How To Work At Cornerstone Behavioral Health

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1 CORNERSTONE Behavioral Health Mental Health and Substance Abuse Programs Client Handbook Revised: May 2012

2 Introduction W elcom e to Cornerstone Behavioral Health. Our m ission is to provide individual, confidential and caring treatm ent for individuals and fam ilies with behavioral health needs, im proving their quality of life. The inform ation contained in this handbook is to acquaint you with som e of Cornerstone's policies and procedures. Some of the information contained in this manual is a copy of what you read and signed at the initial visit. This booklet is your personal copy and is provided for future reference. About Cornerstone Cornerstone Behavioral Health, a division of MRSI, is one of W yom ing's prem ier providers of nationally accredited outpatient m ental health services and substance abuse treatm ent program s. Established in 1988, Cornerstone provides area residents with com prehensive, professional services in the com fort and privacy of a state-of-the-art clinic located next to Evanston Regional Hospital. The professional staff at Cornerstone consists of licensed psychologists and psychological interns. Cornerstone offers a broad range of m ental health services including psychological testing and assessments, family and marital therapy, psychiatric assessments and medication management (via tele-psychiatry by board certified psychiatrists at Cheyenne Regional Medical Center), child and adolescent therapy, com puterized testing for attention deficit hyperactivity disorder (ADHD), and individual and group therapy. Cornerstone's outpatient substance abuse treatm ent program s enable clients to rem ain with their fam ilies, attend school, and m aintain em ploym ent while receiving treatment. Substance abuse treatm ent program s are available on a sliding fee scale based on gross fam ily incom e. In addition to highly successful outpatient groups, intensive outpatient treatm ent program s, and individual counseling, Cornerstone offers aftercare, DUI and MIP schools, drug screenings, and prevention education. Cornerstone Goals Cornerstone Behavioral Health is committed, to the degree necessary for each client, to the following goals: 1. Support the recovery, health or well-being of the persons or fam ilies served. 2. Enhance the quality of life of the persons served. 3. Reduce symptom s or needs and build resilience. 4. Restore and/or im prove functioning. 5. Support the integration of the persons served into the comm unity. Substance Abuse Services A substance abuse evaluation is conducted to determ ine whether an individual has a problem atic pattern of substance use that could benefit from treatm ent. A clinical interview plus testing including ASI and ASAM (Placem ent Criteria for the Treatm ent of Substance-Related Disorders) are designated for new clients or clients who have not had a recent evaluation (six months to one year) that continues to be a valid indicator of the client s current level of functioning. This evaluation is performed by a qualified therapist and includes an interview (and testing, if applicable) with the client and/or referral source to assess for the appropriateness of available services. Inform ation m ay also be obtained from fam ily m em bers/legal guardian (when applicable and permitted); and other appropriate and perm itted collateral sources. This collateral information is obtained with the permission (signed release of information form) of the client. The intake/ evaluation takes into account the individual s age, developm ent, culture, and education (i.e., correct form s, testing instruments, etc.). The assigned therapist gathers sufficient inform ation during the intake/evaluation to determ ine the level of care indicated. The therapist identifies strengths, abilities, needs and preferences of the client as well as co-occurring disabilities and/or disorders, and how they will be addressed in the developm ent of the individual treatm ent plan. In addition, the therapist addresses the client s desired outcom es and expectations and provides for the use of assistive technology or resources as

3 needed. All of these issues are addressed in an ongoing fashion. The treatm ent plan is developed with the active participation of the client and is updated as needed to meet the changing needs of the client. Cornerstone ensures that inform ation and education are relevant to the needs of the client. Substance abuse services including appropriate placem ent of clients, and their continued stay, transfer, and discharge recom m endations are determ ined to the extent reasonably possible, through application of the current ASAM client placement criteria. Substance Abuse Treatm ent options provided by Cornerstone Behavioral Health include adult and adolescent outpatient group or intensive outpatient treatm ent. These m ultifaceted, highly com prehensive program s are designed to help individuals with chem ical dependencies and substance abuse issues through individual, group, and fam ily therapy. Cornerstone also offers aftercare program s, DUI school, MIP school, drug and alcohol education, and prevention services. Psychological Services Cornerstone Behavioral Health offers a full range of outpatient psychological services utilizing only professionals trained at the doctoral level with specialty training in areas addressing a wide variety