Privacy Policy

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. Effective date of this Notice of Privacy Practices: February 16, 2026.

Your Information
In this HIPAA Notice of Privacy Practices (“HIPAA Notice”), when we use “your information” or “your protected health information”, we are referring to information that identifies you and relates to your health or condition, your health care services, or payment for those services. It includes health information, like diagnosis and treatment plans. It also includes demographic information like your name, address, phone number and date of birth.

Your Rights
When it comes to your protected health information, you have rights. This section explains your rights and how we can help you.

Get a copy of your medical record
We will provide a copy or summary of your protected health information, usually within 30 days of your request.

Ask us to correct your medical record
We may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communications
You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. We will say “yes” to all reasonable requests.

Ask us to limit what we use or share
You can ask us not to use or share certain protected health information for treatment, payment, or our operations. If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurance. We are not required to agree to your request.

Get a list of those with whom we’ve shared your information
You can ask for a list of the times we’ve shared your protected health information with outside organizations or individuals in the six years prior to your request. This list must include the date we shared the information, a description of the information we shared, who we shared it with, and why. We will include all the times we’ve shared your information, except for when it was about treatment, payment, and health care operations, and certain other disclosures (such as you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this HIPAA Notice
You can ask for a paper copy of this HIPAA Notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you
If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your protected health information. We will verify the person has this authority and can act for you before we rely on any decisions made by this person.

File a complaint if you feel your rights are violated
You can complain if you feel we have violated your rights by contacting us using the information on page 2. You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, or calling (877) 696-6775. Complaints will in no way affect how we care for you. We will not retaliate against you for filing a complaint.

Your Choices
For certain protected health information, you can tell us your choices about what we share. If you have a clear preference for how we share your protected health information, in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions. In these cases, you have the right and choice to tell us to:

• Share protected health information with your family, close friends, or others involved in your care
• Share protected health information in a disaster relief situation

If you are not able to tell us your preference, for example if you are unconscious, we may share your information to the extent permitted by law.

Our Uses and Disclosures
How do we typically use or share your protected health information? We typically use or share your health information in the following ways without your written authorization:

Treatment
We may use or disclose your protected health information to provide you with medical treatment or services and, to the extent permitted by law, share it with other professionals who are treating you. Example: A provider treating you for an injury asks another provide about your overall health condition.

Payment
We can use or share your protected health information to bill and obtain payment from health plans or other entities for care that you receive. This may include certain activities that your health insurance plan may undertake before it approves or pays for the health services, such as making a determination of eligibility or coverage for insurance benefits, reviewing services provided to you for medical necessity; and undertaking utilization review activities.

Health care operations
We can use and share your protected health information to run our organization, improve your care, contact you when necessary, and to train our staff and students. Example: We use protected health information about you for certain administrative, financial, legal, quality assessment and improvement, accreditation, credentialing and training activities.

Business associates
We may share your protected health information with third parties we contract with to provide certain products or services on our behalf. We usually call them “business associates.” Business associates are required by law to safeguard your information in the same way we do.

How else can we use or share your health information?
We can share protected health information about you for certain situations such as:

• Preventing or controlling disease and managing epidemics
• Helping with product recalls
• Reporting adverse reactions to medications
• Reporting of events that we are required or permitted to report
• Preventing or reducing a serious threat to anyone’s health or safety 

Comply with the law
We will share protected health information about you if state or federal law requires it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.

Work with a medical examiner
We can share protected health information with a coroner, medical examiner, or funeral director when an individual dies.

Workers’ Compensation, law enforcement, and other government requests
We can use or share protected health information about you for workers’ compensation claims, with law enforcement officials, with health oversight agencies, and for special government functions such as military, national security, and presidential protective services as required by law.

Respond to lawsuits and legal actions
We can share protected health information about you in response to a court or administrative order, discovery request, or in response to a subpoena.

When UGL Health is required to obtain authorization to use or disclose your health information
Except for the situations listed above, any other use or disclosure of your health information requires us to obtain your specific written authorization.

Special Situations
Some types of health information are specially protected under state or federal law and those laws may impose more restrictive requirements on disclosure of this information, even for purposes described above. When those more restrictive laws apply, we may need your specific written authorization to release these types of health information, even in some cases, for the purpose of treatment, payment, and health care operations. The types of health information that are subject to additional restrictions include HIV test results, and information related to treatment for mental illness, developmental disability, or alcohol or drug abuse.

