Notice of Privacy Practices

Effective date: October 1, 2026

1. Who this notice applies to

This notice applies to CMHS Psychiatry Group, PLLC, doing business as Comprehensive Mental Health Solutions ("the Practice," "we," "us," or "our"), and to all of its psychiatrists, psychiatric nurse practitioners, and other licensed prescribers, nurses, medical assistants, staff, and contractors. The Practice provides psychiatric evaluation, medication management, and SPRAVATO® (esketamine) treatment.

We see patients in person at:

• 51 Cherry Street, Milford, CT 06460 (main office)
• 57 Plains Road, Milford, CT 06461

We also provide telehealth visits to patients located in Connecticut.

Your psychiatric record is kept in our electronic health record, Osmind, and you can reach it through the Osmind patient portal and app. This notice covers your health information in any form: electronic, paper, or spoken.

A note about our two organizations

Therapy services are provided by a separate legal entity, Comprehensive Mental Health Solutions LLC. The two organizations share office locations and our phone number, but each keeps its own records and has its own Notice of Privacy Practices. If you receive care from both, you will receive both notices.

Comprehensive Mental Health Solutions LLC provides management, scheduling, billing, and administrative support to the Practice under a business associate agreement, which requires it to protect your information the same way we do.

2. Our responsibilities

The law requires the Practice to:

• keep your protected health information (PHI) private and secure
• give you this notice of our legal duties and privacy practices
• follow the terms of the notice currently in effect
• tell you promptly if a breach occurs that may have compromised the privacy or security of your information

Your health information is protected by the federal HIPAA Privacy Rule and by Connecticut law. Connecticut gives mental health records more protection than HIPAA does. Where Connecticut law or another federal law is stricter than HIPAA, we follow the stricter rule. Section 5 explains the most important of these protections.

3. How we use and share your information for treatment, payment, and operations

We use and share health information to provide your care, get paid for it, and run our practice. For mental health records, Connecticut law allows these uses without your written consent only in limited ways. When Connecticut law requires your consent, we ask for it in writing as part of your intake paperwork.

Treatment

We use your information to evaluate you, prescribe and monitor medication, and provide SPRAVATO® treatment. For example, we send prescriptions electronically to your pharmacy, review your medication history through e-prescribing networks, order lab tests, and coordinate with a therapist at Comprehensive Mental Health Solutions LLC who is also treating you. Under Connecticut law, we may share information with other people directly involved in your diagnosis or treatment when needed for your care, and we will tell you when we have done so. To share information with an outside provider, such as your primary care doctor, we ask for your written consent.

Payment

We use and share information to bill and collect payment for your care. For example, we send your health plan the information it needs to process a claim, such as your name, dates of service, the services provided, and your diagnosis code. We may also share information to check your eligibility or get prior authorization. Connecticut law limits what we may share for billing to what is needed to get paid.

Health care operations

We use information to run the practice and improve care. For example, we review records for quality and compliance, train and supervise clinicians, and work with our attorneys, accountants, and auditors. We share only what is needed for the task.

Business associates

We work with outside companies that handle information for us, such as our electronic health record (Osmind), patient portal, telehealth platform, e-prescribing service, secure messaging and phone system, online intake forms, email, and claims processing. Each signs a business associate agreement that requires it to protect your information as HIPAA requires.

Appointment reminders and care-related messages

We may contact you by phone, text message, email, or portal message to remind you of appointments, follow up on your care, or tell you about treatment options and services we offer. You can ask us to contact you a different way (see Section 7).

4. Other ways we may share your information without your authorization

Federal law allows the uses and disclosures below without your written authorization. For mental health information, we make these disclosures only when Connecticut law also allows them, and we share only the minimum needed.