of problem s consum ers m ay have. These services include therapy for individuals, fam ilies, couples, as well as for children, adolescents, and adults. Every individual who wishes to receive psychological services from Cornerstone Behavioral Health, m ust have a psychological screening. This screening is performed by a qualified therapist and includes an interview (and testing, if applicable) with the client and/or referral source to assess for the appropriateness of available services. Inform ation m ay also be obtained from family m em bers/legal guardian (when applicable and perm itted); and other appropriate and perm itted collateral sources. This collateral inform ation is obtained with the perm ission (signed release of inform ation form) of the client and/or guardian. The screening takes into account the individual s age, developm ent, culture, and education (i.e., correct form, testing instrum ents, etc.). The assigned therapist gathers sufficient inform ation during the screening to develop an individualized, person-centered treatm ent plan. The therapist identifies strengths, abilities, needs and preferences of the person served as well as co-occurring disabilities and/or disorders, and how they will be addressed in the development of the individual treatment plan. In addition the therapist addresses the client s desired outcom es and expectations and provides for the use of assistive technology or resources as needed. Cornerstone ensures that inform ation and education are relevant to the needs of the client. The therapist and client focus on whatever difficulties led the client to pursue treatm ent. These difficulties m ight include, but are certainly not lim ited to: Depression, anxiety, eating disorders, m arital difficulties, difficulty coping with life stress, trouble controlling anger, or general dissatisfaction in one or m ore aspects of life. Through discussion of one's specific difficulties with a therapist, an individual and/or fam ily is able to develop a better understanding of the factors influencing his or her difficulties, and consequently, to discover the freedom necessary to m ake choices that will dispose of difficulties. Psychological testing/assessments are also available. Psychological testing/assessm ents are usually requested when there is some question about what might be troubling a particular person, or to gather information about a person's current emotional well-being, psychological or personality m ake-up, or academ ic and intellectual functioning. Psychiatric Services Telehealth/telepsychiatry services are offered through Cheyenne Regional Medical Center. Cornerstone Behavioral Health serves as a location-site for these services. For more information regarding the nature and types of services available, please feel free to give us a call at or check our website: cornerstonebh.com Psychiatric Advance Directives Policy Individuals have the right to m ake decisions concerning their health care, including the right to accept or refuse medical or surgical treatment, and the right to formulate Advance Directives, as permitted under

4 State law. No individual shall be discrim inated against, or have care conditioned on whether the individual has executed any Advance Directives. Procedures A. Upon adm ission, the client and/or guardian will be asked if they have any Advance Directives. If the client indicates that they do have Advanced Directives, a copy will be requested, and noted in the client s file. B. In the event that the client does not have any Advance Directives, but would like additional information; he/she will be provided with appropriate contact information and/or documents. Federal Law requires that clients receive inform ation regarding Advanced Directives. For additional inform ation regarding Psychiatric Advance Directives, please speak with your primary care physician or psychiatrist. You m ay also contact your local counsel, the Am erican Medical Society, your local Bar Association, or the Area Agency 10B, Inc., by calling Ombudsm an office at Consent for Services W henever a client com es into Cornerstone Behavioral Heath, a com pleted and appropriately signed Consent for Services form will be maintained in the client file. No services will be performed without this Consent for Services form being completed and signed by the appropriate parties. Sample of Form: I consent to such: (circle one or more as applicable), Psychological screening, Psychological evaluation/testing, individual counseling, and fam ily/couples counseling, intake, ASI, evaluation, individual counseling, couples counseling, Intensive Outpatient Treatm ent Program, Aftercare, Family W eek, support group, Outpatient Education, Transitional Services, Co-dependency workshop, DUI Class, Breathalyzer, urinalysis test, as a professional staff of Cornerstone may determ ine. I am aware that care and treatm ent in this area is not an exact science, and I acknowledge that no guarantees have been made to me as to the result of evaluation and/or treatm ent. I acknowledge that to comply with all the rules and regulations, includes the agreem ent to attend all therapy sessions (specific for substance abuse client: includes attending all therapy sessions of this program alcohol and drug free, and I may be subjected to periodic screening for alcohol and drug use), and follow the recom m ended treatm ent. I will respect the privacy and rights of other clients in this