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Life Lines                                                  August 2018

Using Gmail for your private practice? Why you may want to rethink it.

During a recent conversation with some fellow counselors, the topic of email came up. One mentioned that they were surprised to learn that they should not be using Gmail for their primary private practice email. It was news to a few others in the group who were using Gmail for their practice email. Unfortunately, these counselors were making themselves vulnerable to HIPAA violations (and possible large fines) without even knowing it.

Most counselors are aware of needing to abide by the Health Insurance Portability and Accountability Act (HIPAA) standards for protecting sensitive patient data by making sure their notes are secure and not disclosing confidential information without a client's signed consent form. However, HIPAA also applies to email communications (as well as text and instant messaging). Therefore, clinicians are required to take reasonable steps to protect clients' protected health information (PHI) from their computer to the client's inbox.

So, how does this apply to Gmail? Well, if PHI is transmitted via a Gmail account, Google has access to that information. In fact, Google reports that they scan emails for advertising purposes (ever wonder about how targeted those ads are?) and, although it's unlikely, Google's employees can see your emails. That makes Google a Business Associate to your private practice. The good news is that you can sign a Business Associate Agreement (BAA) with Google to obtain legally binding assurances for the safety of the data transmitted via email. The bad news? Google will not sign a BAA for unpaid accounts. In fact, Google's terms of service explicitly prohibit sending PHI via their email. That makes Gmail non-compliant with HIPAA regulations.

Then, what can you do? If you'd like to continue to use Google, you can pay for GSuite and then sign the BAA with Google. This BAA covers Gmail, Google Calendar, Google Drive, and several other Google Apps (not Google Voice...that's another article). This will also give you an even more professional email address, as you can use your practice name as the domain name (e.g., PrivatePractice@gmail.com vs YourName@PrivatePractice.com). In addition to having a BAA, getting written consent from your clients before communicating with them via email is essential. It's a great idea to make sure that your service agreement includes a policy on electronic communication. You should also add an automatic email signature as a reminder for recipients to delete an email if it not meant for them and that email is not a secure communication method.

There are other secure email and messaging services available, as well. In my practice, I like to use the client messaging feature on my EHR software that communicates with my clients in their secure, HIPAA-compliant portal. Although I follow the recommendations above, my client's email is not always secure on their end, especially if they use a work email address, and I prefer all my client communication and information in one spot. Do your research to find the best platform for your private practice needs.

Curious to know more about legal issues in private practice, including more information on HIPAA compliance? Stay tuned to the upcoming MMHCA Workshop schedule for future dates of our Legal Issues in Counseling workshop.
Raeleen Davis, MA, LPC, NCC
Treasurer MMHCA
Napoleon Harrington and Jim Blundo with NBCC Executives at AMHCA Leadership Conference on August 1st in Orlando, FL.
Greetings to all of you across the great state of Michigan.  
As the summer closes and we begin to embrace another fall, we too are entering new phases of our strategic plan and looking forward to some great things.  As President I am excited to continue to represent mental health counselors across the state and work with an outstanding team to execute the mission, vision and objects of the Michigan Mental Health Counselors Association.  Our team has been working diligently to improve many facets of our profession, right here at home through advocacy, training, networking and much more.  

During the summer Executive team members  represented Michigan at the American Mental Health Counselors Association's National Conference.  We learned of the national priorities for improving the quality of care and access to care in our profession, and how we can assist the national priorities at the state level.  We also were invited to present at the conference, and share with the other states what types projects and activities that we have done in order to help make our MMHCA successful.  The workshop was facilitated by Jim Blundo and it was titled "Getting Your Chapter in Order; the Michigan Model".  We had a wonderful response to the information presented and several invitations to help with improving other state chapters.  We also have a presence on AMHCA National Committees as well as serving in leadership support capacity.

One of our major priorities over the last year has been to continue to recruit and retain members to MMHCA.  Many of you that have been aware of this has helped us in tremendous ways.  Every message you shared through social media, every email, and every word you shared in person - we say thank you.  Our membership team is finding good success with the efforts you've helped us with.  For those that are not yet members or need to renew; don't hesitate to explore our website and click the membership link.  There you'll find the pertinent information of how to support us in our continual efforts of protection and advocacy for our license.  
Thank you Michigan for your encouragement, contributions, and service to MMHCA, we appreciate and need each and everyone of you!  We've got plenty of work to do. 

