Pious Practicians LLC Policies

Subscription Agreement & Non-Disclosure Policy

This Subscription Agreement outlines the terms and conditions governing you, the Care Partner(CP), subscription to Pious Practicians LLC (PP LLC) services. By subscribing, you agree to the following:

Subscription Terms:​

• Your subscription will continue indefinitely until you actively cancel the service or discontinue scheduled payments.

• You are responsible for the agreed-upon subscription fees, which will be billed according to your chosen billing cycle (monthly, quarterly, or annually).

Your subscription includes the following:

• Services include access to a PP for health/medical-related questions, support, explanation, and advocacy. It is expressly understood and agreed that no interactions with the PP will include diagnoses or treatments of medical conditions. Instead, experiences may be shared, and any advice or information provided by the PP is for informational purposes only.

• All interactions with your designated PP.

• Information and resources provided to you by your PP.

• Shared best practice interventions that align with the principles of the Hippocratic Oath as understood and applied by Registered Nurses, emphasizing a commitment to do no harm and practice faithfully.

• Advocacy, support, and management services tailored to your chosen subscription tier (Signature, Comprehensive, or Complex).

Support will be provided through the following communication methods:

• Phone or Zoom/Video calls

• Text messages

• Emails

• Provided documents containing shared information.

Response times will be prioritized as follows:

• Immediate attention will be given to medical emergencies.

• Following medical emergencies, priority will be given to Complex Plan holders, then Comprehensive Plan holders, and lastly, Signature Plan holders, on a first-come, first-served basis within each tier.

Non-Disclosure Policy

• You, the CP & PP LLC, commit to maintaining the strict confidentiality of all client information, including personal health information, shared during the course of our services. This obligation extends indefinitely beyond the termination of this agreement.

Cancellation & Service Modification Policy​

• You may cancel your subscription at any time.

• Upon cancellation, your access to the subscription service will cease on the last day of your current prepaid subscription period.

• No refunds will be provided for the remaining portion of a prepaid subscription period following cancellation.

Grace Period: A three (3) calendar day grace period is provided for delayed or missed payments, during which services will continue without interruption. Failure to remit payment within this grace period will result in the suspension or termination of services.

Service Modification Policy

• Subscribers may request to modify their service tier at any time.

• Requests to upgrade to a higher-tiered plan (e.g., from Signature to Comprehensive, or Comprehensive to Complex) will be accommodated, and any adjustments to fees will be communicated and implemented accordingly.

• Requests to downgrade to a lower-tiered plan (e.g., from Complex to Comprehensive, or Comprehensive to Signature) will be accommodated, and the change will take effect at the start of the next billing cycle.

Limitation of Liability & Care Partner Responsibility

Any advice, information, or support taken from the PP is entirely at the CP's sole responsibility and discretion. The PP and Pious PPs LLC,  are hereby released from any and all liability and outcomes related to such advice or information. It is understood and agreed by the CP that any advice or support received should be independently confirmed through the CP's own research or disclosed to and supported by the CP's physician, primary care provider (PCP), or specialty doctor.

Payment & Billing Policy

Subscription Fees:

• The subscription fees for our services will be negotiated and mutually agreed upon during the registration process.

• You will be charged a recurring monthly, quarterly, or annual fee based on your chosen billing cycle & negotiated cost.

Billing Cycle, Payment Methods, Failed Payments & Refunds:

• Your billing cycle will commence as agreed upon during registration.

• We accept any form of automatic and continuous payment method that is mutually agreed upon.

• In the event of a failed payment, individualized service in real-time will be discontinued at the end of paid billing cycle.

• Refunds or service adjustments will only be considered if an error in billing or payment was made by Pious PPs.

• No refunds will be issued for the allotted service period unless payment was made or overpaid in error.

• We are committed to addressing legitimate concerns while also ensuring the sustainability of our business operations.

Care Partner Privacy & Security Policy

This policy outlines how we collect, use, store, and protect the personal and medical information of our subscribers. We are deeply committed to maintaining the privacy and security of your information.

