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Compliance
HIPAA
 
Privacy Statement
 

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. This policy also describes how THE BRIDGE may use other information about you. Please review it carefully.

 

Who We Are: This Notice describes the privacy practices of THE BRIDGE, their employees (including counselors, nurses, and treatment aides), and other individuals that work at THE BRIDGE. (THE BRIDGE refers to the THE BRIDGE's residential substance abuse treatment centers, intensive outpatient centers, counselor offices, and other facilities.)

  1.   Our Privacy Obligations: Certain laws require THE BRIDGE to maintain the privacy of medical
      and health information about you ("Protected Health Information") and to provide you with this
      Notice of our legal duties and privacy practices with respect to Protected Health Information.
      When we use or disclose Protected Health Information, we are required to abide by the terms
      of this Notice (or other notice in effect at the time of the use or disclosure).
  2.   Uses and Disclosures with Your Consent or Your Authorization

                         A.  Use and Disclosure With Your Consent. As a condition of treatment, except in an emergency or other special circumstances, we will ask you to read and sign a written consent ("Your Consent") to our use and disclosure of Protected Health Information for purposes of treatment provided to you, obtaining payment for services provided to you, and for our health care operations (e.g., internal administration, quality improvement, and customer service), as detailed below:

                            §    Treatment. We use and disclose Protected Health Information to provide treatment and
      other services to you; for example, to diagnose and treat your injury or illness. In addition,
      we may contact you to provide appointment reminders or information about treatment
      alternatives or other health-related benefits and services that may be of interest to you.

                            §    Payment. We may use and disclose Protected Health Information to obtain payment for 
     services that we provide to you at a BRIDGE facility. For example, we may use or disclose
     Protected Health Information to claim and obtain payment from your health insurer, HMO,
     or other company that arranges or pays the cost of some or all of your health care ("Your
     Payer"), and to verify that Your Payer will pay for health care.

                           §    Health Care Operations. At THE BRIDGE, we use and disclose Protected Health
     Information for our health care operations, which include internal administration and
     planning and various activities that improve the quality and cost effectiveness of the care
     that we deliver to you.   

                        B.   Use or Disclosure with Your Authorization. As described above, Your Consent only permits us to use Protected Health Information for purposes of treatment, payment, and our health care operations. We may use or disclose Protected Health Information for any reason other than treatment, payment, and health care operations only when (1) you give us your authorization on our authorization form ("Your Authorization") or (2) there is an exception described in Section IV below.

  1.   Uses and Disclosures Without Your Consent or Your Authorization

                         A.Use or Disclosure For Treatment, Payment, and Health Care Operations Without Your Consent or Your Authorization. At THE BRIDGE, we may use or disclose Protected Health Information for purposes of treatment, obtaining payment, and our health care operations without Your Consent or Your Authorization under the following three circumstances: (1) when you require emergency treatment; (2) when we are required by law to treat you and we attempt to obtain Your Consent, but are unable to obtain it; and (3) when we attempt to obtain Your Consent but are unable to obtain it due to substantial barriers to communicating with you (e.g., you are unconscious or otherwise incapacitated) and we reasonably infer that you would have consented in the absence of the barriers.

                        B. Disclosure to Relatives and Close Friends. When you are present in a BRIDGE facility and are capable of communicating, we may use or disclose Protected Health Information to a family member, other relative, a close personal friend, or to any other person identified by you, if we (1) obtain your agreement; (2) provide you with the opportunity to object to the disclosure and you do not object; or (3) reasonably infer that you do not object to the disclosure.

If you are not present, or the opportunity to agree or object to a use or disclosure cannot practicably be provided because of your incapacity or an emergency circumstance, we may exercise our professional judgment to determine whether a disclosure is in your best interests. If we disclose information to a family member, other relative, or a close personal friend, we would disclose only information that is directly relevant to the person's involvement with your health care.

                        C. Fundraising Communications. We may contact you to request a tax deductible contribution to support important activities of THE BRIDGE. In connection with any fundraising, we may disclose to our fundraising staff demographic information about you (e.g., your name, address, and phone number) and dates of health care that we provided to you.

                        D. Marketing Communications. We may use or disclose Protected Health Information to identify health-related services and products that may be beneficial to your health and then contact you about the services and products. 