Napoleon Harrington MA, NCC, LPC 
Michigan Mental Health Counselors Association- President
Leadership Oakland, 28th Class-Alumni & President
Ambassador Counseling & Resource Group
Founder/Therapist/Counseling Supervisor

September 14 Breakfast Networking Meeting at Leon's Family Dining in Dearborn
September 28 Human Trafficking Workshop at Spring Arbor University in Spring Arbor
October 5 Human Trafficking Workshop at Bellbrook in Rochester Hills
October 12 Human Trafficking Workshop at Baker College in Clinton Township
October 13 Counseling Practice With Less Legal Risk at Great Lakes College in Lansing
October 19 MMHCA Annual Meeting at Brick Street Bar & Grille in Grand Blanc
November 2 Breakfast Networking Meeting at Leo's Coney  Island in Sterling Heights
November 9 Human Trafficking Workshop at Baker College in Allen Park
November 16 Networking at Night at Theo & Stacy's Restaurant in Portage
November 17 Private Practice Workshop at Western  Michigan University
December 7 Breakfast Networking Meeting at Beggar's Banquet Restaurant in East Lansing
Bridging Initiative for Students and New Professionals
The Michigan Mental Health Counseling Association invites you to engage in the Bridging Initiative experience. This initiative is designed to help students and new professionals make connections and bridge the gap between the learners and mental health industry by providing:
- Opportunities to network with local industry professionals
- Discounted rates for MMHCA events and conferences
- Access to the complete library of Competency building workshops, webinars and trainings with new       
  workshops added monthly (starting October 2018)
- Virtual question and answer hotline with a library of FAQs
We would like to hear from you! 
Forward your comments or questions, and suggestions of ways we may provide support for your student to new professional journey, to Dr. Katherine E. James at mmhcaBI@gmail.com
Join now at a discounted Bridging Initiative rate by contacting Dr. Katherine E. James at mmhcaBI@gmail.com.
July 25, 2018
The Bureau often receives complaints from individuals who are unable to obtain their medical records or about medical records that are mishandled by providers. We want to remind providers of the requirements to maintain and provide medical records.
Pursuant to Michigan law, MCL 333.16213, an individual licensed or registered under the Public Health Code must keep and maintain a record for each patient for whom they have provided medical services. Unless a longer retention period is required under federal or state laws or regulations, or by generally accepted standards of medical or professional practice, a licensee must keep and retain each record for a minimum of 7 years from the date of service for that patient. A licensee is obligated under statute to fulfill these requirements, even in the event a licensee sells or closes their practice, retires from practice, or otherwise ceases to practice.
A licensee that fails to comply with this requirement is subject to administrative action against their license, including a fine up to $10,000.00. Further details regarding a licensee's obligation to maintain patient records can be found here.
Executive Director Report
Out of My Mind
Where are you?
We send out emails to nearly 4500 counselors and other allied professionals on a regular basis. Of this number, only 450 pay annual dues. We need everyone to help promote, defend and advance the profession. This is in your best interest! Can this loyal and supportive group be the only committed professional in Michigan? My hope is no!
If you truly believe in what you do for a living than please help us help you.
MMHCA has built an association that is able to serve your needs unlike any other organization in Michigan. We are actively seeking your membership to promote you. This is what we have done and will continue to do for all counselors in Michigan.
Here are our results on behalf of counselors in Michigan:
  • Increased visibility as core providers along with our peers
  • Creating a living wage for many more than ever before
  • Greater exposure on social media. Please like us on Facebook
  • Effectively convincing the Michigan bureaucratic systems that we are capable and equal to all mental health professionals
  • Negotiated Diagnosis and reimbursement of fees for service with Blue Cross
  • Have a powerful lobbying firm to protect and advance our ability to provide services across the many specialties of counseling.
  • Created a nonprofit 501c3 (Michigan Mental Health Providers Association) to offer greater training opportunities and allow individuals and business to gift our association and enable us to offer programs for consumers.
  • Developed the Bridging Initiative to help Graduate Students and New Professional to improve their ability to succeed in the profession
  • Provided 33 Human Trafficking Training Workshops to date to fulfill the LARA requirement that all health professional must have training in-order to renew their license. (1800 plus counselors and social workers have taken our course. (Go to our mobile friendly website to find new dates and locations)
  • Workshops provided regionally this year across Michigan. These will be provided along with new offerings through 2019:
  1. Human Trafficking
  2. Billing and Coding
  3. Navigating the Blue Cross Reimbursement System
  4. Legal Issues
  5. Private Practice Development
  • We have held Networking Breakfasts in several locations across the state.
This event creates:
  1. a great face to face connection
  2. intangible added value to those attending
  3. Blue Cross Consultants provide information on how to navigate their reimbursement system
  4. update you on the latest public policy and legislation issues impacting your ability to practice
  5. great environment for sharing, job possibilities, supervision and internship needs, business opportunities, etc.
  6. The goal of one a month is in sight. Membership in MMHCA is not required to attend.
Legislative and Public Policy Initiatives:
They will be advising us on relevant public policy issues and providing our extensive lobbying needs
  • Introduced legislation to update the LPC License with the intent of creating Portability
  • On the national level we advocated for inclusion of counselors in the Medicare System. We are still fighting!
  • Promoted counselor employability within the Department of Health and Human Services System
  • Identifying funding within State and National grants to work on mental health, opioid addiction, and other specialized programs
Please try us out for a year and see what a $100 per year buys you. The next step is up to you. Go to our mobile friendly website to join. www.mmhca.org 
Like us on Facebook!
James Blundo, LPC, CCMHC, NCC
MMHCA Executive Director
Ms Donna Craig, JD

