Privacy Policy

JAL Practice LLC d/b/a Emerge Therapies ("Emerge," "we," "our," or "us") is an outpatient behavioral health practice providing mental health services, including Spravato (esketamine) treatment, intravenous ketamine therapy, transcranial magnetic stimulation (TMS), medication management, and related behavioral health services.

We are committed to protecting the privacy and confidentiality of individuals who visit our website, contact our practice, inquire about services, or receive care from Emerge.

This Privacy Policy explains what information we collect, how we use and protect that information, and when it may be shared with third parties in connection with our operations and delivery of services.

This policy applies to information collected through our website, telephone communications, text messaging, patient intake processes, and other interactions with Emerge.

Emerge is a health care provider covered by the Health Insurance Portability and Accountability Act (HIPAA). Where Massachusetts law protects your information more than federal law does (for example, mental health, HIV, and genetic information), we follow Massachusetts law.

Depending on your interaction with Emerge, we may collect the following categories of information:

A. Information You Provide Directly

This may include:

• Name, date of birth, email address, telephone number, and mailing address.
• Information submitted through website inquiry forms or contact requests.
• Insurance information and basic information necessary to verify benefits.
• Referral information provided by you or your referring provider.
• Appointment and scheduling information.
• Communications with our administrative or clinical team.
• Information necessary to coordinate care and respond to inquiries.

B. Health and Treatment Information

When you become a patient, Emerge collects and maintains protected health information (PHI), including:

• Medical and behavioral health history.
• Treatment records and clinical assessments.
• Medication and treatment information.
• Insurance eligibility, authorizations, and claims information.
• Clinical communications and documentation.
• Information necessary for treatment coordination and continuity of care.

Health information maintained by Emerge is handled in accordance with HIPAA and applicable Massachusetts privacy laws.

In this policy, "personal information" means information that identifies you or could reasonably be used to identify you, including PHI. PHI is subject to the additional protections described in Section 6 and in our Notice of Privacy Practices.

Emerge may use information collected from you for the following purposes:

• Responding to questions and requests for information.
• Scheduling appointments and coordinating patient care.
• Managing patient intake and referral workflows.
• Communicating with patients regarding appointments, scheduling changes, and administrative matters.
• Verifying insurance eligibility and benefits.
• Obtaining insurance authorizations (including prior authorization requests) and processing claims.
• Providing and coordinating treatment, including with your other providers, pharmacies, and laboratories.
• Managing billing, payment processing, and collections from you, your health plan, or others.
• Communicating with referring providers and other healthcare professionals when permitted by law.
• Running our practice, including quality review, staff training, and audits.
• Maintaining practice operations and improving administrative workflows.
• Meeting legal, regulatory, and recordkeeping obligations.
• Protecting the security and integrity of our practice and systems.

Emerge does not use patient health information to create advertising profiles or sell identifiable patient information.

Uses that require your written authorization. We will obtain your written authorization before using or disclosing your PHI for marketing, for the sale of your PHI, for most uses of psychotherapy notes, and for any other use or disclosure not described in this policy or in our Notice of Privacy Practices. You may revoke an authorization in writing at any time, except to the extent we have already acted on it.

Emerge uses selected third-party service providers to support its administrative, communication, and operational functions. These providers may process or have access to information as necessary to perform services on our behalf.

Emerge may work with additional vendors that support healthcare operations, including electronic health record systems, customer relationship management (CRM) tools, billing and revenue cycle management services, insurance verification, payment processing, technology support, and secure document management.

Vendors that create, receive, maintain, or transmit PHI on our behalf are business associates. Each business associate agrees in writing to protect your information, and vendors receive information only as reasonably necessary to provide their contracted services or as otherwise permitted by law.

Emerge does not authorize its service providers to use patient information for their own independent marketing purposes.

Emerge may communicate with patients and individuals who have contacted our practice through telephone calls and SMS text messages, using the contact methods you authorize.

Text messages may include:

• Appointment reminders and confirmations.
• Scheduling updates and appointment changes.
• Responses to patient inquiries.
• Intake and administrative requests.
• General practice-related communications.
• Other nonclinical administrative notifications.

Patients may opt out of text messaging at any time by replying STOP to any text message from Emerge, or by calling (781) 776-1944 or emailing support@emergetherapies.health.

For additional information regarding text messaging, consent, and opt-out procedures, please review our SMS/Text Messaging Terms and Conditions.

Consent to receive text messages is not a condition of receiving healthcare services from Emerge.

Emerge is required by law to maintain the privacy of your protected health information, to give you notice of our legal duties and privacy practices, to follow the notice currently in effect, and to notify you if a breach of your unsecured PHI occurs.

Protected health information is used and disclosed in accordance with HIPAA, applicable Massachusetts law, and Emerge's Notice of Privacy Practices. Where Massachusetts law protects your information more than federal law does (for example, mental health, HIV, and genetic information), we follow Massachusetts law.

