PRIVACY POLICY

Sage Disability places a high priority on protecting your privacy. This privacy policy was created to demonstrate the Sage Disability firm commitment to the privacy of our members and website users. This policy explains what types of information is collected by the Sage Disability websites www.sagedisability.com and how this information is used.

WHAT PERSONALLY IDENTIFIABLE INFORMATION IS COLLECTED

Sage Disability members that register for www.sagedisability.com and individuals that sign up to receive Sage Disability e-communications voluntarily provide us with contact information (such as name and email address). We may use this information for specific, limited purposes. You may always “opt out,” either now or at any time in the future, if you do not wish to receive our messages.

IP addresses:  Sage Disability uses your IP address to help diagnose problems with our server, to administer www.sagedisability.com, and for statistical metrics used to track website visitor traffic.

Cookies:  www.sagedisability.com uses “cookie” messages to automatically help provide better services. They remind us who you are and your preferences for our website based on what you’ve done and told us before. The “cookie” is placed in your computer and is read when you come back to our website. Cookies let us take you to the information and features you’re particularly interested in. They also let us track your usage of www.sagedisability.com, so we know which parts of our sites are most popular. You can reject cookies or cancel them by instructing your Web browser accordingly.

How Your Information May Be Used:  We use your personal information to provide you with personalized service; to send e-mail alerts to you; to answer your requests; to process your membership application; etc. You may choose to opt out at any time, which will cease all communications from us. We may also use your information to track visitors to our website. This lets us see which of our features are the most popular so we can better serve our users’ needs. It also lets us provide aggregate data about our traffic (not identifying you personally, but showing how many visitors used which features, for example) to outside parties.

Email Privacy:  Sage Disability does not sell or rent email addresses to anyone outside the organization.

External Links:  www.sagedisability.com includes links to external websites. These links do not fall under the www.sagedisability.com domain, and Sage Disability is not responsible for the privacy practices or the content of external websites. Your use of any linked website is solely at your own risk.

Modifications:  We may amend this privacy policy from time to time; please review it periodically. We maintain the option to modify this privacy at any time by electronic notice posted on our website. Your continued use of our website after the date that such notices are posted will be deemed to be your agreement to the changed terms.

PROTECTED HEALTH INFORMATION PRIVACY POLICY

The appropriate collection, use and disclosure of a client’s protected health information (PHI) is fundamental to assisting clients in the development and submission of Social Security disability claims. Protecting the privacy and the confidentiality of client PHI is of vital importance to Sage Disability and its staff. This policy explains the client’s rights and Sage Disability’s responsibilities regarding PHI. This policy explains how and why the client’s PHI is utilized, safeguards, limitations on disclosure, client consent and rights, information about applicable laws and how changes to this policy will be made available to the client. Sage Disability abides by its commitment to privacy and protection of client PHI. 

This policy applies to any and all information regarding a client’s PHI related to the client’s physical and mental health. A client’s PHI may include documents and information provided by the client, documents and information developed by Sage Disability to support a client’s Social Security disability claim, documents and information produced by medical professionals providing medical assessments to support the development of a client’s disability claim and administrative and billing information. PHI may include documents or information that identifies you, relates past, present and future physical and mental conditions, past and present diagnosis, test results, treatment and symptoms, present and future treatments and tests and administrative and billing information.

Sage Disability considers protection of PHI a vital priority and has developed and follows a set of policies to maintain appropriate protections. This policy reflects compliance with fair information practices, applicable laws and standards of practice. This policy is constructed around the following Principles of Privacy:

• Purpose of maintaining PHI. Sage Disability collects, maintains, and utilizes PHI for the purpose of assisting clients in the development of Social Security disability claims. PHI is the basis for any and all Social Security disability claims. Sage Disability’s ability to effectively advise and assist clients in the development of Social Security disability claims is predicated on access to PHI, ability to produce new documents based on that information, and consult with other medical and legal professionals about a client’s specific case. 
• Consent. Sage Disability’s possession and use of PHI is contingent on consent from the client. Consent to maintain and utilize PHI for the purpose of advising and assisting clients in the development of disability claims is assumed as a result of consent to the consulting services agreement, this privacy policy and by providing PHI to Sage Disability. 