                        E. Public Health Activities. We may disclose Protected Health Information for the following public health activities and purposes: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury, or disability, as required by law and public health concerns; (2) to report child abuse and neglect to public health authorities or other government authorities authorized by law to receive such reports; (3) to report information about products under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk to contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work related illnesses and injuries or workplace medical surveillance.

                        F.  Victims of Abuse, Neglect, or Domestic Violence. We may disclose Protected Health Information without Your Consent or Authorization to a government authority, including a social service or protective services agency, authorized by law to receive reports of such abuse, neglect, or domestic violence, if we reasonably believe you are a victim of abuse, neglect, or domestic violence.

                        G.  Health Oversight Activities. We may disclose Protected Health Information to a health oversight agency that oversees the health care system and ensures compliance with the rules of government health programs such as Medicare or Medicaid.

                        H.  Judicial and Administrative Proceedings. We may disclose Protected Health Information in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

                        I. Law Enforcement Officials. We may disclose Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order.

                        J. Health or Safety. We may disclose Protected Health Information to prevent or lessen a serious and imminent threat to a person's or the public's health or safety.

                        K. Specialized Government Functions. We may disclose Protected Health Information to units of the government with special functions, such as the U.S. military or the U.S. Department of State.

                        L. Decedents. We may disclose Protected Health Information to a coroner or medical examiner as authorized by law.

                        M. Organ and Tissue Procurement. We may disclose Protected Health Information to organizations that facilitate organ, eye, or tissue procurement, banking, or transplantation.

                        N. Research. We may use or disclose Protected Health Information without your consent or authorization if our Institutional Review Board or Privacy Board approves a waiver of authorization for disclosure.

                       O.  Workers' Compensation. We may disclose Protected Health Information as necessary to comply with workers' compensation laws.

  1. Your Individual Rights

1.       For Further Information; Complaints. If you desire further information about your privacy rights, are concerned that we have violated your privacy rights, or disagree with a decision that we made about access to Protected Health Information, you may contact our Privacy Officer. You may also file written complaints with the Director, Office of Civil Rights of the U.S. Department of Health and Human Services. Upon request, the Privacy Office will provide you with the correct address for the Director. We will not retaliate against you if you file a complaint with the Director or us.

2.       Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of Protected Health Information (1) for treatment, payment, and health care operations, (2) to individuals (such as a family member, other relative, close personal friend, or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction.

3.       Right to Receive Confidential Communications. You may request, and we will accommodate, any reasonable written request for you to receive Protected Health Information by alternative means of communication or at alternative locations.

4.       Right to Inspect and Copy Your Health Information. You may request access to your medical record file, as well as your enrollment, payment, claims adjudication, case, medical management records, and your billing records maintained by us in order to inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. If you request a copy or copies of your record, you will be charged a cost-based fee for each copy.

5.       Right to Amend Your Records. You have the right to request that we amend Protected Health Information maintained in your medical record file, enrollment, payment, claims adjudication, case, medical management records, or billing records. We will comply with your request unless we believe that the information that would be amended is accurate and complete or other special circumstances apply.

6.       Right to Receive Paper Copy of This Notice. Upon request, you may obtain a paper copy of this Notice, even if you agreed to receive such notice electronically.

  1. Effective Date and Duration of This Notice

1.       Effective Date. This Notice describes the privacy policy of THE BRIDGE that will become effective on or before April 14, 2003, the date that federal law specifies for these protections of Protected Health Information. Prior to the effective date, THE BRIDGE will continue to protect your Protected Health Information as required by other applicable laws, regulations, and policies.

2.       Right to Change Terms of this Notice. We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all Protected Health Information that we maintain, including any information created or received prior to issuing the new notice. If we change this Notice, we will post the new notice in waiting areas around THE BRIDGE Facilities, and on our Internet site at http://www.bridgeinc.org. You also may obtain any new notice by contacting the Privacy Officer.

  1. Privacy Officer
You may contact the Privacy Officer at:

Privacy Officer The Bridge, Inc.,
3232 Lay Springs Road, Gadsden, AL 35904
E-mail: compliance@bridgeinc.org

 


Child Nutrition Program
Wellness Policy 18 19

Prison Rape Elimination Act (PREA)

What is PREA?