We may use and share your PHI without your written authorization for:

• Treatment — to provide and coordinate your care.
• Payment — to bill and collect, including prior authorization requests.
• Health care operations — to run our practice, review quality, train staff, and conduct audits, including through business associates.
• Reminders and care information — appointment reminders and information about your treatment, using the contact methods you authorize.
• People involved in your care — with a family member, friend, or the person giving you a ride home whom you identify, unless you object.
• As required or permitted by law, as described in Section 7.

Our use of third-party platforms does not change our obligation to protect patient information and limit access to authorized personnel.

Emerge may disclose personal information in the following circumstances:

Healthcare Providers and Referring Professionals

Information may be shared with treating providers, referring professionals, pharmacies, laboratories, or other healthcare organizations when necessary for treatment, care coordination, or other purposes permitted by law.

Insurance Companies and Healthcare Benefit Administrators

Information may be shared with insurance companies and benefit administrators for eligibility verification, prior authorizations, claims processing, reimbursement, and other payment-related activities.

Business Associates and Service Providers

Information may be shared with vendors who provide services to Emerge, including CRM, telephone, text messaging, billing, technology, and administrative support, under written agreements to protect your information.

People Involved in Your Care

Information may be shared with a family member, friend, or the person giving you a ride home whom you identify, unless you object.

Legal and Regulatory Requirements

Information may be disclosed when required or permitted by law, including:

• public health and safety, including reporting abuse or neglect and preventing a serious threat to health or safety;
• health oversight, such as licensing boards and audits;
• lawsuits and legal proceedings, including court orders and certain subpoenas;
• law enforcement, in limited circumstances;
• coroners, medical examiners, and funeral directors;
• organ and tissue donation;
• research approved under privacy rules;
• workers' compensation;
• specialized government functions; and
• the U.S. Food and Drug Administration (FDA), including the Spravato® REMS program.

Patient Authorization

Information may be disclosed when a patient provides appropriate written authorization or otherwise provides permission as permitted by law.

Emerge maintains reasonable administrative, technical, and physical safeguards designed to protect personal information from unauthorized access, disclosure, alteration, or destruction.

Access to information is limited to authorized personnel and service providers who require access to perform their responsibilities.

If a breach of your unsecured PHI occurs, we will notify you as required by law.

Information is retained for as long as reasonably necessary to fulfill the purposes described in this policy and to satisfy applicable legal, regulatory, healthcare recordkeeping, and business requirements. Healthcare records may be retained for periods required by applicable federal and state laws.

No electronic system or method of transmission can be guaranteed to be completely secure.

Depending on the nature of the information and applicable law, you have the right to:

• Get a copy of your paper or electronic medical record (we may charge a reasonable, cost-based fee).
• Ask us to correct your record.
• Ask us to contact you in a specific way or at a specific address or phone number (confidential communications).
• Ask us to limit what we use or share. We are not required to agree, except that we must agree not to share information with your health plan about a service you paid for in full out of pocket, if you ask.
• Get a list of certain disclosures we made in the past six years.
• Get a paper copy of our Notice of Privacy Practices at any time.
• Choose someone to act for you, such as a health care agent or legal guardian.
• Revoke an authorization previously provided, in writing, except to the extent we have already acted on it.
• Opt out of SMS communications.
• Exercise other rights available to you under applicable state privacy law.

Requests involving medical records or protected health information should be directed to Emerge's Privacy Officer at (781) 776-1944 or support@emergetherapies.health. Emerge will respond to requests in accordance with applicable law.

Our website may use essential cookies or similar technologies to support website functionality and security.

If additional analytics or tracking technologies are implemented, this policy will be updated as appropriate to describe their use.

You may adjust your browser settings to limit or disable cookies. Certain website features may not function properly if cookies are disabled.

Emerge complies with applicable federal civil rights laws and does not discriminate on the basis of race, color, national origin (including limited English proficiency and primary language), age, disability, or sex. Emerge does not exclude people or treat them differently because of these characteristics.

We provide free help to people with disabilities so they can communicate with us, such as qualified sign language interpreters and written information in other formats (large print or accessible electronic formats), and free language services to people whose primary language is not English, such as qualified interpreters and information written in other languages. To ask for these services, call (781) 776-1944 or email support@emergetherapies.health.

Emerge may update this Privacy Policy periodically to reflect changes in our practices, services, technology, or applicable laws.

Any updates will be posted on our website with a revised effective or updated date. The current Notice of Privacy Practices is available in our offices, at emergetherapies.health, and on request.

For questions about this Privacy Policy, requests concerning personal information, or privacy-related concerns, please contact Emerge Therapies:

Privacy complaints. If you believe your privacy rights have been violated, you may contact our Privacy Officer or file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, at www.hhs.gov/ocr/complaints or 1-800-368-1019. We will not retaliate against you for filing a complaint.

Civil rights grievances. If you believe we have failed to provide language or disability services or have discriminated in another way, you can file a grievance with our Civil Rights Coordinator at (781) 776-1944 or support@emergetherapies.health. You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, at ocrportal.hhs.gov, by mail at 200 Independence Avenue SW, Room 509F, HHH Building, Washington, DC 20201, or by phone at 1-800-368-1019 (TDD 1-800-537-7697).