Sage Disability may utilize and disclose PHI in accordance with the limitations of this policy without any further written consent. However, the client retains the right at any and all times to determine or change how their PHI is used and disclosed or request return and/or destruction of any and all PHI in Sage Disability’s possession. Any requests to remove consent or specific limitations on the possession and use of PHI must be submitted in writing (either electronically or by mail). Sage Disability will comply promptly with any client requests relating to consent and PHI. However, any limitations on the utilization and disclosure of PHI beyond the scope of this policy will significantly impact Sage Disability’s ability to provide advice and assistance and may create a situation where Sage Disability can provide no further assistance to a client.

• Limited Collection. Collecting and maintaining PHI is limited to information necessary to provide advice and assistance in the development of Social Security disability claims. Collection of past and present PHI is limited to that which is provided by the client. Sage Disability will not attempt in any way to gain additional past or present PHI through any other means than requests to the client. The only exception to this policy is if the client chooses to use a medical professional pre-identified by Sage Disability for a physical or mental health assessment as part of an individual claim strategy. In this case, Sage Disability may coordinate directly with said medical professional to obtain PHI. If the client chooses to use any other medical professional Sage Disability will coordinate solely with the client and will not attempt to contact said medical professional. THE CLIENT CONTROLS WHAT PHI IS PROVIDED TO SAGE DISABILITY. It is important for the client to understand that limitations on PHI provided to Sage Disability limits our ability to provide effective advice and assistance. Limited Use, Disclosure and Retention.

1. Limited Use: The client consents to Sage Disability’s limited use of PHI as follows: evaluate a client’s physical and mental health conditions to develop individual claim strategies, develop medical assessments to support a Social Security disability claim, make recommendations and schedule additional physical and mental health assessments, develop Social Security documents for claim submission. Sage Disability may also use PHI to support development of Sage Disability internal practices and procedures and to train staff. Sage Disability may also use any documents we have produced as templates to support claim development for other clients. Utilization of PHI for these purposes will separate an individual client’s identity from the information as an added level of protection. Sage Disability will always seek client consent (either electronically or in writing) before using or disclosing PHI for purposes beyond the scope of this privacy policy.
2. Limited Disclosure: Sage Disability will limit disclosure of PHI to the minimum necessary to support operations. PHI may be disclosed to selected Sage Disability employees to support development of a client’s disability claim and the conduct of Sage Disability operations. PHI may also be disclosed to selected medical, legal, Social Security Administration, Disability Determination Services, and other Social Security claim professionals for the sole purposes of gaining opinions, recommendations, peer review and quality control to support development of a client’s disability claim. Disclosure may also be made to medical professionals that are providing physical or mental health assessments to support development of a client’s disability claim. Any persons to whom PHI has been disclosed will comply with the accountability and safeguard provisions of this policy.

Disclosure of PHI pursuant to legal obligations may occur as required by state or federal entities which may include but is not limited to disclosure to government agencies for health oversight activities, licensing and auditing, when abuse or neglect is apparent, threats to health or safety or to prevent serious harm, court order or subpoena, coroners and medical examiners and national security matters. Any disclosure under this consideration will be limited to the minimum legal and statutory requirements. PHI will not be disclosed to family, friends or others without express permission from the client. Under no circumstances do we sell client lists or other protected information to third parties.

1. Limited Retention.  Sage Disability will only retain PHI for the duration of the consulting relationship which ends once all claims have been pursued and all consulting fees have been paid. Once the consulting relationship has ended PHI will be physically destroyed or electronically erased in accordance with industry standards for PHI protection. Sage Disability may retain copies of documents we have produced to serve as templates for development of other client claims. Any retained documents will remove any personal identifying information.