Authorization Required for Certain Uses of Disclosures
We must obtain your written authorization for most uses or disclosures of the following: (1) psychotherapy notes; (2) uses or disclosures of your health information for marketing purposes; (3) disclosures of your health information in exchange for direct or indirect remuneration to UGL Health. Federal and state law requires certain substance use disorder records (“Part 2 Records”) to be kept confidential. Written consent is usually needed to share Part 2 Records, with some exceptions (medical emergencies, research, audits, public health, court orders, etc.). Part 2 Records may be shared with your consent for treatment, payment, healthcare operations, and program coordination. Please note that if your information is disclosed under this HIPAA Notice, it may be subject to redisclosure by recipients.

Withdrawing authorization
If you sign an authorization form, you may withdraw your authorization at any time, as long as your withdrawal is in writing. If you wish to withdraw your authorization, please submit your written withdrawal to our Health Information Management Department at medicalrecords@uglhealth.org or by calling your local clinic phone number. Please understand that we cannot take back any disclosures that were made before you withdrew your authorization.

Our Commitment
We are required by law to:

• Maintain the privacy and security of your protected health information.
• Promptly notify you if a breach occurs that may have compromised the privacy or security of your information.
• Follow the duties and privacy practices described in this HIPAA Notice and give you a copy of it. Not use or share your information other than described in this HIPAA Notice unless you tell us we can. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

Changes to the Terms of this HIPAA Notice
We can change the terms of this HIPAA Notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in our office, and on our website.

Contact Information
Upper Great Lakes Family Health Center
Attention: Privacy Officer
135 E M-35, Gwinn, MI 49855
HIM@uglhealth.org

Other Instructions for this HIPAA Notice

• Effective Date of this Notice: 04/29/2026
• UGL Health participates in a Medicare Accountable Care Organization (ACO). This means that certain health information may be shared with the ACO for care coordination and quality improvement purposes.
• We electronically exchange health care information to facilitate access to health and/or mental health information that may be relevant to your care. For example, if you were admitted to a hospital on an emergency basis and cannot provide important information about your health condition, health information exchanges allow us to make your medical information available to those who need it to treat you. Access to your health and/or mental health information is readily available, when needed, which means better care for you. You have the right to opt-out of the health information exchange by notifying the Front Office of your clinic.
• We participate in an arrangement to help facilitate health information that may be needed to provide you with care. As part of this arrangement, we have agreed to store health information of our patients in a jointly shared electronic medical record with other health care provider participants in this arrangement. When it is needed, this shared electronic medical record will provide participants with access to health information essential to providing you with medical care. The need for this could occur, for example, if you were admitted to a hospital on an emergency basis and you were unconscious and could not provide important information about your health condition. Each participant in the shared electronic medical record has implemented policies and procedures governing appropriate access to health information in the shared electronic medical record in accordance with state and federal law. Any access to your health information that we store in the electronic medical record by non-UGL Health participants will only be made for the purposes described in this notice.
• By accessing your Healow patient portal account, you have the ability to view online, download, and share your health information.

Applicability of this HIPAA Notice
This HIPAA Notice applies to UGL Health in our capacity as a covered entity health care provider subject to HIPAA and to the entities in our affiliated covered entity. The HIPAA Notice also covers the privacy practices of all other providers approved to practice at UGL Health clinics.  For a complete list of UGL locations and providers, please visit our website at www.uglhealth.org.

Who is not covered by this notice
This notice does not apply to care you receive from other providers in their personal offices or at other locations than the sites described on our website. Your providers may have their own policies and procedures that apply to your health information that they record or maintain outside of UGL Health. You should review your provider’s notice for information on how they will handle your health information outside of UGL Health sites.

NOTICE OF PRIVACY PRACTICES OF UGL HEALTH SUBSTANCE USE DISORDER TREATMENT PROGRAMS. Effective Date of this Part 2 Programs Notice: February 16, 2026

Part 2 Programs
In addition to the privacy protections afforded to all medical records under HIPAA, there is another federal law that provides additional confidentiality protects for substance use disorder records (“Part 2”).

Certain UGL Health facilities and/or departments operate substance use disorder programs under Part 2. This notice is intended to provide patients with UGL Health’s summary of the laws and regulations governing substance use disorder treatment records protected under Part 2. To the extent applicable state law is even more stringent than Part 2 on how we may use or disclosure your Part 2 Records, we will comply with the more stringent law.