• Required by law. When a federal, state, or local law requires it.
• Abuse and neglect reporting. Our clinicians are mandated reporters. We report suspected abuse or neglect of a child, an older adult, or a person with an intellectual disability to the agency the law designates.
• Serious threat to health or safety. If we believe there is a substantial risk of imminent physical harm to you or someone else, we may share information with people who can help prevent the harm, including law enforcement or the person at risk.
• Public health. To report disease, injury, or other information to public health authorities as the law requires.
• FDA and drug safety programs. To report medication side effects or product problems to the FDA or the manufacturer. SPRAVATO® can only be given through an FDA-required safety program (REMS). If you receive SPRAVATO®, we enroll you in the program and report required monitoring information to it.
• Prescription monitoring. Connecticut requires prescribers to review the Connecticut Prescription Monitoring and Reporting System (CPMRS) before prescribing certain controlled medications. Your pharmacy reports those prescriptions to the system.
• Health oversight. To government agencies that oversee health care, such as licensing boards, the Connecticut Department of Public Health, and Medicaid program auditors.
• Lawsuits and legal proceedings. Connecticut law protects mental health records in legal proceedings. We will not release your records in response to a subpoena alone. We need your written consent or a court order, unless a specific exception in Connecticut law applies.
• Law enforcement. Only when the law requires it, such as in response to a court order or warrant, or when needed to prevent a serious and imminent threat.
• Coroners and medical examiners. To identify a person who has died or determine a cause of death.
• Workers' compensation. As the law allows for workers' compensation claims, generally with your consent.
• Specialized government functions. For military command authorities if you are a member of the armed forces, or for national security and protective services, as the law requires.
• Correctional institutions. If you are an inmate of a correctional institution or in the custody of law enforcement, we may share information the institution needs to provide your care or protect the health and safety of you and others.
• Research. We do not conduct or take part in research using patient information.

Family members and others involved in your care

With your permission, we may share information with a family member, friend, or other person you name who is involved in your care or helps pay for it. If you are not present or cannot agree, such as in an emergency, we may share what that person needs to know if we believe it is in your best interest. We may also share information with disaster relief organizations to let your family know where you are and how you are doing.

De-identified information

We or our business associates may remove the information that identifies you, as HIPAA defines it. Information that no longer identifies you is not protected health information.

5. Information with extra protection

Connecticut mental health records

Connecticut law protects communications between you and your psychiatric providers and records of your psychiatric care (Connecticut General Statutes sections 52-146c through 52-146j, 52-146q, and 52-146s). In general, we need your written consent before we share these records, except in the limited situations those laws allow. These include sharing with others involved in your treatment, the minimum needed for billing, emergencies involving a risk of imminent harm, court-ordered evaluations, and reports the law requires.

Psychotherapy notes

Our clinicians document your care in progress notes, which are part of your health record and are protected under this notice and Connecticut law. We do not keep separate psychotherapy notes. Under HIPAA, psychotherapy notes are a clinician's private notes analyzing a counseling session, kept apart from the rest of the record. If we ever keep them, we will use or share them only with your written authorization, except in the narrow situations HIPAA allows, such as when the law requires it.

Substance use disorder records

We are not a substance use disorder treatment program. However, we may receive records of substance use disorder treatment from another provider. Records that come from a federally assisted treatment program are protected by a federal law, 42 CFR Part 2, in addition to HIPAA. If we receive these records, we will not use or share them, or testify about their content, in any civil, criminal, administrative, or legislative investigation or proceeding against you unless you give specific written consent or a court issues an order after you have been given notice and a chance to be heard. A court order used for this purpose must be accompanied by a subpoena or similar legal requirement to produce the records. If you have signed a general consent allowing a program to share your records for treatment, payment, and health care operations, we may use and redisclose those records as HIPAA allows, except in legal proceedings as described above.

HIV-related information

Connecticut law (C.G.S. 19a-583) requires your specific written consent before we disclose HIV-related information, except in limited situations the law allows.

Reproductive and gender-affirming health care

Connecticut law (C.G.S. 52-146w) limits our ability to disclose information about reproductive health care or gender-affirming health care in a civil action or proceeding, including requests connected to proceedings in other states, unless you give written consent or a listed exception applies.