• Accountability. Sage Disability takes its commitment to securing client privacy very seriously. Every employee and third party associated with disability claim development and administrative functions of Sage Disability is responsible for the protected information under their control. All parties with access to PHI are informed about the importance of privacy and receive information and training periodically to update them about this privacy policy and related issues. Sage Disability is required by law to protect your health information and provide notification of any compromise of PHI. Sage Disability may need to make changes to this policy in the future to better protect PHI and remain in compliance with legal obligations. While a client, Sage Disability will provide notice of any changes to this policy and make available a copy for the client’s review.
• Safeguards: Protecting PHI. Sage Disability protects PHI with appropriate safeguards and security measures. 

1. Storage.  Sage Disability maintains PHI only as electronic files. All paper copies of records received are immediately scanned and stored electronically and the paper copies are destroyed by shredder. Electronic files are maintained on HIPAA compliant cloud-based storage. All electronic systems comply with industry standard security protocols. 
2. Access Control.  Access to PHI will be limited to employees and third parties directly involved in advising a client, developing claims and medical-legal evidence and administrative functions and only when required in the performance of their duties pursuant to the consulting services agreement. Hard copy paper files are controlled with physical safeguards and access procedures. Electronic files are controlled through pass-word security and access limitations based on each employee’s role and responsibilities. 
3. PHI Transmission. Sage Disability utilizes electronic transmission procedures in the conduct of operations. Sag Disability transmits documents electronically through email with password protection. Please remember that e-mail is not necessarily secure against interception. If communications are very sensitive, transmission should only be conducted through password protected files.
4. Confidential Communications. The client has the right to request confidential communications both in the manner and place of communications. The client may specify a particular means of communication (e.g. by email only) and a specific place (e.g. work phone only). The client may limit communications to specified individuals. Any requests for confidential communications must be made in writing (either electronically or by mail) and include all specified instructions. Sage Disability will grant all reasonable requests in a timely manner. 
5. Third Parties. Sage Disability may consult with third parties such as medical, legal and Social Security professionals to assist in the development of your claim. Any third parties are also bound by law and ethics to safeguard PHI and must agree to abide by this privacy policy. Any PHI provided to third parties is limited to the information necessary to perform the service for which they are engaged and will require that they not maintain or disclose the information for purposes other than that to which they are contracted.

• Access and Correction. 

1. Right to Access. The client maintains the right to access PHI maintained by Sage Disability.  Clients may request copies of PHI maintained by Sage Disability in writing (either electronically or by mail). Requests should designate how the client would like to receive copies (either electronically or by mail). Requests will be processed in a reasonable time after confirmation of identity.  Sage Disability may charge a fee for this service, and if so, will provide notice in advance of processing the request. 
2. Amendments and Corrections. The client maintains the right to request corrections to PHI created by Sage Disability if the client believes that any information is incorrect or incomplete. Any requests for corrections must be submitted in writing (either electronically or by mail) and must include the correction desired, reasoning for the correction, and any supporting evidence. Sage Disability is not required to agree to requested corrections relating to any opinions made in good faith. Sage Disability will provide its decision and reasoning for any requests for correction in writing. If the request is not granted, Sage Disability will include the request for correction and/or a statement of disagreement from the client in their file. Any corrections to PHI not created by Sage Disability must be addressed to the party that created the PHI, such as any medical professionals that provide physical or mental health assessments. Sage Disability does not have the authority to correct PHI provided by another party but can include statements of disagreement from the client. 
3. Disclosures. The client maintains the right to know to whom their PHI has been disclosed by Sage Disability pursuant to this policy. Upon request, Sage Disability will provide a list of parties to whom a client’s PHI has been disclosed.

• Challenging Compliance.  Sage Disability encourages clients to contact us with any questions or concerns they might have about their privacy or Sage Disability’s Privacy Policy. We will investigate and respond to any concerns about any aspect of our handling of PHI without any fear of repercussions. If the client is not satisfied with Sage Disability’s response or believes that their privacy rights have been violated, they may file a complaint with the U.S. Department of Health and Human Services. Instructions for how to file a complaint can be found at the following web address: https://www.hhs.gov/hipaa/filing-a-complaint/complaint-process/index.html.