal Justice Restrictions: We cannot disclose information to law enforcement without a court order or your consent
- No Acknowledgment: We cannot acknowledge your presence in our program without your consent
- Limited Exceptions: Disclosures may be made without consent only for medical emergencies, child abuse reporting, or pursuant to valid court orders
Redisclosure Prohibition
Any person or organization that receives your substance use disorder records from us is prohibited from making further disclosure without your written consent, except as permitted by federal regulations.
How We Use and Disclose Your Health Information
Uses and Disclosures With Your Authorization
We will obtain your written authorization before using or disclosing your PHI for purposes other than treatment, payment, or healthcare operations, including:
- Marketing communications
- Sale of PHI
- Psychotherapy notes (separate authorization required)
- Most uses and disclosures of substance use disorder records
Uses and Disclosures Without Your Authorization
Treatment
We may use and disclose your PHI to provide, coordinate, or manage your healthcare treatment, including:
- Sharing information among your treatment team
- Consulting with other healthcare providers
- Coordinating care with family members or support persons (with your consent)
- Providing referrals to other healthcare providers
Payment
We may use and disclose your PHI for payment activities, including:
- Billing you or your insurance company
- Determining eligibility for benefits
- Processing claims and payments
- Utilization review and pre-authorization
Healthcare Operations
We may use and disclose your PHI for healthcare operations, including:
- Quality assessment and improvement activities
- Clinical training and education
- Accreditation and licensing activities
- Business planning and administrative functions
Required by Law
We may disclose your PHI when required by federal, state, or local law, including:
- Public Health Activities: Disease reporting, public health investigations
- Health Oversight Activities: Audits, investigations, inspections by health agencies
- Judicial and Administrative Proceedings: In response to court orders or administrative subpoenas
- Law Enforcement: When required by law or court order (limited for substance use records)
- Child Abuse Reporting: Suspected child abuse or neglect
- Threats to Health or Safety: Serious threats to your health and safety or that of others
Emergencies
In medical emergencies, we may disclose PHI necessary to prevent serious harm to your health and safety.
Your Rights Regarding Your Health Information
Right to Request Restrictions
You have the right to request restrictions on how we use or disclose your PHI. While we will consider your request, we are not required to agree to restrictions except in certain circumstances involving payment to health plans.
Right to Access Your Records
You have the right to inspect and obtain copies of your PHI that we maintain, with some exceptions. We will respond to your request within 30 days and may charge reasonable fees for copying.
Right to Request Amendment
If you believe your PHI is incorrect or incomplete, you may request that we amend the information. We may deny your request if the information is accurate and complete.
Right to an Accounting of Disclosures
You have the right to receive an accounting of certain disclosures of your PHI made by us in the six years prior to your request.
Right to Request Confidential Communications
You may request that we communicate with you about your PHI in a certain way or at a certain location to protect your privacy.
Right to File a Complaint
You have the right to file a complaint if you believe your privacy rights have been violated. You may file complaints with:
- NovaVia Privacy Officer: [Contact information below]
- U.S. Department of Health and Human Services: www.hhs.gov/hipaa/filing-a-complaint
We will not retaliate against you for filing a complaint.
Website and Digital Privacy
Website Information Collection
Our website may collect:
- Voluntary Information: Information you provide through contact forms, appointment requests, or registration
- Automatic Information: IP addresses, browser type, pages visited, time spent on site
- Cookies: Small files stored on your device to improve website functionality
Online Communications
- Email and online communications may not be secure
- Please do not include sensitive health information in unsecured communications
- We use secure patient portals for confidential health information exchange
Third-Party Services
We may use third-party services (analytics, chat features) that have their own privacy policies. We ensure these services meet our privacy and security standards.
Security Safeguards
We implement comprehensive security measures to protect your PHI:
Administrative Safeguards
- Privacy and security training for all workforce members
- Access controls and user authentication
- Incident response procedures
- Regular security risk assessments
Physical Safeguards
- Secured facilities with controlled access
- Workstation security controls
- Secure storage of physical records
- Proper disposal of PHI-containing materials
Technical Safeguards
- Encryption of electronic PHI in transit and at rest
- Access controls and user authentication systems
- Audit logs and monitoring systems
- Secure backup and recovery procedures
Business Associates
We may share your PHI with business associates who perform services on our behalf (billing companies, IT support, legal counsel). All business associates must sign agreements requiring them to protect your PHI according to HIPAA standards.
Telehealth Services
When we provide telehealth services:
- We use HIPAA-compliant platforms with appropriate security features
- You are responsible for ensuring privacy on your end during sessions
- Sessions may be recorded only with your explicit consent
- Technical issues may affect the quality or security of communications
Changes to This Policy
We reserve the right to change this Privacy Policy and make the new provisions effective for all PHI we maintain, including information created or received before the change. We will:
- Post the updated policy on our website
- Provide copies upon request
- Notify you of material changes as required by law
Contact Information
Privacy Officer
Name: [Privacy Officer Name]
Title: Privacy Officer
Address: [Business Address]
Phone: [Phone Number]
Email: [Privacy Email Address]
General Contact
NovaVia
Address: [Business Address]
Phone: [Main Phone Number]
Website: novavia.health
Office Hours
[Insert office hours]
Emergency Contact
For mental health emergencies, please call 911 or go to your nearest emergency room.
- Crisis Hotline: 988 (Suicide & Crisis Lifeline)
- SAMHSA National Helpline: 1-800-662-4357
Additional Resources
- HIPAA Information: www.hhs.gov/hipaa
- Substance Abuse Privacy Rights: www.samhsa.gov/about-us/who-we-are/laws-regulations/confidentiality-regulations-faqs
- Arizona Department of Health Services: www.azdhs.gov
Notice: This Privacy Policy complies with HIPAA Privacy Rule, 42 CFR Part 2, and applicable state laws. If you have questions about this policy or your privacy rights, please contact our Privacy Officer.
Document Version: 1.0