Minors

We treat patients age 5 and older. For patients under 18, a parent or legal guardian is usually the minor's personal representative and may exercise the rights in this notice. Connecticut law (C.G.S. 19a-14c) allows a minor to consent to outpatient mental health treatment without a parent in certain situations. When a minor receives care on that basis, the minor controls the related information, and we will not share it with a parent without the minor's consent unless the law requires or allows it. Medication treatment generally requires the consent of a parent or guardian for patients under 18.

6. Uses that require your written authorization

We will ask for your written authorization before we:

• use or share psychotherapy notes, if we ever keep them, except as described in Section 5
• use or share your information for marketing
• sell your information. We do not sell health information.
• use or share your information in any way not described in this notice

We do not use your information for fundraising. You may revoke an authorization at any time by writing to our Privacy Officer. Revoking it stops future disclosures but does not undo anything we already shared while the authorization was in effect.

7. Your rights

To use any of the rights below, contact our Privacy Officer using the information in Section 10. We may ask you to make the request in writing, and we will verify your identity.

• See and get a copy of your record. You can ask to see or get a copy of your health and billing records, on paper or electronically. We will respond within 30 days. We may charge a reasonable, cost-based fee as the law allows. In limited cases, such as when a licensed clinician determines that access would likely endanger your life or physical safety or that of another person, we may deny part of a request. If we do, we will explain why in writing and tell you how to ask for a review.
• Ask us to correct your record. If you believe information in your record is incorrect or incomplete, you can ask us to amend it. We will respond within 60 days. If we say no, we will tell you why in writing, and you may submit a statement of disagreement to be added to your record.
• Ask for confidential communications. You can ask us to contact you in a specific way, such as only on your cell phone, or at a different address. We will agree to reasonable requests and will not ask why.
• Ask us to limit what we use or share. You can ask us not to use or share certain information for treatment, payment, or operations. We are not required to agree, but we will consider your request. If you pay for a service in full out of pocket, you can ask us not to share information about that service with your health plan, and we will agree unless the law requires us to share it.
• Get a list of those we have shared information with. You can ask for a list (an accounting) of the times we shared your information in the six years before your request, with whom, and why. The list does not include disclosures for treatment, payment, or operations, or disclosures you authorized. We provide one list a year for free and may charge a reasonable, cost-based fee for additional lists within 12 months.
• Get a copy of this notice. You can ask for a paper copy of this notice at any time, even if you agreed to receive it electronically.
• Choose someone to act for you. If you have given someone medical power of attorney, or someone is your legal guardian, that person can exercise your rights. We will confirm the person has this authority before we act.
• Be notified of a breach. We will notify you if a breach occurs that may have compromised the privacy or security of your information.
• File a complaint. See Section 10.

8. Email, text messages, and the patient portal

The most secure way to send us health information is through the Osmind patient portal and app. Regular email and text messages are not fully secure and can be read by others or sent to the wrong person. If you choose to communicate with us by regular email or text, we will understand that you accept that risk. You can ask us at any time to stop using email or text with you. Reply STOP to any text message, or call (203) 651-5117. Email and text messages are not monitored around the clock. Do not use them for an emergency.

9. Changes to this notice

We may change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available on request, in our offices, in the Osmind patient portal and app, and on our website at www.cmhsct.com. The effective date is shown on the first page.

10. Questions and complaints

If you have questions about this notice, want to use one of your rights, or believe your privacy rights have been violated, contact our Privacy Officer:

Elizabeth Laliberte
Compliance Manager and Privacy Officer
CMHS Psychiatry Group, PLLC, d/b/a Comprehensive Mental Health Solutions
51 Cherry Street, Milford, CT 06460
Phone: (203) 651-5117
Email: info@cmhsct.com

You can also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, 200 Independence Avenue SW, Washington, DC 20201, by calling 1-877-696-6775, or online at www.hhs.gov/ocr/complaints.

We will not retaliate against you for filing a complaint. Filing a complaint will not affect your care.

