Notice of Privacy Practices
Effective Date: July 8, 2026
THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU OR YOUR CHILD MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Participation Pathways is committed to protecting the privacy of health information. This Notice of Privacy Practices explains how Participation Pathways may use and disclose protected health information, your rights regarding that information, and our legal duties to protect it. This Notice applies to occupational therapy services, consultation services, intake information, records review, evaluation information, appointment-related information, and other health information maintained by Participation Pathways.
Participation Pathways is operated by:
Rosalyn Johnson, MOT, OTR/L
Pediatric Occupational Therapy & Consultation
Email: hello@participationpathways.com
Phone: 916-515-7524
Website: participationpathways.com
For privacy-related questions, contact:
Privacy Contact: Rosalyn Johnson, MOT, OTR/L
Email: hello@participationpathways.com
Phone: 916-515-7524
Our Legal Duties
Participation Pathways is required by law to:
Maintain the privacy and security of protected health information.
Provide this Notice explaining our privacy practices.
Follow the terms of the Notice currently in effect.
Notify affected individuals if there is a breach of unsecured protected health information.
Not use or disclose protected health information except as permitted or required by law.
Protected health information may include information about a child’s occupational therapy needs, developmental history, evaluation results, consultation records, school participation concerns, service recommendations, appointment information, billing information, and other information that can identify the child or family.
How We May Use and Disclose Health Information
Participation Pathways may use and disclose protected health information for treatment, payment, and health care operations without written authorization, as permitted by HIPAA and applicable law.
Treatment
Participation Pathways may use and disclose health information to provide, coordinate, or manage occupational therapy services and related consultation. Examples may include:
Reviewing intake information.
Conducting an occupational therapy evaluation.
Providing parent consultation.
Reviewing records and preparing recommendations.
Communicating with caregivers or authorized representatives.
Coordinating with other providers, educators, or team members when appropriate authorization or legal permission exists.
Preparing documentation related to occupational therapy services.
Payment
Participation Pathways may use and disclose health information for payment-related purposes. Examples may include:
Creating invoices.
Processing payment.
Documenting services provided.
Communicating about account status.
Providing information needed for payment processing or reimbursement, if applicable.
Participation Pathways may be private-pay, insurance-based, or a combination depending on the services offered. Payment practices may change over time.
Health Care Operations
Participation Pathways may use and disclose health information for health care operations. Examples may include:
Scheduling and appointment management.
Quality review and service improvement.
Documentation review.
Business planning and administration.
Professional consultation.
Legal, accounting, compliance, or insurance-related activities.
Technology and security operations.
Training and supervision, when applicable.
Appointment Reminders and Service Communications
Participation Pathways may use contact information to send appointment reminders, scheduling updates, forms, administrative messages, or service-related communications. Communications may occur by phone, email, secure scheduling platform, or other approved methods.
Participation Pathways may use HIPAA-enabled Acuity Scheduling for appointment scheduling, secure intake forms, agreements, and appointment-related communication when appropriate protections and agreements are in place. Regular Squarespace website forms are not used to collect protected health information. Acuity’s HIPAA guidance states that Acuity can support HIPAA-related use, while other Squarespace tools, including regular form blocks, cannot be used as part of a HIPAA-compliant solution.
Business Associates
Participation Pathways may disclose protected health information to business associates who perform services on our behalf, such as scheduling, technology, billing, administrative support, legal, accounting, or compliance services. Business associates are required to protect health information according to applicable privacy and security requirements.
Uses and Disclosures Required or Permitted by Law
Participation Pathways may use or disclose protected health information when required or permitted by law. These uses and disclosures may include:
Reporting suspected abuse, neglect, or exploitation.
Responding to court orders, subpoenas, or legal process.
Complying with health oversight activities.
Responding to public health requirements.
Reporting certain injuries or threats as required by law.
Cooperating with law enforcement when legally required or permitted.
Responding to workers’ compensation or similar programs, if applicable.
Preventing or reducing a serious and imminent threat to health or safety.
Complying with federal, state, or local law.
California also has medical privacy laws, including the Confidentiality of Medical Information Act and other patient access and privacy laws. The California Attorney General describes several state laws that protect health information privacy.
School, Educational, and IEP-Related Information
Participation Pathways may receive or review school-related records, such as IEP documents, school evaluations, teacher input, therapy reports, or educational records. These records may be protected by different privacy laws depending on where they originated and who maintains them. Participation Pathways will use and disclose school-related records only as permitted by law, authorization, consent, or professional obligation.
Please do not send IEP documents, evaluation reports, medical records, or child-specific school concerns through general website forms or general email unless you have been directed to an appropriate secure method.
Parents, Guardians, and Personal Representatives
For pediatric services, parents, legal guardians, or other legally authorized representatives may generally act on behalf of a minor child with respect to health information, unless limited by law. Participation Pathways may request documentation of legal authority when needed.