  • PREA addresses the detection, elimination and prevention of sexual
    assault in DYS facilities throughout Alabama.
  • PREA directs the collection and dissemination of information on the incidence of juvenile on juvenile sexual violence as well as staff sexual misconduct with juveniles in Alabama Department of Youth Services (ADYS) custody, or private providers contracting with ADYS, such as The Bridge.
Does PREA apply to The Bridge?
Yes, PREA applies to all Bridge residential programs contracted with the Alabama Department of Youth Services.


What is the evidence of The Bridge commitment to maintain a safe environment for juveniles?
The Bridge is committed to providing a safe environment for youth. All Bridge staff receive specialized training to ensure that this occurs through initial orientation and subsequent PREA refresher training topics.

When sufficient evidence exists, The Bridge does not hesitate to remove that employee and to support criminal prosecution of that employee.

How does PREA impact Bridge employees?  
PREA addresses the safety of juveniles while in a Bridge program - including sexual assault, sexual harassment, juvenile on juvenile sexual assault, and any sexual contact between staff and a juvenile whether or not the contact is alleged to be consensual. PREA pertains to the safety of juveniles or adjudicated offenders while in the custody of the criminal justice system including jail, detention, non-secure residential care, private contracted programs, and/or secure confinement. PREA also directs agencies to maintain data regarding juvenile on juvenile sexual assaults, nonconsensual sexual acts, and staff and juvenile sexual misconduct.
 
Can The Bridge be sued for not complying with PREA? 
No. PREA does not create any right to sue. However, there is an ethical responsibility to protect the safety of staff and those juveniles in custody. Failure to protect incarcerated juveniles can result in civil liability for the agency, supervisors, and staff, both personally and professionally.
 
What are the consequences for not complying with PREA? 
If The Bridge fails to comply with the PREA National Standards for juveniles, The Bridge will be removed as an eligible contract provider for ADYS residential programs.
 
Why should I be concerned with sexual misconduct at a facility?  
Sexual misconduct is not about sex, but about safety and security. Both are compromised whenever boundaries break down and a staff member becomes personal or intimate with a juvenile.

Staff sexual misconduct and juvenile on juvenile sexual assault undermines the mission of The Bridge by creating unstable living and working environments for the juveniles as well as their supervising staff members.
 
What about juveniles who either manipulate the system using PREA or make false allegations against staff?  
Staff are often concerned that addressing PREA-related issues in policy and procedure, and educating juveniles as to their right to be safe while in custody, may result in false accusations or false reports of staff misconduct. All allegations will be thoroughly and timely investigated and false allegations may be prosecuted.
 
 
What is The Bridge PREA Policy?
In compliance with Sections 115.311 and 115.322 of the Prison Rape Elimination Act (PREA) Standards, The Bridge has established a zero tolerance for incidents of juvenile sexual assault, rape or sexual harassment in any ADYS facility. The Bridge has implemented policies and procedures to ensure that the PREA Standards are upheld in all Bridge ADYS residential facilities. All allegations of sexual assault/harassment that meet the definitions of PREA are referred for investigations to the local Alabama Department of Human Resources and sheriff offices.
 
How do I report sexual abuse?
If you suspect sexual abuse has happened at a Bridge facility, you have several options for reporting.
  1. You may contact the PREA Compliance Staff:
PREA Program Manager- Angie Pate
Office Phone:  (256) 546-6324 x500
Gadsden Campus, 3232 Lay Springs Rd
Gadsden, AL 35904

PREA Coordinator- Kim Harden
Office Phone: (256) 546-6324 x229
Gadsden Campus, 3232 Lay Springs Rd
Gadsden, AL 35904
  1. If you prefer, you may call and report to the Sheriff or Police Department in the location where the allegations occurred. All reports are taken seriously and investigated as outlined in PREA and Bridge rules and procedures.
  2. You can report abuse by using a 3rd party form Click Here to download the form.
  3. Additionally, you may call and report to the Alabama Department of Youth Services ADYS PREA Coordinator at 334-215-3802; or you may call the ADYS Sexual Assault Hotline at 1-855-332-1594.
To whom does The Bridge report concerning PREA?
In compliance with PREA Standard §115.389 regarding publication of aggregated sexual abuse data, The Bridge is required to submit reports to the U.S. Department of Justice through the Survey of Sexual Violence Summary form.  The Bridge reports that on the 2012 U.S. Department of Justice Survey of Sexual Violence Summary form, The Bridge had no founded allegations of sexual abuse in our ADYS contract residential programs in 2012. The Bridge continues to educate all staff, students, contractors, and volunteers on PREA and the importance of protecting youth from sexual abuse. 