If you are in crisis or thinking about harming yourself, do not wait for a reply to an email, text, or portal message. Call or text 988, the Suicide & Crisis Lifeline, available 24 hours a day. In an emergency, call 911 or go to the nearest emergency room.

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Effective date: October 1, 2026

1. Who this notice applies to

This notice applies to Comprehensive Mental Health Solutions LLC ("CMHS," "we," "us," or "our") and to all of its therapists, clinical supervisors, and associate clinicians, staff, trainees, and contractors. CMHS provides individual therapy, couples therapy, EMDR, and related psychotherapy services.

We see patients in person at:

• 51 Cherry Street, Milford, CT 06460 (main office)
• 57 Plains Road, Milford, CT 06461

We also provide telehealth visits to patients located in Connecticut.

Your therapy record is kept in our electronic health record, TherapyNotes, and you can reach it through the TherapyPortal client portal. This notice covers your health information in any form: electronic, paper, or spoken.

A note about our two organizations

Psychiatric medication management and SPRAVATO® are provided by a separate legal entity, CMHS Psychiatry Group, PLLC, which also uses the name Comprehensive Mental Health Solutions. The two organizations share office locations and our phone number, but each keeps its own records and has its own Notice of Privacy Practices. If you receive care from both, you will receive both notices.

CMHS also provides management, scheduling, billing, and administrative support to CMHS Psychiatry Group, PLLC under a business associate agreement. When our staff handle psychiatry records in that role, they protect them under that agreement and the Psychiatry Group's notice.

2. Our responsibilities

The law requires CMHS to:

• keep your protected health information (PHI) private and secure
• give you this notice of our legal duties and privacy practices
• follow the terms of the notice currently in effect
• tell you promptly if a breach occurs that may have compromised the privacy or security of your information

Your health information is protected by the federal HIPAA Privacy Rule and by Connecticut law. Connecticut gives mental health records more protection than HIPAA does. Where Connecticut law or another federal law is stricter than HIPAA, we follow the stricter rule. Section 5 explains the most important of these protections.

3. How we use and share your information for treatment, payment, and operations

We use and share health information to provide your care, get paid for it, and run our practice. For mental health records, Connecticut law allows these uses without your written consent only in limited ways. When Connecticut law requires your consent, we ask for it in writing as part of your intake paperwork.

Treatment

We use your information to provide therapy and coordinate your care. For example, your therapist may consult with a clinical supervisor, or with a psychiatric prescriber at CMHS Psychiatry Group, PLLC who is also treating you. Under Connecticut law, we may share information with other people directly involved in your diagnosis or treatment when needed for your care, and we will tell you when we have done so. To share information with an outside provider, such as your primary care doctor, we ask for your written consent.

Payment

We use and share information to bill and collect payment for your care. For example, we send your health plan the information it needs to process a claim, such as your name, dates of service, the services provided, and your diagnosis code. We may also share information to check your eligibility or get prior authorization. Connecticut law limits what we may share for billing to what is needed to get paid.

Health care operations

We use information to run the practice and improve care. For example, we review records for quality and compliance, train and supervise clinicians, and work with our attorneys, accountants, and auditors. We share only what is needed for the task.

Business associates

We work with outside companies that handle information for us, such as our electronic health record (TherapyNotes), patient portal, telehealth platform, secure messaging and phone system, online intake forms, email, and claims processing. Each signs a business associate agreement that requires it to protect your information as HIPAA requires.

Appointment reminders and care-related messages

We may contact you by phone, text message, email, or portal message to remind you of appointments, follow up on your care, or tell you about treatment options and services we offer. You can ask us to contact you a different way (see Section 7).

4. Other ways we may share your information without your authorization

Federal law allows the uses and disclosures below without your written authorization. For mental health information, we make these disclosures only when Connecticut law also allows them, and we share only the minimum needed.