program by not disclosing who I see or what I hear outside this program either while in the program or after completion of the program. I, the undersigned, understand that this agency does not have 7 day/week, 24 hour a day services, and that in case of emergency after the agency hours of 8:00 a.m. to 5:00 p.m., Monday through Friday, I am to go to the Evanston Regional Hospital or call High Country Behavioral Health at I, the undersigned, being the legal parent/guardian, give my consent for Cornerstone to provide services to. (Minor Child) (Specific to the substance abuse clients) I understand funding for Cornerstone Behavioral Health is provided in part by W yom ing Departm ent of Health, Substance Abuse Division. The Division may review my chart as a part of any utilization review, audit, certification, payment or complaint investigative processes. (Signature obtained)

5 Client Rights Cornerstone Behavioral Health strives to protect and promote the rights, privacy and confidentiality of all persons served. Cornerstone safeguards the rights of the persons served in a m anner that is responsive to each person s age or developm ental level, gender, social supports/preferences, cultural orientation/background, psychological characteristics, sexual orientation, physical condition, and spiritual beliefs. Cornerstone ensures that inform ation and education are relevant to the needs of the persons served. Cornerstone communicates and shares the Client Rights in a manner that is clear and understandable to the client prior to the beginning of services and at least annually thereafter. The Client Rights are also posted in the lobby for review. If clarification is needed, the client m ay speak with their designated clinician. Cornerstone Behavioral Health ensures that the sharing of confidential billing, utilization, clinical, and other adm inistrative and service-related inform ation is done so according to confidentiality guidelines that recognize applicable regulatory requirem ents such as the federal rules for addiction treatm ent program s (42CFR) and HIPAA. The organization also ensures that the persons served are protected from abuse (physical, sexual, psychological, and fiduciary abuse); retaliation; harassm ent and physical punishm ent; and humiliating, threatening, or exploitive actions. Sample of Form: Prior to the first meeting with one of Cornerstone s staff members, each client is given an outline of the policies relating to client rights which states, As a client of this center, you have the following rights: 1) To receive treatment regardless of sex, race, creed, ethnic origin, age, sexual preference, religion, socioeconomic status, handicaps, mental health/substance abuse disorder, or sources of financial support... The client also receives a client handbook that contains inform ation such as client rights and responsibilities; grievance policy/procedure; Notice of Privacy Practices, hours of operation, confidentiality, follow-up policy/ procedure, financial inform ation, after hours em ergency contacts, fam iliarization with the premises; program policies and procedure regarding sm oking, illicit or licit drugs brought into the program, policy on controlled substances at Cornerstone, etc. A client may request to examine and/or review the contents of their treatment records with their primary clinician unless clinically contraindicated. If a client s rights under this section are lim ited or denied because of clinical contradictions, such lim itations of denial shall be fully documented in the client record. All client treatment records are the property of MRSI/Cornerstone and may not be removed from the premises. Each client receiving services will be inform ed of their rights which are as follows: 1. To receive treatment regardless of sex, race, creed, ethnic origin, age, sexual preference, religion, socioeconomic status, handicaps, m ental health/substance abuse disorder, or sources of financial support; 2. To participate in the development of their treatment plan and goals that are reviewed and updated periodically, and to include significant others in treatm ent; 3. Upon request, to exam ine and/or review their charts with their prim ary clinician unless clinically contraindicated; 4. The right to initiate a grievance and m echanism for requesting review of grievance; 5. Each client (or where appropriate, the client s legal guardian) shall be inform ed of his/her rights in a language the client understands. The inform ation shall be presented to the client, both orally and in writing;

6 6. If a client s rights under this section are lim ited or denied because of clinical contradictions, such limitations or denial shall be fully documented in the client record; 7. Each client s confidentiality, personal dignity, and privacy shall be recognized and respected in provision of care and treatm ent, except where otherwise prohibited by law (see confidentiality). (Signature obtained) Confidentiality Each client receiving services at Cornerstone Behavioral Health will be inform ed of the policy regarding confidentiality. Sample of Form: The confidentiality of client records m aintained by this program is protected by Federal Law and Regulations. Cornerstone Behavioral Health ensures compliance with 42 CFR Part 2, 45 CFR Part 160 and 164, and other legal restrictions affecting confidentiality of alcohol, drug abuse, and other m edical client records. Generally, the program may