In some situations, state or federal law may limit what information can be shared with a parent, guardian, or representative. Participation Pathways will follow applicable law.
Uses and Disclosures Requiring Written Authorization
Participation Pathways will obtain written authorization before using or disclosing protected health information for purposes not otherwise permitted by law.
Written authorization is generally required for:
Disclosures to people or organizations not involved in care, payment, or operations unless otherwise permitted by law.
Sharing records with schools, providers, advocates, attorneys, or other third parties when authorization is required.
Marketing communications when authorization is required by law.
Sale of protected health information.
Uses or disclosures of psychotherapy notes, if applicable.
You may revoke an authorization in writing at any time, except to the extent Participation Pathways has already relied on the authorization.
Marketing and Sale of Information
Participation Pathways will not sell protected health information. Participation Pathways will not use protected health information for marketing purposes when written authorization is required, unless written authorization has been obtained.
Highly Sensitive Information
Certain types of information may receive additional protections under federal or state law. This may include information related to mental health, substance use disorder treatment, reproductive health care, communicable diseases, genetic information, or other sensitive information. Participation Pathways will follow applicable federal and state privacy laws when handling sensitive information.
Your Rights Regarding Health Information
You have certain rights regarding protected health information. Some rights may be exercised by a parent, legal guardian, or authorized representative on behalf of a minor child, subject to applicable law.
Right to Inspect and Receive a Copy
You have the right to request access to inspect or receive a copy of protected health information maintained by Participation Pathways. Requests must be made in writing. Participation Pathways may charge a reasonable, cost-based fee when permitted by law.
Participation Pathways may deny access in limited circumstances permitted by law. If access is denied, you may have the right to request a review of the denial.
Right to Request an Amendment
You have the right to request an amendment to health information if you believe it is incorrect or incomplete.
Requests must be made in writing and should explain the reason for the requested amendment.
Participation Pathways may deny the request in certain circumstances, such as when the information is accurate and complete, was not created by Participation Pathways, is not part of the records maintained by Participation Pathways, or is not available for inspection.
If a request is denied, you may submit a written statement of disagreement.
Right to an Accounting of Disclosures
You have the right to request a list of certain disclosures of protected health information made by Participation Pathways. This right does not apply to all disclosures. For example, it generally does not include disclosures for treatment, payment, health care operations, disclosures made with authorization, or certain other disclosures excluded by law.
Requests must be made in writing.
Right to Request Restrictions
You have the right to request restrictions on how Participation Pathways uses or discloses protected health information for treatment, payment, or health care operations. Participation Pathways is not required to agree to all requested restrictions.
If Participation Pathways agrees to a restriction, we will follow it unless the information is needed for emergency treatment or the restriction is otherwise limited by law.
Right to Restrict Certain Disclosures to Health Plans
If you pay out of pocket in full for a service and request that Participation Pathways not disclose information about that service to a health plan for payment or health care operations, Participation Pathways will honor the request when required by law.
Right to Request Confidential Communications
You have the right to request that Participation Pathways communicate with you in a specific way or at a specific location. For example, you may request communication by phone rather than email, or at a specific phone number.
Requests must be reasonable and may need to be made in writing.
Right to Receive a Paper or Electronic Copy of This Notice
You have the right to receive a paper or electronic copy of this Notice at any time.
This Notice is also available on the Participation Pathways website.
Right to Be Notified of a Breach
You have the right to be notified if there is a breach of unsecured protected health information that affects you or your child.
Complaints
You may file a complaint if you believe your privacy rights have been violated.
You may contact Participation Pathways directly:
Privacy Contact: Rosalyn Johnson, MOT, OTR/L
Email: hello@participationpathways.com
Phone: 916-515-7524
You may also file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights.
Participation Pathways will not retaliate against you for filing a complaint.
Our Responsibilities
Participation Pathways is responsible for:
Protecting the privacy and security of protected health information.
Following the terms of this Notice.
Notifying affected individuals if required following a breach of unsecured protected health information.
Making this Notice available on request.
Posting this Notice on the Participation Pathways website.
Updating this Notice when privacy practices change.
HHS states that covered entities must make a Notice of Privacy Practices available to anyone who asks and prominently post it on a website that provides information about services or benefits.
Changes to This Notice
Participation Pathways may change the terms of this Notice at any time. Changes may apply to health information already maintained by Participation Pathways and to information received in the future. When changes are made, Participation Pathways will update the effective date and post the revised Notice on the website.
Questions
For questions about this Notice or privacy practices, contact:
Participation Pathways
Rosalyn Johnson, MOT, OTR/L
Pediatric Occupational Therapy & Consultation
Email: hello@participationpathways.com
Phone: 916-515-7524
Website: participationpathways.com
This Notice is provided for informational and compliance purposes and should be reviewed periodically to ensure it reflects current Participation Pathways privacy practices and applicable law.