Information Collection and Use: We collect personal and medical information that you provide to us during the subscription process and throughout the provision of our services. This information is used to:

• By subscribing to Pious practicians LLC, you agree to all policies listed & revisions on the website. Authorization for Disclosure includes verbal consent from CP & interaction with their chosen healthcare providers. Sharing of information includes health care & insurance provided portals of patient information & data. Real-time communications & presence of your PP during hospital stays, clinic and other health related visits. Review of preparatory information provided by care providers in preparation for procedures, examinations & surgeries. Disclosure of any shared information will be consent verbally by the CP to family members or other disclosed persons, including specialists.

• Facilitate communication to best educate, advocate, research & best support your health management endeavors.

• Provide tailored advocacy, support, and management services.

• Share relevant information and resources.

• Maintain accurate records of our interactions and communicate with your care providers with your consent & presence.

• Improve the quality and delivery of our services.

Our Commitment to Non-Disclosure: We uphold the strictest standards of confidentiality. Your personal and medical information will not be disclosed to third parties without your explicit consent, except when required by law or for essential operational purposes (e.g., secure data storage). All our personnel are bound by confidentiality agreements. All information, including biographical and personal health information, disclosed by the CP is provided with the CP's express consent. Such information will not be shared with anyone other than employed PPs with Pious PPs LLC. PP agrees to maintain the confidentiality of all such information in accordance with applicable privacy laws.

Data Security Measures: We implement robust security measures to protect your information from unauthorized access, use, disclosure, alteration, or destruction. These measures include:  

• Secure data storage and encryption protocols.

• Restricted access to your information on a need-to-know basis.

Compliance with Privacy Regulations: While our direct-to-consumer service model may have nuanced applicability to specific healthcare privacy regulations like HIPAA, we are committed to adhering to the spirit and principles of such regulations and maintaining the highest standards of data privacy and security. We continuously review and update our policies to align with evolving best practices and legal requirements. We encourage you to consult with your own legal counsel for clarification on the applicability of specific regulations to our services.

Your Rights Regarding Your Information: You have the right to all the following:

• Access the personal and medical information we hold about you.

• Request corrections to any inaccuracies in your information.

• Request the deletion of your information, subject to our data retention policy and legal obligations.  

• Receive notification of any data breaches that may impact your information.

Data Retention & Deletion Policy

Client data will be retained for the duration of your subscribed account in good standing. By request, you may consent to retention of information for future use if future service needs are promising. Providing ongoing services to active subscribers.

• Complying with legal and regulatory requirements.

• Maintaining records of our interactions for quality assurance and potential legal defense.

• Facilitating any potential reactivation of services should a former subscriber choose to return.

Data Deletion Process: Upon service cancellation, or when the data is no longer necessary for the purposes outlined above and the retention period has expired, client data will be securely deleted. This process includes:

• Electronic Data: Securely overwriting or erasing electronic files and databases using industry-standard methods to prevent data recovery.

• Physical Records (if any): Shredding or otherwise destroying physical documents containing personal or medical information in a manner that renders them unreadable.

Exceptions to Deletion: In certain circumstances, data may not be immediately or fully deleted, including:

• When required by law or legal process (e.g., court orders, subpoenas).

• For ongoing legal or regulatory investigations.

• For the establishment, exercise, or defense of legal claims.

• When anonymized or aggregated for research or statistical purposes, in a form that does not identify individual clients.

This Agreement constitutes the entire agreement between the CP and PP LLC, concerning the subject matter hereof and supersedes all prior and contemporaneous agreements, understandings, and representations, whether written or oral. We are committed to ensuring the secure and responsible management of your data throughout its lifecycle, from collection to secure deletion. 

Severability: If any provision of this Agreement is held to be invalid or unenforceable, the remaining provisions shall remain in full force and effect.

Medical & Healthcare Specific Policies

Pious PPs LLC does not provide direct medical care, diagnose, prescribe medications, or replace the role of a licensed physician or other direct care providers. Our role is to support, guide, inform, educate, and advocate for the client within the healthcare system. 