not say to a person outside the program that a client attends the program, or disclose any inform ation identifying behavioral health clients unless: 1. The client consents in writing, OR; 2. The disclosure is allowed by a court order after application showing good cause, OR; 3. The disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation, OR; 4. The client commits a crime either at the program or against any person who works for the program, OR; 5. Citation of the Federal Law, OR; 6. In the event of im m inent life-threatening physical danger to the client or others. Violation of the Federal Law and Regulations by a program is a crime. Suspected violations may be reported to the United States Attorney in the district where the violation occurs. Federal Laws and Regulations do not protect any inform ation about a suspected child/adult abuse or neglect from being reported under State Law to appropriate State or local authorities. (See U.S.C. 290-ee-3 and 42 U.S.C. 290ff-3 for Federal Laws and 42CFR Part2 for Federal Regulations.) If the client is a m oderate to heavy consumer of alcoholic beverages, or if they have ever used any type of IV drugs in the past, they are at a higher risk for contraction of tuberculosis and/or HIV/AIDS. The staff recom m end such clients contact their personal physician or the local County Public Health unit for tuberculosis and/or HIV identification test. The local health unit is Uinta County Public Health 350 City View Drive, Suite 101 Evanston W Y (Signature Obtained) Financial Agreement-Fee For Services Mountain Regional Services, Inc., d.b.a. Cornerstone Behavioral Health, is a non-profit organization, established to help people with m ental health and substance abuse problems and to provide consultation

7 and education to com m unity organizations. All fiscal operations are in accordance with generally accepted accounting principles. Individuals receiving services at Cornerstone are expected to pay all insurance co-paym ents and deductibles at the time services are rendered. Clients who have no insurance are required to pay 100% for services rendered at each visit unless prior arrangements are m ade. Those individuals that have insurance that pays the insured directly (i.e., Blue Cross Blue Shield) are responsible for the entire fee at the time services are rendered. The client s insurance policy is a contract between them and their insurance company. Cornerstone is not a party to that contract. As a courtesy, this office will subm it bills to insurance carriers. In order to facilitate claim s processing, the client m ust provide all insurance policy information and changes to our office. If, as often is the case, the insurance company pays less than 100%, the client will be charged for the remainder. If payment is not received from the insurance company within 60 days, the client will be expected to pay the fee. It will then be their responsibility to pursue reim bursem ent from their insurance com pany. The fees charged at Cornerstone reflect the usual and custom ary rates in the area. The clients are responsible for paym ent regardless of any insurance com pany s arbitrary determ ination of usual and custom ary rates for services. The client s bill is their responsibility whether their insurance company pays or not. Medicaid/Equality Care recipients are responsible for a $2.45 co-pay for each visit; this co-pay does not apply to recipients under 21 years of age or pregnant women. After 60 days, there will be a finance charge of 1.5% per month (annual rate of 18%) charged to the client s account. The standard fee is charged for missed appointments, unless they are canceled at least 24 hours before the scheduled appointm ent, or if an em ergency or extenuating circum stances prevent the client from making their appointm ent. Cancelled or m issed appointm ents by Medicaid/Equality Care clients cannot be billed to Medicaid/Equality Care, therefore, the client (and/or parent/guardian) will be charged and responsible for m issed appointment fees. The adm inistrative director (or designee) will be responsible for com m unicating regularly with insurance com panies to ensure coverage and obtain benefit inform ation; m aintaining preauthorization inform ation and working with the clinician to provide necessary information for continued coverage; and keeping track of the clients account inform ation to include copays, insurance paym ents, am ounts due, etc. If the client fails to make the payments as required, the administrative director (or designee) will inform the clinician of the situation. The clinician will then speak with the client to determ ine what action(s) should be taken (i.e. paym ent plan, referrals to Departm ent of Fam ily Services, Department of Vocational Rehabilitation, etc.) to address funding issues. If it becom es necessary to discharge a client for nonpayment, the client will be referred to the community mental health center which provides mental health services on a sliding fee scale based on household income. Delinquent accounts m ay be turned over to a professional collection agency or attorney for appropriate action. The client (and/or parent/guardian) will assum e responsibility for all collection charges incurred, including but not limited to: Legal fees and court costs. In the event that working with an outside party/parties for collection becom es necessary, the client authorizes release of inform ation necessary to obtain full paym ent of their account by signing the financial agreement. (Signature Obtained) Sliding Fee Scale (At Cornerstone sliding fee scale is for Substance Abuse Treatment Services Only) As part of the W yoming Department of Health, Behavioral Health Division - Block Grant, Cornerstone Behavioral Health will charge clients who are served under the contract, on a sliding fee scale adopted from the W yom ing Departm ent of Health, Behavioral Health Services Division Sliding Fee Scale Guidance for Treatment Providers as set forth in The sliding fee scale shall be posted in the lobby and made