This Part 2 Notice
This notice describes:

• How Part 2 Records may be used and disclosed
• Your rights and respect to your Part 2 Records
• How to file a complaint concerning a violation of the privacy or security of your Part 2 Records, or of your rights concerning your Part 2 Records

You have the right to obtain a paper or electronic copy of this Part 2 Notice upon request and to discuss it with our Privacy officer at the contact information listed below if you have questions.

How We May Use and Share Your Part 2 Records
We will obtain your written consent to use and disclose your Part 2 Records unless we are permitted to use and disclose such records without your written consent by Part 2. You may revoke your written consent in writing, except to the extent that our Part 2 Program or other lawful holder of the information has already acted in reliance on your consent, and subject to limitations described below for disclosures to the criminal justice system. You may revoke the consent by contacting the Health Information Department at HIM@uglhealth.org or by calling your local clinic phone number. The following are examples of circumstances where Part 2 allows use and disclosure of your Part 2 Records with your written consent.

Designated Person or Entities
We may use and disclose your Part 2 Records in accordance with consent to any person or category of persons identified or generally designated in the consent. For example, if you provide written consent naming your spouse or health care provider, we will share your information with them as provided in your consent.

Consent for Treatment, Payment, or Health Care Operations
We may use or disclose your Part 2 Records with your consent for treatment, payment, or health care operations. The written consent may be a single consent for all future uses and disclosures for treatment, payment, and health care operations purposes, until such time as the consent is revoked by you. Organizations who received your information for these purposes are required by law or contract to protect your information as required by federal law protecting Part 2 Records or by HIPAA. Recipients who are required to protect your information as required by HIPAA may share your information only as allowed by HIPAA except that they may not re-disclose information for civil, criminal, administrative, and legislative proceedings against you.

Central Registry or Withdrawal Management Program
We may disclose your Part 2 Records to a central registry or any withdrawal management or treatment program for the purpose of preventing multiple enrollments, with your written consent. For example, if you consent to participating in a drug treatment program, we can disclose your information to the related program to coordinate care and avoid duplicate enrollment.

Criminal Justice System
We may disclose information from your Part 2 Records to those people within the criminal justice system who have made your participation in a Part 2 Program a condition of the disposition of any criminal proceedings against you. The written consent must state that it can be revoked upon the passage of a specific amount of time or occurrence of a specific, ascertainable event. The time or occurrence upon which consent becomes revocable may be no later than the final disposition of the conditional release or other action in connection with which the consent was given. For example, if you consent, we can inform a court-appointed officer about your treatment status as part of a legal agreement or sentencing conditions.

PDMPs
We may report any medical prescribed or dispensed by us to the applicable state prescription drug monitoring program as required by state law. We will first obtain your consent to disclose Part 2 Records to a prescription drug monitoring program prior to reporting such information.

The following is a summary of the limited circumstances under which we may acknowledge your presence or disclose your Part 2 Records, or information from your Part 2 Records to individuals outside of the Part 2 Program without your written consent.

Qualified Service Organizations
We may disclose your Part 2 Records to our qualified services organizations to the extent necessary for these organizations to provide services to or on behalf of the Part 2 Program.

Reporting Certain Criminal Conduct
We may disclose to law enforcement the following information about certain criminal conduct committed by you:

• Information related to a suspected criminal conduct committed by you on the premises of a UGL Health facility;
• Information related to the suspected criminal conduct committed by you against UGL Health personnel; and
• Reports of suspected abuse and neglect made under state law to the appropriate state or local authorities.

Medical Emergencies
We may disclosure your information to medical personnel to the extent necessary during a medical emergency if you are unable to provide prior authorization of the disclosure. We may also disclose your identifying information to medical personal of the Food and Drug Administration (“FDA”) who assert a reason to believe that your health may be threatened by an error in the manufacture, labeling, or sale of a product under FDA jurisdiction, and that the information will be used for the exclusive purposes of notifying patients or their physicians of potential dangers.

Audit and Evaluations
We may disclose information to others for specific audits or evaluations. This includes those who provide financial assistance to UGL Health or those who conduct audits and evaluations required under federally funded health care programs and federal agencies who oversee those programs.

