Notice of Privacy Practices

Personal Courage, LLC
2040 Raybrook St. SE, Suite 300, Grand Rapids, MI 49546
Phone: 616-287-3218 (relay users dial 711) | Fax: 616-239-2820 | Email: admin@findyourpersonalcourage.com

Effective date: October 13, 2026. Version 1.

Free language help and disability aids are available to clients, parents, guardians and companions who need them to communicate with us. See the last section of this notice.

About this notice

This notice explains how Personal Courage, LLC ("we") uses and shares health information about you, and your rights over it. It covers all health information we hold about you from the moment we receive it, including what you tell us when you first contact us through our website inquiry form, by phone or by text, whether or not you become a client. It applies to in-person and telehealth care.

We will ask you to confirm in writing that you received this notice.

Michigan law gives your therapy extra protection

Our clinicians are licensed by the State of Michigan, and Michigan law makes what you share with them confidential and privileged. This is stricter than the federal privacy law (HIPAA), and we follow whichever law protects you more. In general, we share information about your therapy only:

• with your permission, or that of a person with legal authority to act for you;
• in the supervision of your clinician that Michigan law requires; or
• to meet a legal duty that Michigan law places above confidentiality, such as reporting suspected child abuse or warning of a threat of violence.

How we use and share information for your care

Your consent at intake

When you start services, we ask for your written consent to share with your health plan what it needs to pay for your care. The same consent lets us use your information to review the quality of our care and run the practice.

Treatment

Your clinician uses your information to plan your care. If your clinician holds a limited license (LLMSW), the licensed master's social worker who supervises them reviews your care, as Michigan law requires. We share information with others who treat you, such as your doctor, only with your written permission. For example, your therapist may then talk with your doctor about how poor sleep is affecting your mood.

Payment

We send your health plan (Medicaid, Medicare or a private plan) claims that show your name, the date and type of each service and a diagnosis code. With your permission, before your first appointment we may check your coverage, which tells the plan you asked about care with us.

Running the practice (health care operations)

We use information to run the practice and improve our care: for example, review of your care by the Clinical Director, record reviews, staff training, scheduling, billing and handling a concern you raise.

Companies that work for us

Outside companies, such as our health record system, telehealth platform and email, receive information only as needed to work for us. Each must sign a written agreement (a business associate agreement) to protect it.

If you are at serious risk of harming yourself

With the agreement you sign at intake, if your clinician believes you are at serious and immediate risk of harming yourself, the clinician may contact emergency services, a crisis team or a person you named for this purpose at intake. The clinician shares only what that person needs to help keep you safe. For teens, see "Children and teens".

Family and others

We share information with a family member, a friend or another person involved in your care, or in paying for it, only when you tell us we may.

When we share without your permission

Federal law allows sharing without permission for some public purposes. Michigan's law is stricter, so we share without your permission only in these situations.

Suspected child abuse or neglect. Our clinicians must report it immediately to the Michigan Department of Health and Human Services, even when a teen who started therapy on their own tells us. Michigan law may also require us to give relevant records to a state caseworker investigating the report.

Suspected abuse of a vulnerable adult. Our clinicians must report immediately when they suspect that an adult who cannot protect themselves, because of an impairment or advanced age, is being abused, neglected or exploited. If the report is about you, we tell you promptly, unless that could put you at risk of serious harm. We do not tell a representative we believe is responsible.

Threats of violence. If you tell your clinician of a threat of physical violence against a person who can be identified, and you appear to intend and be able to carry it out soon, Michigan law requires the clinician to act. The clinician will arrange hospital care, or try to warn the person and tell the police. If that person is a minor or incompetent, the clinician also tells the Michigan Department of Health and Human Services and the person's parent or guardian.

Courts, legal demands and police. We release information in response to a subpoena, court order or other legal demand, or to the police, only with your written permission, when a judge orders it or when a law requires it and Michigan law allows it. Examples are the warning above and the laws under "Oversight and other laws".

Oversight and other laws. Agencies that oversee health care, such as the Michigan Department of Licensing and Regulatory Affairs (LARA) and Medicaid and Medicare auditors, may ask to review records. We share with them, or under any other law that requires sharing, only with your permission or when a law requires it and Michigan's confidentiality law allows it. We share only as much as that law requires.

Other public purposes. Federal law would also allow sharing without permission for the purposes below. We share for these only with your written permission, or when a law requires it and Michigan law allows it:

• public health activities
• health research
• coroners, medical examiners and funeral directors
• organ and tissue donation
• military and veterans' matters
• national security and protection of officials
• correctional institutions
• workers' compensation claims
• disaster relief

Uses that need your written permission

• Psychotherapy notes. Some clinicians keep notes, apart from your record, that analyze what was said in sessions. Almost any use or sharing of them needs your written permission. Federal law gives you no right to see them, but you can ask your clinician or the Privacy Officer about them. Your regular record, including your diagnosis, treatment plan and progress, is yours to see and copy.
• Marketing and sale. We do not use or share your information for marketing, and we do not sell it. Either would need your written permission.
• Any other use not described in this notice needs your written permission.