8 available to persons seeking substance abuse services. The sliding fee scale rates will not be applied to agencies, organizations or third party payors. For clients served under this contract, Cornerstone m ay not refuse to offer or provide services due to the client s inability to pay. A client shall not be denied access to services for non-paym ent without it being addressed as part of the treatm ent plan with a reasonable tim e-frame for resolution of the issue. However, services may be denied to clients who fail to address financial responsibilities as indicated in the treatment plan and refuse or are unwilling to pay their agreed upon fee. At the time of admission clients served under the contract will sign a financial agreement outlining the policies/ procedures with regard to the sliding fee scale. The financial agreem ent will indicate the discount (if applicable) based on the household incom e (client, spouse, significant other, etc.). Proof of incom e is required prior to signing the financial agreement. Failure to provide proof of income may result in the implementation of the maximum rate per program until such proof is provided and at which time a new financial agreem ent will be com pleted/signed. Once the client submits the proper docum entation (i.e., check stubs for family members [self/spouse], previous tax returns, etc.), the sliding fee will be put into effect from that date forward. Financial agreements will not be backdated. If a client (and/or spouse, if applicable) are unemployed, they may both be required to sign an unem ploym ent verification. The client (and/or spouse, if applicable) may be required to subm it an unem ploym ent verification each week to m aintain the specified discount. If a client (and/or spouse, if applicable) fails to subm it an unemployment verification during any week of treatm ent, the original financial agreement may be void and the client will not be eligible for the sliding fee scale discount. If the client s (and/or spouse, if applicable) em ploym ent circum stances change and/or they obtain m edical insurance at anytime during treatment, they are required to notify Cornerstone promptly, at which time a new financial agreem ent will be signed and sliding fee scale discount adjusted according to the client s (and/or spouse, if applicable) current incom e. They are required to provide proof of incom e as indicated above. If the client does not follow through with their responsibility of notifying Cornerstone promptly of changes in em ploym ent or insurance, Cornerstone reserves the right to balance bill for back charges beginning the first date of their em ploym ent/insurance. If the child is a m inor, the parents/guardians will be responsible for signing and providing proper documentation. In the event of a positive U/A test, the client and/or parent/guardian will be required to pay a fee to cover the cost of the laboratory testing. This fee is required at the tim e the service is provided. If the laboratory test results do not confirm the positive urinalysis results, the fee will be refunded. A fee is charged and paym ent required prior to beginning treatment for books and program materials. As part of the financial agreement, the client will be informed of the minimum weekly payment as determined by the sliding fee scale. Clients will also be inform ed that the discount will not be applied until insurance paym ents (if applicable) are received as the sliding fee scale rates are not applied to agencies, organizations, or third party payors as required by the State contract. In addition, if a client has insurance and m edicaid, it is the client s (or parent/guardian, if applicable) responsibility to ensure that Cornerstone Behavioral Health receives the explanation of benefits (EOB) from the insurance company so that Medicaid be billed. If the client does not submit the appropriate EOB s in a timely manner, the client will be financially responsible for those dates not billed/paid by Medicaid. At the time of admission, clients served under the contract are informed that a minimum weekly payment is due EVERY W EEK, and they are instructed to call Cornerstone Behavioral Health and speak with the adm inistrative director (or designee) if there are extenuating circum stances that prevents them from m aking their payment as agreed upon. Clients will be informed that payments made by their insurance company do not go towards their minimum weekly payment. Cornerstone Behavioral Health will not deny and/or refuse services to clients served under the contract due to inability to pay. A client shall not be denied access to services for non-payment without it being addressed as part of the treatment plan with a reasonable time frame for resolution of the issue. However, services may be denied to clients who refuse to pay their agreed upon fee and/or communicate extenuating