On October 13th we will be presenting another workshop on legal matters and private practice. The presenter is Donna Craig, JD. Her credentials and experience are impeccable. She has represented both counselors and nurses with LARA, Board of Counseling and in the courts. Donna is very knowledgeable and now a consultant for MMHCA members. 

Jeremy S. Norwood, MA, PHd, JD 
Dr. Jeremy Norwood is currently an Associate Professor and serves as Chair of the Department of Sociology, Global Studies, and Criminal Justice at Spring Arbor University.  In addition to completing his doctoral dissertation on human trafficking indicators amongst migrant farmworker populations in Western Michigan, he has helped to train thousands of professionals from several fields.   
All health professionals licensed in Michigan are required to have a course in Human Trafficking in order to renew their license. This law was passed by the state legislature with oversight by the Department of Licensing and Regulation (LARA). We are offering seven workshops around the state through May of this year to meet this requirement. There will be more workshops offered in the fall and in 2019. 6 CEU's provided for LLPC/LPC, Social Workers, and CAADC. All health professionals are welcome. Register at: www.mmhca.org
New Michigan Law Requires Training In Human Trafficking!
Upcoming Human Trafficking Workshops 
September 28 at Spring Arbor University
October 5 at Bellbrook in Rochester Hills
October 12 at Baker College in Clinton Twp
November 9 at Baker College in Allen Park

More Information and Online Registration on www.mmhca.org.
Human Trafficking Information
There has been much confusion regarding the required training standards by the new Michigan Law regarding Human Trafficking.
It is difficult to determine what you are obligated to take to meet the state requirements.  If your only goal is to meet the minimum standards, then our training is probably not for you.
MMHCA decided to offer the best workshop available based on the laws outlined. We created the best possible training available. Here is how we did it.
Dr. Jeremy Norwood who is on the faculty at Spring Arbor University was approached to develop the workshop. He used the stated language from the bill and developed an outline. We then looked at his extensive knowledge of the topic and decided to have him produce a powerful workshop based on his knowledge and experiences.
In addition to his extensive work in this arena, every year he takes a group of students to Asia to study Human Trafficking. Dr. Norwood is presently in Cambodia with a group of students studying the sociological impact and its connection to US trafficking.
Those that have taken the workshop describe it as powerful and intense. They walk away with a greater understanding of the major impact and possible strategies for intervention.
Please consider our offering. It will change your life for the better. In addition, it qualifies for 6 hours of CEU's and a certificate to prove your participation.
We encourage health professionals and graduate students to use our workshops for the best quality training in Michigan.

Michigan Mental Health Counselors Association

Newsletter by:
Cindy S. Goldman, MEd, LPC, NCC
MMHCA Member at Large