• Required by law. When a federal, state, or local law requires it.
• Abuse and neglect reporting. Our clinicians are mandated reporters. We report suspected abuse or neglect of a child, an older adult, or a person with an intellectual disability to the agency the law designates.
• Serious threat to health or safety. If we believe there is a substantial risk of imminent physical harm to you or someone else, we may share information with people who can help prevent the harm, including law enforcement or the person at risk.
• Public health. To report disease, injury, or other information to public health authorities as the law requires.
• Health oversight. To government agencies that oversee health care, such as licensing boards, the Connecticut Department of Public Health, and Medicaid program auditors.
• Lawsuits and legal proceedings. Connecticut law protects mental health records in legal proceedings. We will not release your records in response to a subpoena alone. We need your written consent or a court order, unless a specific exception in Connecticut law applies.
• Law enforcement. Only when the law requires it, such as in response to a court order or warrant, or when needed to prevent a serious and imminent threat.
• Coroners and medical examiners. To identify a person who has died or determine a cause of death.
• Workers' compensation. As the law allows for workers' compensation claims, generally with your consent.
• Specialized government functions. For military command authorities if you are a member of the armed forces, or for national security and protective services, as the law requires.
• Correctional institutions. If you are an inmate of a correctional institution or in the custody of law enforcement, we may share information the institution needs to provide your care or protect the health and safety of you and others.
• Research. We do not conduct or take part in research using patient information.

Family members and others involved in your care

With your permission, we may share information with a family member, friend, or other person you name who is involved in your care or helps pay for it. If you are not present or cannot agree, such as in an emergency, we may share what that person needs to know if we believe it is in your best interest. We may also share information with disaster relief organizations to let your family know where you are and how you are doing.

De-identified information

We or our business associates may remove the information that identifies you, as HIPAA defines it. Information that no longer identifies you is not protected health information.

5. Information with extra protection

Connecticut mental health records

Connecticut law protects communications between you and your therapist and records of your therapy (Connecticut General Statutes sections 52-146c through 52-146j, 52-146q, and 52-146s). In general, we need your written consent before we share these records, except in the limited situations those laws allow. These include sharing with others involved in your treatment, the minimum needed for billing, emergencies involving a risk of imminent harm, court-ordered evaluations, and reports the law requires.

Psychotherapy notes

Our clinicians document your care in progress notes, which are part of your health record and are protected under this notice and Connecticut law. We do not keep separate psychotherapy notes. Under HIPAA, psychotherapy notes are a clinician's private notes analyzing a counseling session, kept apart from the rest of the record. If we ever keep them, we will use or share them only with your written authorization, except in the narrow situations HIPAA allows, such as when the law requires it.

Substance use disorder records

We are not a substance use disorder treatment program. However, we may receive records of substance use disorder treatment from another provider. Records that come from a federally assisted treatment program are protected by a federal law, 42 CFR Part 2, in addition to HIPAA. If we receive these records, we will not use or share them, or testify about their content, in any civil, criminal, administrative, or legislative investigation or proceeding against you unless you give specific written consent or a court issues an order after you have been given notice and a chance to be heard. A court order used for this purpose must be accompanied by a subpoena or similar legal requirement to produce the records. If you have signed a general consent allowing a program to share your records for treatment, payment, and health care operations, we may use and redisclose those records as HIPAA allows, except in legal proceedings as described above.

HIV-related information

Connecticut law (C.G.S. 19a-583) requires your specific written consent before we disclose HIV-related information, except in limited situations the law allows.

Reproductive and gender-affirming health care

Connecticut law (C.G.S. 52-146w) limits our ability to disclose information about reproductive health care or gender-affirming health care in a civil action or proceeding, including requests connected to proceedings in other states, unless you give written consent or a listed exception applies.

Minors

We treat patients age 5 and older. For patients under 18, a parent or legal guardian is usually the minor's personal representative and may exercise the rights in this notice. Connecticut law (C.G.S. 19a-14c) allows a minor to consent to outpatient mental health treatment without a parent in certain situations. When a minor receives care on that basis, the minor controls the related information, and we will not share it with a parent without the minor's consent unless the law requires or allows it.

