Effective Date: October 1, 2026
Legal Practice: CTA Behavioral Health & Family Counseling, Inc.
DBA: CTA Behavioral Health
Privacy Officer: Candice Fuimaono, LMFT
Practice Address: 6296 Magnolia Ave #1156, Riverside, CA 92506
Telephone: (951) 897-6123
Privacy Email / Secure Contact: info@ctabehavioralhealth.com
Client Portal: Sessions Health Client Portal
Your Information. Your Rights. Our Responsibilities.
This Notice describes how health information about you may be used and disclosed, how you may obtain access to that information, and the responsibilities CTA Behavioral Health has for protecting it.
Please review this Notice carefully.
1. Your Rights
You have rights concerning your health information. These may include the right to inspect or obtain a copy of your health record; request correction or amendment; request confidential communications; ask CTA to limit certain uses/disclosures; request an accounting of certain disclosures; obtain a paper/electronic copy of this Notice; designate an authorized personal representative; request certain restrictions when you pay entirely out of pocket; file a privacy complaint; and exercise these rights without retaliation.
2. Obtain a Copy of Your Health Record
You may ask to inspect or obtain an electronic or paper copy of health information CTA maintains about you that is subject to your right of access.
CTA will verify identity and authority before providing records.
CTA will follow the shorter applicable deadline when California law gives greater access rights. CTA’s internal policy generally provides for inspection within the applicable California timeframe and copies within the applicable California timeframe, ordinarily no later than 15 days for qualifying requests.
CTA may charge only a lawful and reasonable cost-based fee when permitted and will not withhold records merely because money is owed.
3. Request Correction or Amendment
You may ask CTA to correct health information you believe is inaccurate or incomplete.
CTA may deny a request in circumstances permitted by law but will explain a denial and applicable rights.
CTA preserves the original record and uses an amendment/correction/addendum process rather than silently deleting or rewriting a signed clinical entry.
4. Request Confidential Communications
You may ask CTA to communicate at a particular phone number, email address, mailing address, through the secure portal, without detailed voicemail, or through another reasonable method.
CTA will honor reasonable requests as required by law.
5. Ask CTA to Limit What We Use or Share
You may ask CTA not to use or disclose certain information for treatment, payment, or health-care operations. CTA is not always required to agree.
If CTA agrees to a restriction, it will follow it except when disclosure is permitted despite the restriction, such as for emergency treatment.
Fully Self-Paid Services
If you pay for a health-care service completely out of pocket, you may request that CTA not disclose information about that service to your health plan for payment or health-care operations. CTA will honor a qualifying request unless disclosure is required by law.
6. Request an Accounting of Certain Disclosures
You may ask for a list of certain disclosures. The accounting generally covers the six years preceding the request, subject to HIPAA exclusions.
Ordinary disclosures for treatment, payment, and health-care operations generally are not included in the standard accounting.
CTA will ordinarily provide one qualifying accounting within a 12-month period without charge; a reasonable cost-based fee may apply to additional requests when permitted.
7. Obtain a Copy of This Notice
You may request a paper copy at any time, even if you previously agreed to receive it electronically.
CTA will also maintain the current Notice through its client portal and therapy website.
8. Choose Someone to Act for You
If another person has valid legal authority to act for you, that person may exercise applicable privacy rights on your behalf.
CTA will verify authority before allowing access or action. Family relationship alone does not automatically establish authority to obtain the psychotherapy record.
9. File a Privacy Complaint
If you believe CTA violated your privacy rights, you may complain directly to CTA.
CTA Privacy Officer: Candice Fuimaono, LMFT
Phone: (951) 897-6123
Email: info@ctabehavioralhealth.com
You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights.
CTA will not retaliate against you for filing a privacy complaint or exercising a privacy right.
10. Family, Friends, and Others Involved in Your Care
You may tell CTA whether information may be shared with a spouse/partner, family member, close friend, caregiver, emergency contact, person involved in care, or person helping pay for care.
When you are present and able to make decisions, CTA will ordinarily follow your stated preference within legal limits.
If you cannot communicate your preference, CTA may make a disclosure permitted by law when the clinician determines it is in your best interest or necessary to address a serious safety concern.
Listing someone as an emergency contact does not automatically give that person access to the entire clinical record.