“In compliance with PREA Standard §115.389 regarding publication of aggregated sexual abuse data, The Bridge is required to submit reports to the U.S. Department of Justice through the Survey of Sexual Violence Summary form.  The Bridge reports that on the 2013 U.S. Department of Justice Survey of Sexual Violence Summary form, The Bridge had no founded allegations of sexual abuse in our ADYS contract residential programs in 2013. The Bridge continues to educate all staff, students, contractors, and volunteers on PREA and the importance of protecting youth from sexual abuse. “

How does the Bridge investigate abuse allegations?
POLICY
It is THE BRIDGE policy to ensure that an administrative or criminal investigation is completed for all allegations of sexual abuse, sexual assault, and sexual harassment. 
 
PROCEDURES 
  1. When THE BRIDGE conducts its own administrative investigations into allegations of sexual abuse and sexual harassment, it shall do so promptly, thoroughly, and objectively for all allegations, including third-party and anonymous reports. 
  2. The Program and QA Managers shall receive special training in sexual abuse investigations involving juvenile victims.
  3. THE BRIDGE shall refer all criminal investigations to the local law enforcement and department of human resource with jurisdiction to conduct such investigations.
  4. Investigators shall gather and preserve direct and circumstantial evidence, including any available physical and DNA evidence and any available electronic monitoring data; shall interview alleged victims, suspected perpetrators, and witnesses; and shall review prior complaints and reports of sexual abuse involving the suspected perpetrator. 
  5. THE BRIDGE shall not terminate an investigation solely because the source of the allegation recants the allegation. 
  6. The credibility of an alleged victim, suspect, or witness shall be assessed on an individual basis and shall not be determined by the person’s status as juvenile or staff. No facility shall require a juvenile who alleges sexual abuse to submit to a polygraph examination or other truth-telling device as a condition for proceeding with the investigation of such an allegation. 
  7. Administrative investigations shall include an effort to determine whether staff action or failures to act contributed to the abuse. All investigations shall be documented in written reports that include a description of the physical and testimonial evidence, the reasoning behind credibility assessments, and investigative facts and findings. 
  8. Investigations shall be documented in a written report that contains a thorough description of physical, testimonial, and documentary evidence and attaches copies of all documentary evidence where feasible. 
  9. Substantiated allegations of conduct that appears to be criminal shall be referred to law enforcement, department of human resources, and department of youth services for further investigation. 
  10. THE BRIDGE shall contact DYS service monitors and/or DYS community residential program administration, and DYS licensing authorities within 24 hours of any alleged sexual abuse incident. 
  11. THE BRIDGE shall retain all written reports for as long as the alleged abuser is incarcerated or employed by the agency, plus five years, unless the abuse was committed by a juvenile and applicable law requires a shorter period of retention.  
  12. The departure of the alleged abuser or victim from the employment or control of the facility shall not provide a basis for terminating an investigation.
  13. When outside agencies investigate sexual abuse, THE BRIDGE shall cooperate with outside investigators and shall endeavor to remain informed about the progress of the investigation. 
  14. At the conclusion of all PREA investigations, the Campus Administrator shall complete THE BRIDGE Investigative Outcomes of Allegations of Sexual Abuse/assault or Sexual Harassment and submit it to THE BRIDGE PREA Coordinator. 
  15. THE BRIDGE shall impose no standard higher than a preponderance of the evidence in determining whether allegations of sexual abuse or sexual harassment are substantiated.

PREA Audit Report Kennington 2016:
ALABAMA_KENNINGTON_ADDICTION_TREATMENT_CENTER_YEAR3CYCLE2.pdf



PREA Audit Report Mitchell 2017: 
ALABAMA_MITCHELL ADDICTION TREATMENT CENTER_YEAR1CYCLE2.pdf



Report Based on the Annual Survey of Sexual Violence for the Kennington ATC Program 2015-2018

Report Based on the Annual Survey of Sexual Violence for the Mitchell ATC Program 2015-2018

 
 
 
 
 
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