Persons Involved in Your Care
Depending on your age and mental capacity, we may be allowed to disclose certain information to your legally authorized representative (such as a parent of a minor or court appointed guardian), for payment purposes. Your legally authorized representative may be allowed to authorize disclosures of your information.

Deceased Patients
We may disclose your information relating to cause of death under laws which require the collection of death or other vital statistics or permitting inquiry into the cause of death. For other disclosures where authorization is required, we may disclose your information if authorization was given by an executor, administrator, or other personal representative appointed under applicable state law. If there is no such appointed representative, the authorization may be given by the patient’s spouse or, if none, by any responsible member of the patient’s family.

Judicial Proceedings
We may disclose information about you in response to a court order and subpoena that comply with the requirements of the regulations and other applicable law. However, Part 2 Records, or testimony about your records, cannot be shared in any civil, administrative, criminal, or legislative proceedings against you unless you provide specific written consent, or a court issues an appropriate order. Your Part 2 Records will only be used or disclosed based on a court order after notice and an opportunity to be heard is provided by you, the organization, or other holder of the Part 2 Record in accordance with Part 2. A court order authorizing use of disclosure of Part 2 Records must be accompanied by a subpoena or other similar legal mandate compelling disclosure before the Part 2 Records may be used or disclosed. We will ask for your written consent before using or disclosing your Part 2 Records for situations not described in this Part 2 Programs Notice. You may revoke your written consent at any time.

Communications within Part 2 Program and UGL Health
We may use or disclose information between or among personnel having a need for the information in connection with their duties that arise out of the provision of diagnosis, treatment, or referral for treatment of alcohol or drug abuse, provided that such communication is either within the Part 2 Program, or between the Part 2 Program and UGL Health with your written consent. For example, our staff, including doctors, nurses, and other clinicians, will use your health information to provide your treatment care. Your health information may be used in connection with billing statements we send you and in connection with tracking charges and credits to your account. We may also use your health information to check for eligibility for insurance coverage and prepare claims for your insurance company where appropriate. We may use and disclose your health information in order to conduct our health care business and to perform functions associated with our business activities, including accreditation and licensing.

Violations of Laws and Regulations
A violation of the federal law and regulations governing the confidentiality of substance use disorder records is a crime. Suspected violations may be reported to the Substance Abuse and mental Health Services Administration Center for Substance Abuse Treatment at 5600 Fishers Lane, Rockville, MD 20857 or (240) 276-1660 or to the US Attorney for the district in which the violation occurred.

Your Rights as a Patient in the Program
As a patient in a UGL Health Part 2 Program, you have certain rights with regard to your Part 2 Records, in addition to those rights described in our HIPAA Notice:

• You have a right to request restrictions of disclosures made with your prior consent for purposes of treatment, payment, and health care operations. We will review your request but are not required to agree unless the request relates to sharing information with your insurance provider and your care has already been paid for by another source. If we agree to your request, we may still share your information where needed for emergency care or where required by law.
• You have a right to request and obtain restrictions on disclosures of Part 2 Records to your health plan for those services for which you have paid in full.
• You have the right to an accounting of disclosures of electronic records of your care by a UGL Health Part 2 Program to people outside our program for the past 3 years. Additionally, if you provided consent to share your information for treatment through a health information exchange, care management organization, or other intermediary, you have a right to a list of disclosures by an intermediary for the past 3 years.
• You have the right to obtain a paper or electronic copy of this notice upon request. You may also find this notice on our website.
• You have a right to file a complaint to UGL Health’s Privacy Officer, listed below, and the Secretary of the Department of Health and Human Services. For directions on how to contact the Secretary, please contact the Privacy Officer whose contact information is listed below. You will not be retaliated against for filing a complaint.

Our Commitment
The UGL Health Part 2 Programs are required by law to maintain the privacy of Part 2 Records, to provide patients with notice of its legal duties and privacy practices with respect to such records, and to notify affected patients following a breach of unsecured records.

The UGL Health Part 2 Programs are required to abide by the terms of this Notice currently in effect. We reserve the right to make changes to this Part 2 Programs Notice at any time, and any changes will apply to all Part 2 Records we maintain. If we make changes to how we manage your Part 2 Records, we will change this Notice and update it on our website.

If you have any questions about this Part 2 Programs Notice or your privacy, you may contact the Privacy Officer:

Upper Great Lakes Family Health Center
Attention: Privacy Officer
135 E M-35, Gwinn, MI 49855
HIM@uglhealth.org