HIPAA NOTICE OF PRIVACY PRACTICES
Coherent Mind Trauma Counseling
DBA of Cimo Psychotherapy Services LLC
Effective Date: February 16, 2026
Privacy Officer: Dan Cimo, MSW, LCSW
Phone: (757) 231-5308
Email:dan@thecoherentmind.com
Your Information. Your Rights. Our Responsibilities.
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.
Your Rights
You have the right to:
Get a copy of your paper or electronic medical record
Correct your paper or electronic medical record
Request confidential communication
Ask us to limit the information we share
Get a list of those with whom we've shared your information
Get a copy of this privacy notice
Choose someone to act for you
File a complaint if you believe your privacy rights have been violated
Your Choices
You have some choices in the way that we use and share information as we:
Provide mental health care
Market our services and sell your information (we never do this)
Our Uses and Disclosures
We may use and share your information as we:
Treat you
Run our organization
Bill for your services
Help with public health and safety issues
Comply with the law
Address workers' compensation, law enforcement, and other government requests
Respond to lawsuits and legal actions
Your Rights
When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
Get an electronic or paper copy of your medical record
You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Submit your request in writing to our Privacy Officer.
We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
Under HIPAA, you do not have a right to access psychotherapy notes, and we are not required to provide copies of these notes.
Ask us to correct your medical record
You can ask us to correct health information about you that you think is incorrect or incomplete. Submit your request in writing to our Privacy Officer.
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, only by phone or only by mail) or to send communications 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 health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say "no" if it would affect your care.
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 insurer. We will say "yes" unless a law requires us to share that information.
This is particularly relevant to this practice because we are a private-pay practice and do not bill insurance directly.
Special protections may apply to substance use disorder treatment records.
Get a list of those with whom we've shared information
You can ask for a list (accounting) of the times we've shared your health information for six years prior to the date you ask, who we shared it with, and why.
We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). This includes certain disclosures of substance use disorder information as required by federal law.
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 privacy notice
You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
This notice is also available at www.thecoherentmind.com.
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 health information.
We will make sure the person has this authority and can act for you before we take any action.
File a complaint if you feel your rights are violated
You can complain if you feel we have violated your rights by contacting our Privacy Officer using the information at the top of this notice.
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, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
You may also file a complaint with the Virginia Board of Social Work at 9960 Mayland Drive, Suite 300, Henrico, VA 23233, by calling (804) 367-4441, or by visiting www.dhp.virginia.gov/boards/socialwork/.
Complaints regarding substance use disorder confidentiality may also be subject to federal enforcement laws.
We will not retaliate against you for filing a complaint.
Your Choices
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your 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 both the right and choice to tell us to:
Share information with your family, close friends, or others involved in your care
Share information in a disaster relief situation
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
In these cases we never share your information unless you give us written permission:
Marketing purposes
Sale of your information
Most sharing of psychotherapy notes
Note: This practice never markets or sells your personal information.
Our Uses and Disclosures
How do we typically use or share your health information?
We typically use or share your health information in the following ways. Certain records, including substance use disorder treatment records, may be subject to additional federal protections.
Treat you
We can use your health information and share it with other professionals who are treating you.
Example: We consult with your psychiatrist about medication that may support your therapy work.
Run our organization
We can use and share your health information to run our practice, improve your care, and contact you when necessary.
Example: We use health information about you to manage your treatment and services.
Bill for your services
We can use and share your health information to bill and get payment from health plans or other entities.
Example: As a private-pay practice, we provide you with superbills containing your name, dates of service, diagnosis codes, and procedure codes that you may submit to your insurance company for possible out-of-network reimbursement.
How else can we use or share your health information?
We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.
Help with public health and safety issues
We can share health information about you for certain situations such as:
Preventing disease
Reporting adverse reactions to medications
Reporting suspected abuse, neglect, or domestic violence
Preventing or reducing a serious threat to anyone's health or safety
Under Virginia law (VA Code § 63.2-1509), we are required to report suspected abuse or neglect of anyone under 18. Virginia law also requires us to report suspected abuse, neglect, or exploitation of adults age 60 or older, or incapacitated adults age 18 or older (VA Code § 63.2-1606). Under Virginia law (VA Code § 54.1-2400.1), if you communicate a specific and immediate threat to cause serious bodily injury or death to an identified person, we have a duty to take steps to protect that person, which may include warning the potential victim and notifying law enforcement.