• All medical decisions remain the sole responsibility of the client/CP (CP), in consultation with their treating healthcare providers. Our services are advisory and supportive, not curative or diagnostic. If & when we communicate with a CP's healthcare team, it is with written consent, as a liaison, not as a primary provider, upon registration with PP LLC & agreement with set policies as stated here. Limitations on our ability to access or interpret certain medical records, are with you the CP & without explicit client authorization or disclosure to the CP’s care providers, PCP & other specialty practices & physicians.

• We remain HIPAA Compliant as a Registered Nurse entity dealing with protected health information (PHI), adhering to HIPAA principles stated below, is essential. 

• Revocation of Authorization is the client's right to revoke this authorization at any time in writing, or by discontinuing subscription services.

• Limits to Confidentiality: Briefly mention any legal or ethical situations where confidentiality must be breached (e.g., mandated reporting for abuse, public health threats, court orders). Always consult legal counsel on these specific clauses.

HIPPA Privacy Rule, Security Rule, and Breach Notification Rule

1. HIPAA Privacy Rule:

Patient Rights: Individuals have rights over their health information, including the right to the following: Please consider, most information is inapplicable to the functions of PP LLC, but provided to you for your review here:

• Receive a Notice of Privacy Practices (NPP) explaining how their information may be used and shared.

• Access and obtain a copy of their health records.

• Request amendments or corrections to their health information.

• Request restrictions on how their information is used or disclosed (though covered entities are not always required to agree).

• Receive an accounting of certain disclosures of their PHI.

• Complain to the Office for Civil Rights (OCR) if they believe their privacy rights have been violated.

Permitted Uses and Disclosures: PHI can be used and disclosed without patient authorization for: Treatment: Providing, coordinating, or managing healthcare. (e.g., sharing information between providers involved in a patient's care).

Payment: Billing and collection activities.

• Healthcare Operations: Administrative, financial, legal, and quality improvement activities (e.g., quality assessment, training, credentialing).

• Certain public health activities, law enforcement purposes, and judicial proceedings (with specific   requirements).

Minimum Necessary Rule: When using or disclosing PHI (other than for treatment, to the individual, or for certain other exceptions), a covered entity must make reasonable efforts to limit the information to the minimum necessary to accomplish the intended purpose.

Consent vs. Authorization: "Consent" was previously required for treatment, payment, and healthcare operations, but is no longer federally mandated (though some state laws or organizational policies may still require it).

• "Authorization" is generally required for uses and disclosures of PHI outside of treatment, payment, or healthcare operations, such as for marketing or research purposes. This must be specific, in writing, and easily revocable by the patient.

2. HIPAA Security Rule:

• This rule establishes national standards to protect electronic protected health information (ePHI).

Confidentiality: ePHI is not made available or disclosed to unauthorized persons or processes.

Integrity: ePHI has not been altered or destroyed in an unauthorized manner.

Availability: ePHI is accessible and usable on demand by an authorized person.

Required Safeguards: Covered entities (and business associates) must implement administrative, physical, and technical safeguards. For an independent RN Patient Advocate, this means:

Administrative Safeguards: Policies and procedures for managing security, workforce training, risk analysis and management.

Physical Safeguards: Protecting physical access to ePHI (e.g., locking offices, securing workstations).

Technical Safeguards: Protecting ePHI transmitted or stored electronically (e.g., access controls, audit controls, encryption, integrity controls, transmission security).

3. HIPAA Breach Notification Rule:

Core Principle: Transparency and accountability when PHI is compromised.

Requirements: Timely notification, content of notification, and reporting to authorities based on the scope and potential harm of the breach.

Applicability to Registered Nurse Patient Advocates

Covered Entities: Healthcare providers, health plans, and healthcare clearinghouses that conduct certain financial and administrative transactions electronically. When PP LLC, directly provide healthcare services and transmit health information electronically in connection with those transactions (e.g., billing insurance), PP LLC could be a Covered Entity.