9 circumstances as outlined above. Coordinating Consumer Services In all cases, the clinician who conducted the psychological screening or substance abuse intake/evaluation, will be responsible for coordinating client services. The prim ary clinician will ensure that the services provided are coordinated and integrated and address goals that reflect the person s served inform ed choice; address em ergent and ongoing issues; continuity of services; and decisions concerning the client. The individual who coordinates the services should: (1) Assum e responsibility for developing and im plem enting the individual plan(s) and ensure the exchange of inform ation regarding the plan; (2) Assist the person to becom e oriented to his/her services to include process for after hours contact/em ergencies; (3) Enable the person s individual plan to proceed in an orderly, purposeful, and goal oriented m anner; (4) Prom ote the program s responsiveness to the strengths, abilities, needs, preferences and expectations of the client; (5) Prom ote the participation of the client in an ongoing basis in discussions of his/her plans, goals, and status involving family m em bers, when applicable and perm itted; (6) Identify and address gaps in services and provide inform ation relating to comm unity resources relevant to client s needs; (7) Coordinate services provided outside of the organization, if applicable; (8) Participate and advocate consistently in team conferences concerning the client; (9) Facilitate the exit/discharge process and arrangem ents for follow-up and appropriate supportive services; (10) Com m unicate inform ation regarding client s progress to appropriate persons including fam ily, legal guardian, or prim ary care physician, when applicable and permitted. Individual Plan for Client An individual plan should be developed in collaboration and active participation with each client and should involve the fam ily/legal guardian of the client when applicable. The individual plan should be written and/or communicated in a manner that is clear and understandable to the client and to the individuals who are responsible for implementing the plan and be signed by the primary clinician, the client, and where appropriate, members of the persons served family or supportive persons. The individual plan should be developed by the designated clinician using the inform ation collected in the initial screening/intake/evaluation and interpretive summary and specify the services to be provided by the program(s). The individual plan should include the following com ponents and should ensure that information and education are relevant to the needs of the persons served. 1. Goals that are expressed in the words of the client; reflective of the informed choice of the client or parent/guardian; appropriate to the person s age and cultural and ethnicity variations, reflect the desired outcom es, expectations, strengths, abilities, needs, desires, and preferences. W here possible, the use of restorative justice principles shall be used in the individualized treatm ent plan of offenders. 2. As all goals at this agency are fitted to the particular client, the time frame for a goal s applicability is determined on an individual basis and documented in the treatment plan of the client. 3. The m easurable/achievable/tim e specific service or treatm ent objectives should reflect the results of the assessm ent and expectations of the client and treatment team; should be appropriate to the treatm ent setting, the person s age and developm ent, education, and co-occurring disability/disorder/concerns; be reflective of the person s culture and ethnicity; and should reflect pro-social thinking, values and behavior. 4. Treatment team members should include an educational specialist, when applicable. 5. The plan should include specific treatm ent interventions, their frequency, and services to be provided by the program. The individual plan should also identify any needs beyond the scope of the program and appropriate referrals m ade and when applicable, inform ation on or conditions for

10 transition to other comm unity services. The prim ary clinician shall provide for coordination and ongoing com m unication between internal and external service providers. 6. Each client plan should be developed within the first two sessions after admission to Cornerstone. W hen possible, a copy of the treatment plan should be provided to the client. 7. Each client plan will have measures to be used to assess the outcomes of the objectives. 8. The individual responsible for implem enting the individualized plan will be the prim ary clinician, unless otherwise noted in the plan. 9. Each plan should be based on the needs and desires of the client and focus on the integration and inclusion of the client into the com m unity, family when appropriate, natural support system s, or other needed services. 