Couples therapy

In couples therapy, the record belongs to the treatment of both participants. We release a joint record outside the couple only with the written consent of both people, unless the law requires otherwise.

6. Uses that require your written authorization

We will ask for your written authorization before we:

• use or share psychotherapy notes, if we ever keep them, except as described in Section 5
• use or share your information for marketing
• sell your information. We do not sell health information.
• use or share your information in any way not described in this notice

We do not use your information for fundraising. You may revoke an authorization at any time by writing to our Privacy Officer. Revoking it stops future disclosures but does not undo anything we already shared while the authorization was in effect.

7. Your rights

To use any of the rights below, contact our Privacy Officer using the information in Section 10. We may ask you to make the request in writing, and we will verify your identity.

• See and get a copy of your record. You can ask to see or get a copy of your health and billing records, on paper or electronically. We will respond within 30 days. We may charge a reasonable, cost-based fee as the law allows. In limited cases, such as when a licensed clinician determines that access would likely endanger your life or physical safety or that of another person, we may deny part of a request. If we do, we will explain why in writing and tell you how to ask for a review.
• Ask us to correct your record. If you believe information in your record is incorrect or incomplete, you can ask us to amend it. We will respond within 60 days. If we say no, we will tell you why in writing, and you may submit a statement of disagreement to be added to your record.
• Ask for confidential communications. You can ask us to contact you in a specific way, such as only on your cell phone, or at a different address. We will agree to reasonable requests and will not ask why.
• Ask us to limit what we use or share. You can ask us not to use or share certain information for treatment, payment, or operations. We are not required to agree, but we will consider your request. If you pay for a service in full out of pocket, you can ask us not to share information about that service with your health plan, and we will agree unless the law requires us to share it.
• Get a list of those we have shared information with. You can ask for a list (an accounting) of the times we shared your information in the six years before your request, with whom, and why. The list does not include disclosures for treatment, payment, or operations, or disclosures you authorized. We provide one list a year for free and may charge a reasonable, cost-based fee for additional lists within 12 months.
• Get a copy of this notice. You can ask for a paper copy of this notice at any time, even if you agreed to receive it electronically.
• Choose someone to act for you. If you have given someone medical power of attorney, or someone is your legal guardian, that person can exercise your rights. We will confirm the person has this authority before we act.
• Be notified of a breach. We will notify you if a breach occurs that may have compromised the privacy or security of your information.
• File a complaint. See Section 10.

8. Email, text messages, and the patient portal

The most secure way to send us health information is through the TherapyPortal client portal. Regular email and text messages are not fully secure and can be read by others or sent to the wrong person. If you choose to communicate with us by regular email or text, we will understand that you accept that risk. You can ask us at any time to stop using email or text with you. Reply STOP to any text message, or call (203) 651-5117. Email and text messages are not monitored around the clock. Do not use them for an emergency.

9. Changes to this notice

We may change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available on request, in our offices, in the TherapyPortal client portal, and on our website at www.cmhsct.com. The effective date is shown on the first page.

10. Questions and complaints

If you have questions about this notice, want to use one of your rights, or believe your privacy rights have been violated, contact our Privacy Officer:

Elizabeth Laliberte
Compliance Manager and Privacy Officer
Comprehensive Mental Health Solutions LLC
51 Cherry Street, Milford, CT 06460
Phone: (203) 651-5117
Email: info@cmhsct.com

You can also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, 200 Independence Avenue SW, Washington, DC 20201, by calling 1-877-696-6775, or online at www.hhs.gov/ocr/complaints.

We will not retaliate against you for filing a complaint. Filing a complaint will not affect your care.

If you are in crisis or thinking about harming yourself, do not wait for a reply to an email, text, or portal message. Call or text 988, the Suicide & Crisis Lifeline, available 24 hours a day. In an emergency, call 911 or go to the nearest emergency room.

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