You can take back (revoke) a permission at any time by telling the Privacy Officer in writing. This stops future sharing but does not undo past sharing. You can give permission on our release form or on Michigan's standard behavioral health release form (MDHHS-5515).

Information with special protection

Substance use disorder records. We are not a federally regulated substance use disorder treatment program. We may receive records from such a program, for example from a past provider. Substance use disorder treatment records we receive from programs subject to 42 CFR Part 2, or testimony describing what those records say, will not be used or shared in civil, criminal, administrative or legislative proceedings against you, unless you give written consent, or a court issues an order that meets the federal Part 2 rules together with a subpoena or similar legal demand.

HIV and AIDS information. Michigan law gives information about HIV and AIDS testing, care and treatment extra protection. We get your written permission before sharing it, except where the law allows otherwise.

Sharing outside the practice. Someone who receives your information and is not covered by federal privacy law may share it again, and federal privacy law may no longer protect it.

Children and teens

Consent. A parent or legal guardian must consent before therapy begins for anyone under 18. There are two exceptions: a teen seen without a parent (below) and a legally emancipated minor, who consents and uses these rights as an adult.

Children under 14. A parent or guardian usually uses the child's privacy rights. The clinician uses professional judgment about how much of what a child shares to pass on to parents, and explains this at intake. Parents can still ask for the child's records, with the limited exceptions under "See and get a copy of your records".

Teens 14 to 17 whose parent or guardian consents. From age 14, a teen's therapy is private. At intake we ask the parent or guardian to agree to this on our Parent or Guardian Agreement to a Teen's Privacy. If a parent or guardian does not agree, or later ends the agreement, the Clinical Director decides how care continues, and we tell the teen what will stay private. With the agreement:

• We share information from the teen's sessions with a parent or guardian only on our Teen's Authorization to Share Information. The teen signs it with clear, informed permission, and it says exactly what will be shared.
• Without it, a parent or guardian who consented and pays receives only what is needed to arrange and pay for care. That means appointment times they help arrange, plus estimates and bills listing services, dates and charges, with no diagnosis or clinical detail. Health plan statements come from the plan and may show a diagnosis code.
• The teen, not the parent, uses the rights in this notice for this care.
• We still share when the law requires it, such as a child abuse report or a warning about a threat of violence. If there is a serious risk that the teen will harm themselves, the clinician may tell a parent or guardian so they can help keep the teen safe. We explain both limits to the teen at the start.

Teens who ask to be seen without a parent. A teen 14 or older may ask to start therapy without a parent's or guardian's consent. The Clinical Director decides each request case by case. Michigan law allows this for outpatient therapy, up to 12 sessions or 4 months, whichever comes first. When a teen is seen this way:

• The teen controls the information and makes any privacy requests. The teen signs the acknowledgment of this notice and any releases.
• We do not tell a parent or guardian about the services without the teen's permission, unless the treating clinician finds a compelling need because of a substantial chance of harm to the teen or someone else. The clinician tells the teen first. Required child abuse reports still apply.
• A parent or guardian is not responsible for the cost. A parent's health plan may send the policyholder a statement, so we talk with the teen about payment before any claim is sent.

Separated and divorced parents. Michigan law does not let us deny a parent a child's records only because that parent does not have custody, unless a protective order bars it. The other rules in this section apply to every parent. Please give us copies of any custody, guardianship or protective orders.

Your rights

To use these rights, contact the Privacy Officer (see "How to reach us"). Please make requests about your records, or about how we contact you, in writing. Email, mail, fax and portal messages count as writing. If you call or tell us in person, we act on it right away and help you put it in writing.

See and get a copy of your records

• You can see and get a copy of your health and billing records, including any Good Faith Estimate, for as long as we keep them. Psychotherapy notes and information gathered for a legal proceeding are not included.
• You can have paper or electronic copies, in the format you ask for if we can readily produce it. We mail copies if you ask.
• We respond as soon as we can within the time the law allows. If you are ending services sooner, we respond before you finish. Any fee is reasonable, based on our cost and told to you first. Electronic copies are free.
• In rare cases we may refuse part of a request: for example, when a parent or other representative asks and a licensed clinician believes access is reasonably likely to cause substantial harm to you or someone else. We explain why in writing, give you the rest of the record and tell you how to ask for a review by a licensed clinician who was not involved.