10. Clients who participate in the substance abuse program s shall not be denied access to services for non-payment without it being addressed as part of the treatment plan with a reasonable time-frame for resolution of the issue. However, services m ay be denied to clients who fail to address financial responsibilities as indicated in the treatm ent plan and refuse or are unwilling to pay their agreed upon fee. 11. For those clients receiving substance abuse services, Quality of Life (QOL) funds m ay be available if the need can be demonstrated by the individual. The primary clinician will meet with the client to discuss the needs, and if found to be appropriate, will include financial goals and objectives in the treatm ent plan. The use of QOL funds by Cornerstone will be specific to each individual client whose needs, as identified in that client s treatment plan, require non-clinical supports and services in order to achieve the clinical outcomes of the client s treatment plan. 12. Each individual treatment plan should be reviewed periodically (at least quarterly) with the client and/or the treatm ent team for continuing relevance to the goal of integration and inclusion, review/m aintain court orders, when applicable, and to modify goals, objectives, and interventions when necessary. 13. The review of treatment plans for individuals enrolled in IOP/AIOP occurs at a minimum of once per m onth. Substance abuse services including appropriate placem ent of clients, and their continued stay, transfer, and discharge recom m endations are determ ined to the extent reasonably possible, through application of the current ASAM client placement criteria. 14. W hen modifications are needed, modifications to the plan will be made by the designated clinician, with the person s served input, within two weeks of the change being identified. These changes will be reported and discussed at the next Mental Health or Substance Abuse Staffing. 15. Reassessm ents should be conducted, when appropriate (i.e., significant change in the client, m ajor life issues, accomplishment of significant goals, incarcerations, or referral to a court system, etc.). 16. Each plan should be coordinated with prior plans or other plans for services received by the individual at Cornerstone Behavioral Health, inform ation on, or conditions for, inclusion/transitions to other services provided outside of the organization, as well as identification of legal requirem ents/im posed fees. 17. The individual plan should specifically identify individuals having co-occurring disabilities/disorders/concerns and specifically address those issues in an integrated m anner. W hen applicable, m edications will be integrated into the overall plan of the client. Services are provided by personnel, either within the organization or by referral, who are qualified to provide services for persons with co-occurring disabilities/disorders/concerns.

11 18. W hen applicable, a personal safety plan is completed with the client as soon as possible after adm ission, that identifies triggers, including assessm ent of risk for dangerous behaviors; current coping skills; warning signs; preferred interventions for personal and public safety, and psychiatric advance directives when available. 19. Progress toward achievem ent of service or treatm ent objectives for the client should be documented and communicated to the client. After each session a progress note shall be com pleted, signed, and dated. The progress note should docum ent the identified goals and objectives that were achieved or revised during the reporting period, significant events or changes in the life of the client that may impact the course of treatment or services, the delivery and outcome of services and specific interventions that support the individual plan, changes in frequency of services, and movement to other levels of care if applicable. 20. It is the policy of Cornerstone Behavioral Health that when changes to a person s served plan is made that the client be actively involved in making those changes, with the full knowledge of the client. These changes will be documented in the person s served file or chart. 21. W hen clinically indicated, discharge planning should be initiated with the client at the earliest possible point in the individual planning service delivery process. Discharge planning for persons with Coexisting/Co-Occurring m edical, psychological, psychiatric disorders/disabilities/ conditions and/or intellectual disabilities should be part of the planning from the beginning to explore other available options/resources. Transtion/Discharge Planning Transition (which may include continuing care [movement to a different level of service or intensity of contact such as from IOP to Aftercare] or placement on inactive status while a client attends an inpatient program) or discharge planning assists the persons served to move from one level of care to another within the organization or to obtain services that are needed but are not available at Cornerstone Behavioral Health based on the needs of the persons served in order to support ongoing recovery, treatment/service gains, or increased community inclusion. Substance abuse services including appropriate placem ent of clients, and their continued stay, transfer, and discharge recom m endations are determ ined to the extent reasonably possible, through application of the current ASAM client placement criteria. W hen clinically indicated, transition/discharge planning should be initiated with the client at the earliest possible point in the individual planning service delivery process and no less than one month prior to the actual discharge. However, there m ay be tim es when the client leaves abruptly when discharge planning is not possible. For persons served with coexisting/co-occurring m edical, psychological, psychiatric disorders/disabilities/conditions and/or intellectual disabilities these issues should