Some types of records, including substance use disorder treatment records, may have additional restrictions on disclosure for public health and safety purposes.
Comply with the law
We will share information about you if state or federal laws require 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 or funeral director
We can share health information with a coroner, medical examiner, or funeral director when an individual dies.
Address workers' compensation, law enforcement, and other government requests
We can use or share health information about you:
For workers' compensation claims
For law enforcement purposes or with a law enforcement official
With health oversight agencies for activities authorized by law
For special government functions such as military, national security, and presidential protective services
Respond to lawsuits and legal actions
We can share health information about you in response to a court or administrative order, or in response to a subpoena. Certain substance use disorder treatment records may require additional legal processes before disclosure, as required by federal law.
Special Protections for Substance Use Disorder Records
Some health information related to substance use disorder diagnosis, treatment, or referral for treatment may be protected by additional federal confidentiality laws (42 CFR Part 2).
Where applicable, we will obtain your written consent before using or disclosing substance use disorder treatment records for treatment, payment, and health care operations, unless an exception applies.
Once disclosed with your consent for these purposes, federal law may permit the recipient to further use or disclose the information as allowed under HIPAA. However, these records cannot be used in legal proceedings against you without your specific written consent or a court order.
You have the right to revoke your consent for these disclosures at any time, except to the extent that we have already acted in reliance on it.
Special Protection for Psychotherapy Notes
Psychotherapy notes are notes recorded by a mental health professional documenting or analyzing the contents of a counseling session, maintained separately from your clinical record. These notes receive special protection under HIPAA and require your specific written authorization before disclosure, with limited exceptions.
Psychotherapy notes do not include medication information, session start and stop times, treatment modalities and frequencies, clinical test results, or summaries of diagnosis, treatment plan, symptoms, prognosis, and progress.
Our Responsibilities
We are required by law to maintain the privacy and security of your protected health information.
We will let you know promptly, within 60 days, if a breach occurs that may have compromised the privacy or security of your information.
We must follow the duties and privacy practices described in this notice and give you a copy of it.
We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
How We Store and Protect Your Information
Your clinical records are maintained in Sessions Health, a HIPAA-compliant electronic health record system that uses encryption and secure servers to protect your information. We maintain Business Associate Agreements (BAAs) with all vendors who may access your protected health information, including:
Electronic health record provider (Sessions Health)
Telehealth platforms (Google and Zoom)
Email service (Paubox)
Payment processor (Ivy Pay, and in some cases Stripe)
Phone service (iPlum)
Payments are processed securely through Ivy Pay, a HIPAA-compliant and PCI-DSS compliant payment platform designed for healthcare providers. Your card information is stored securely by Ivy Pay and is not stored in our records.
Your records are maintained for at least six years following the date of our last session, then securely destroyed in accordance with Virginia law and professional standards.
Changes to the Terms of This Notice
We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available upon request, in your client portal, and on our website at www.thecoherentmind.com.
Contact Information
Coherent Mind Trauma Counseling
DBA of Cimo Psychotherapy Services LLC
Privacy Officer: Dan Cimo, MSW, LCSW
Address: 8401 Mayland Dr #7391, Richmond, VA 23294
Phone: (757) 231-5308
Email:dan@thecoherentmind.com
Website:www.thecoherentmind.com
Compliance Statement
This Notice of Privacy Practices is provided in compliance with:
Health Insurance Portability and Accountability Act of 1996 (HIPAA), 45 CFR Part 164
Health Information Technology for Economic and Clinical Health Act (HITECH)
Confidentiality of Substance Use Disorder Patient Records, 42 CFR Part 2 (as amended February 16, 2026)
Virginia Health Records Privacy Act, VA Code § 32.1-127.1:03
Virginia Board of Social Work Regulations, 18 VAC 140-20