11. Marketing
CTA Behavioral Health does not use psychotherapy information for third-party marketing without legally required authorization.
CTA will not share clinical information with the education LLC for course marketing merely because both companies have common ownership.
Clinical information will not be used to build advertising audiences, retarget clients with education products, market exam-preparation programs, sell courses, create social-media advertising profiles, or promote unrelated services.
12. Sale of Health Information
CTA does not sell protected health information.
13. Fundraising
CTA Behavioral Health does not currently use client health information for fundraising.
If that practice changes, CTA will comply with applicable notice, authorization, and opt-out requirements before using health information for that purpose.
14. Psychotherapy Notes
HIPAA gives separately maintained psychotherapy notes additional protection.
CTA’s initial policy is not to routinely maintain a separate set of HIPAA-defined psychotherapy notes.
If separately maintained psychotherapy notes are created, most uses/disclosures will require written authorization unless a specific legal exception applies.
Ordinary progress notes, assessments, treatment plans, diagnosis, medication information, risk documentation, and billing records are not automatically HIPAA-defined psychotherapy notes.
How CTA May Use and Share Health Information
15. Treatment
CTA may use health information to provide and coordinate treatment, including assessment, treatment planning, psychotherapy, risk evaluation, coordination with another treating professional, referrals, associate supervision, continuity after hospitalization, and determining whether another level of care is appropriate.
Routine coordination may be permitted without a separate authorization under HIPAA, but CTA generally prefers a written release for ongoing routine coordination when reasonably practicable and when another law does not require a different process.
16. Payment
CTA may use/disclose health information as permitted to verify eligibility, obtain authorization, submit claims, respond to payer questions, establish medical necessity, correct claims, appeal denials, receive payment, post remittances, and coordinate benefits.
CTA will not interpret payment authority as unlimited permission to send an insurer every clinical record it requests without review.
17. Health-Care Operations
CTA may use/disclose health information for lawful operations including clinical quality review, supervision, staff training, credentialing, compliance, billing review, audits, complaint investigation, risk management, privacy/security activities, business planning related to health-care operations, and other permitted operational functions.
Access is role-based and limited to authorized personnel.
Other Uses and Disclosures
18. Public Health and Safety
CTA may use/disclose health information when permitted or required for public-health or safety purposes, including suspected child abuse/neglect, elder/dependent-adult abuse, preventing/reducing a serious threat, certain public-health reporting, and other legally authorized purposes.
19. Mandated Reporting
CTA clinicians are mandated reporters in circumstances defined by California law. Information may be disclosed without authorization when a legally required reporting duty applies.
CTA will disclose information appropriate to the report and related safety response rather than unnecessarily disclosing unrelated psychotherapy information.
20. Serious Threats and Emergencies
Information may be disclosed when permitted or required to prevent/lessen a serious threat; obtain emergency psychiatric/medical intervention; contact emergency services; facilitate a welfare check; protect an identifiable person when applicable law requires/permits action; or respond to another qualifying emergency.
CTA will disclose only information reasonably appropriate to the circumstances.
21. Health Oversight
CTA may disclose information to health-oversight agencies for legally authorized licensing investigations, audits, inspections, regulatory compliance, professional discipline, or other oversight.
22. Law Enforcement and Government Requests
CTA may disclose information to law enforcement/government authority when required by law, required by a valid warrant/court order, permitted for qualifying emergency/safety purposes, required by mandated-reporting law, necessary for another recognized purpose, or otherwise permitted.
A telephone request alone does not automatically result in unrestricted disclosure; CTA verifies the legal basis when circumstances permit.
23. Lawsuits and Legal Proceedings
Health information may sometimes be disclosed in response to court orders, administrative orders, subpoenas, depositions, discovery requests, or other legal proceedings.
Psychotherapy records may also be protected by California psychotherapist-patient privilege and other confidentiality laws.
CTA reviews legal requests rather than treating every subpoena as automatic authorization for immediate disclosure.
24. Workers’ Compensation
CTA may disclose health information as authorized or required for workers’ compensation or similar programs.
25. Medical Examiners, Coroners, and Funeral Directors
When permitted by law, CTA may disclose relevant information to a coroner, medical examiner, or funeral director for authorized duties involving a deceased person.