Business Associates: Persons or entities that perform functions or activities on behalf of, or provide services to, a Covered Entity that involve the use or disclosure of PHI. This is often where independent patient advocates fall, if they work with or receive PHI from a Covered Entity (e.g., a hospital, doctor's office). In this case, PP LLC would need a Business Associate Agreement (BAA) with the Covered Entity. In this case, PP LLC will obtain information directly from our CPs.

Direct-to-Consumer Model: If your patient advocacy service is purely direct-to-consumer and you do not conduct electronic transactions with health plans or on behalf of Covered Entities, you might not be a Covered Entity or Business Associate in the strictest sense of HIPAA. As professional Registered Nurses, PP LLC as an entity is professionally and ethically bound to protect patient confidentiality. Your Nurse Practice Act (state law), professional nursing ethics (e.g., ANA Code of Ethics), and common law duty of confidentiality always apply. Best practice strongly dictates that you operate as if you are fully HIPAA compliant, implementing all the safeguards. Patients expect it, and it's essential for building trust and avoiding professional repercussions.

Other Relevant Privacy Laws and Professional Standards in the U.S.A.

State Nurse Practice Acts: Every state has its own Nurse Practice Act, which is the statutory law governing nursing. These acts, and the regulations promulgated by state Boards of Nursing, invariably include provisions regarding patient confidentiality, professional conduct, and the protection of patient information. Violating confidentiality can lead to disciplinary action, including license suspension or revocation.

American Nurses Association (ANA) Code of Ethics for Nurses with Interpretive Statements: This professional code provides ethical guidelines for RNs, placing a strong emphasis on protecting patient privacy and confidentiality as a fundamental ethical duty. It often sets a higher bar than legal requirements.

Common Law Duty of Confidentiality: This is a long-standing legal principle that healthcare providers have a duty to keep patient information confidential. This duty exists regardless of HIPAA and stems from the nature of the provider-patient relationship.

State-Specific Privacy Laws: Some states have additional privacy laws that may be more stringent than HIPAA in certain areas (e.g., mental health records, HIV status, substance abuse treatment records). You must be aware of and comply with your specific state's laws.

42 CFR Part 2 (Confidentiality of Substance Use Disorder Patient Records): If you deal with records related to substance use disorder treatment from federally assisted programs, this federal law imposes even stricter confidentiality requirements than HIPAA.

FERPA (Family Educational Rights and Privacy Act): If your advocacy involves student health records in educational settings, FERPA might apply alongside or instead of HIPAA.

Consumer Protection Laws: Various state and federal consumer protection laws may also touch upon how businesses handle customer data, including health-related information, especially if not strictly covered by HIPAA.

Emergency Protocol & Crisis Management Policy: 

Pious Practicians LLC is not an emergency service: Always contact 911 or their treating physician directly for immediate medical emergencies. In cases where our CP’s  health status significantly changes or deteriorates, we consistently advise them to seek immediate medical attention and PP LLC offers support in coordinating with emergency services if authorized.Our role is supportive, not direct crisis intervention.

Referral & Resource Disclosure Policy: We reserve the right to recommend or refer clients to other healthcare professionals, specialists, or resources based on their needs. Any such recommendations are based on your professional judgment and are not endorsements of any specific outcome from those services.

Disclosure of Conflicts of Interest: Crucially, if PP LLC  has any financial or other relationships with providers or services you refer to, this must be explicitly disclosed. This protects our ethical standing and builds trust.

Informed Consent for Advocacy Services Policy: Goes hand-in-hand with the "Scope of Service" policy but specifically focuses on the client's acknowledgment and consent. This policy confirms your understanding of our role as an RN Patient Advocate, not a direct care provider. This affirms your understanding that you retain full responsibility for their healthcare decisions.

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This Subscription Agreement outlines the terms and conditions governing you, the Care Partner (CP),  subscription to Pious Practicians LLC (PP LLC) services. By subscribing, you agree to the above policies & amendments as noted on this website.

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