Ask us to correct your records

• You can ask in writing for a correction of information you think is wrong or incomplete, and tell us why. If we agree, we correct the record and tell you and others who may rely on the old information, including anyone you name.
• If we say no, for example because the information is accurate and complete, we explain why in writing. You can then file a statement of disagreement, or ask that your request and our answer go with any future sharing of that information.
• Whatever our answer, you may add your own statement correcting or explaining information in your record, and it becomes part of the record.

Get a list of the times we shared your information

You can ask for a list (an accounting) of the times we shared your information in the 6 years before your request. It leaves out sharing for treatment, payment or operations, sharing you permitted and other kinds the law excludes. One list in any 12 months is free. For another, we may charge a reasonable cost-based fee, which we tell you first so you can change or withdraw your request.

Ask us to limit what we use or share

• You can ask us to limit what we use or share for treatment, payment or operations, or what we share with people involved in your care. We do not have to agree, except in the case below. If we agree, we follow the limit unless the information is needed for emergency treatment.
• Paid in full. If you, or someone other than your health plan on your behalf, pay in full for a service and ask us not to share information about it with your plan for payment or operations, we must agree, unless the law requires us to share it. Please ask before the service so that no claim is sent. If you have Medicare or Medicaid, billing rules may require a claim, so ask the Privacy Officer first and we will tell you what is possible.

Ask us to contact you privately

• Regular texts, email and voicemail are not fully private. You can ask us to contact you only in a certain way or at a certain place, such as only on your cell phone or by mail to another address. We say yes to all reasonable requests, and we do not ask why.
• Statements from your health plan (explanations of benefits) come from the plan, not from us. You can ask your plan to send them elsewhere. A plan must do so if you tell it that the usual place could put you in danger.

Get a paper copy of this notice

You can ask for a paper copy at any time, even if you agreed to get this notice electronically.

Choose someone to act for you

• A person with legal authority to make health care decisions for you, such as a guardian or a patient advocate named in a Michigan health care power of attorney, can use your rights for you. A patient advocate can act only after it has been decided in writing that you cannot take part in decisions about your treatment. After a client's death, the personal representative of the estate acts for the client.
• We may decline to treat someone, including a parent, as your representative if we reasonably believe that person has subjected or may subject you to abuse, neglect or domestic violence, or that treating them as your representative could endanger you, and we decide it is not in your best interest.

Complain without fear

• If you believe your privacy rights were violated, you can complain to the Privacy Officer (see "How to reach us"). If your complaint is about the Privacy Officer, our Clinical Director handles it.
• You can also complain to the U.S. Department of Health and Human Services, Office for Civil Rights: online at ocrportal.hhs.gov; by phone at 1-800-368-1019 (TDD 1-800-537-7697); by email at OCRComplaint@hhs.gov; or by mail at U.S. Department of Health and Human Services, Office for Civil Rights, 200 Independence Avenue, S.W., Room 509F, HHH Building, Washington, D.C. 20201. Complaints must be in writing, on paper or online, and are generally due within 180 days of when you knew, or should have known, about the problem. The Office can extend this for good cause.
• We will not retaliate against you for complaining.

Our duties

• The law requires us to keep your health information private, to give you this notice of our legal duties and privacy practices and to tell you if a breach of your unsecured health information occurs.
• We must follow the terms of the notice currently in effect.
• We keep your clinical record at least 7 years after your last date of service, or longer when a law or contract requires it. If the practice closes, we will tell LARA who holds the records.

Changes to this notice

We can change this notice, and the changes will apply to all information we have about you, including information we had before the change. Each new notice shows its effective date. We post it in our office and on our website, and you can ask us for a copy at any time.

How to reach us

For questions about this notice, to use your rights or to complain, contact our Privacy Officer (the Director of Operations and Client Services):

Personal Courage, LLC, 2040 Raybrook St. SE, Suite 300, Grand Rapids, MI 49546
Phone: 616-287-3218 (relay users dial 711) | Fax: 616-239-2820 | Email: admin@findyourpersonalcourage.com

Free language help and disability aids

Language help and disability aids are free. Personal Courage provides language help and disability aids free of charge when you, as a client, parent, guardian or companion, need them to communicate with us. This includes interpreters for other languages, American Sign Language (ASL) interpreters qualified under Michigan law and written information in other languages or in large print, braille or another format you can use. We arrange interpreters through a professional interpreting service, usually by phone or video. You never have to bring your own interpreter or pay for one.

To ask, call 616-287-3218 (relay users dial 711), email admin@findyourpersonalcourage.com or ask at the front desk. Please tell us before your appointment when you can, so we can have help ready. This notice is available in other formats on request.