26. Research
CTA does not currently operate a clinical research program using client records.
Clinical information will not automatically become research data because CTA also operates an education company.
If CTA later participates in research, applicable HIPAA, California, ethical-review, authorization/waiver, and privacy requirements must be satisfied before protected information is used.
Mental Health and California Privacy Protections
27. California Mental-Health Information
California law may provide additional confidentiality and privilege protection beyond HIPAA. Where California law is more protective, CTA will apply the applicable more protective requirement.
Examples may include psychotherapist-patient privilege, additional medical-information authorization requirements, multi-client privacy interests in relational records, California-specific access timelines, and specific written-authorization rules.
CTA will not rely on HIPAA alone when California law provides additional protection.
Substance-Use-Disorder Records
28. 42 C.F.R. Part 2
CTA is not automatically a federally assisted Part 2 program merely because a client discusses alcohol or substance use in psychotherapy.
However, CTA may receive or maintain records protected by 42 C.F.R. Part 2. When Part 2 applies, CTA will provide the additional protections required by federal law.
29. Legal Proceedings Involving Part 2 Records
To the extent CTA maintains Part 2-protected information, CTA will not use/disclose it in a civil, criminal, administrative, or legislative investigation/proceeding against the client unless applicable Part 2 requirements are satisfied, including qualifying written consent or the required court order/subpoena.
30. Part 2 Consent and Specially Protected Notes
When Part 2 requires consent, CTA will obtain the appropriate consent.
A general CTA release form will not be used to defeat protections that require a more specific Part 2 consent.
CTA’s Responsibilities
31. Protect Your Information
CTA is required to maintain the privacy and security of protected health information and uses administrative, physical, and technical safeguards intended to protect information stored/transmitted through the EHR, client portal, telehealth, billing systems, payer portals, secure email, approved devices, cloud systems, and other approved technology.
No electronic system can be guaranteed completely immune from security incidents.
32. Breach Notification
CTA will notify affected individuals when required if a breach occurs that may have compromised privacy/security and will make required reports to government agencies or other entities when applicable.
33. Follow This Notice
CTA must follow the privacy practices described in the Notice currently in effect.
CTA will not use/disclose health information in a way that requires written authorization unless the client provides valid authorization or another legal basis permits/requires the use/disclosure.
34. Business Associates
CTA may use vendors that qualify as HIPAA business associates, such as the EHR, telehealth provider, billing company, clearinghouse, secure cloud provider, IT support, record-management vendor, and other services handling PHI.
CTA will obtain a Business Associate Agreement when required and require appropriate safeguards. 15K-11_-_Notice_of_Privacy_Prac…
35. Education LLC Separation
CTA Behavioral Health & Family Counseling, Inc. and Clinical Training and Supervision Academy, LLC are separate businesses.
Psychotherapy information will not automatically be shared with the education company because the businesses have common ownership or related branding.
Clinical information will remain separated from course enrollment, exam-preparation accounts, CE records, learner dashboards, course marketing, education payment records, and general educational customer data.
36. Rula and Other Separate Practices
Services Candice provides through Rula/SUD Specialty Group or another separate authorized organization are not automatically part of CTA Behavioral Health’s clinical record.
CTA will not import, remove, or combine another organization’s client records merely because the same clinician provided services. Records will be transferred only through an authorized and lawful process.
Changes to This Notice
37. Changes to Privacy Practices
CTA may change this Notice and its privacy practices when permitted by law. A revised Notice may apply to information CTA already maintains and information received after the change.
When a material revision occurs, the current Notice will be available through the portal, website, upon request, and otherwise distributed/made available as required.
Questions and Complaints
38. CTA Privacy Contact
Privacy Officer: Candice Fuimaono, LMFT
CTA Behavioral Health
6296 Magnolia Ave #1156
Riverside, CA 92506
Phone: (951) 897-6123
Email: info@ctabehavioralhealth.com
39. Federal Privacy Complaints
Clients may file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights.
CTA will maintain current complaint-submission information through the website and portal.
CTA will not retaliate against a client for filing a complaint.
Notice Effective Date
Effective Date: October 1, 2026
This Notice remains in effect until replaced by a later approved version.