be part of the planning from the beginning to explore other available options/resources. Cornerstone professionals will arrange a meeting with the client to develop a plan for post-treatment care. Using the initial diagnostic im pression, progress during treatm ent, and gains achieved during program participation, input will be sought from the client in all aspects of developing a discharge plan. Areas of strengths and challenges will be jointly elicited by the Cornerstone professional and client, then discussed. a. Medical illnesses or physical handicaps will be considered for im plications they m ay have on continued aftercare. b. Em otional, fam ily, m arital, relational, legal, environm ental, financial, academ ic, and employm ent stressors and their im pact on continued aftercare will be discussed. The person to be transitioned/discharged will com plete assignm ents prior to a transition/discharge m eeting with the Cornerstone professional. A written transition/ discharge plan will be jointly developed and

12 discussed in the transition/discharge planning session(s). Client Follow-Up Cornerstone Behavioral Health strives to provide individual, confidential and caring treatm ent for persons and fam ilies with behavioral health needs, im proving their quality of life. Each client will be asked to participate in ongoing client satisfaction surveys and follow-up surveys as well as state m andated surveys to determine what they find/found helpful about the services they are currently receiving and/or received, what areas need im provem ent, how Cornerstone m ight continue to help them, overall quality of care received; achievem ent of outcomes, and overall satisfaction. They are invited and encouraged to add additional comments on the survey(s) if they would like to comment on any aspect of the services about which the survey(s) did not ask. There is also a suggestion box located in the front lobby. A consent for follow-up will be obtained from each client. After a client is discharged from treatm ent, the adm inistrative director or his/her designee will im m ediately prepare and m ail a client satisfaction survey. If an unplanned transition or discharge occurs, the prim ary clinician with the assistance of the administrative director (or designate) will be responsible for follow-up to determine with the client whether further services are needed and to offer or refer to needed services, when possible. If/when a client is discharged or rem oved from the program for aggressive/assaultive behavior, follow-up occurs (within 72 hours post discharge) to ensure appropriate care is obtained. Approxim ately three m onths post discharge a follow-up survey will be sent to determine the status of the client s progress. The adm inistrative director will m aintain and m onitor inform ation received and provide feedback to the president and/or clinical director for areas that need im provem ent as well as for program planning, perform ance im provem ent, strategic planning, organizational advocacy efforts, financial planning, and resource planning. This inform ation is continually analyzed, and the analysis is integrated into the business practices of the organization. The input is used to help determ ine if the organization is: Meeting the current needs of the persons served and other stakeholders; offering services that are relevant to the persons served and other stakeholders; and identifying potential new opportunities for the growth and developm ent of program s and services. Weapons and Violence The Com pany is concerned with providing clients and employees a safe and productive environm ent. As such, the Com pany strictly prohibits the possession or use of any and all weapons, including handguns on Com pany prem ises by a client, employee, vendor, or other visitor, whether licensed or unlicenced and whether concealed or visible, unless the individual has a valid concealed weapons perm it from the proper governm ental authority. The Com pany prem ises not only include the m ain facilities, but also entrances and exits, break areas, parking lots, vehicles and pathways. Com pany em ployees are further prohibited from the possession or use of any and all weapons while conducting business on behalf of the Company away from com pany prem ises. Employees aware of a client or another employee possessing a weapon while on company property or on a company function must immediately report it to their supervisor. If the supervisor has a weapon or is unavailable, the em ployee should report this to the Hum an Resource Department or any departm ent director as soon as possible. Clients or employees who are threatened, witness, or overhear a threat of bodily harm must immediately report it to a supervisor. If a supervisor made the threat or is unavailable, the employee should report it to the Human Resource Department or any department director as soon as possible. If a client or employee receives a threat away from com pany property even though not within the course of company business, such a threat should be reported if you believe it may be carried out on company property or during com pany business.

13 As determined by the Company, any client or employee possessing a weapon or responsible for threats or violence, is subject to discharge from the program, and/or corrective action, up to and including term ination of em ploym ent. This policy was adopted from the MRSI/Cornerstone Em ployee Guidelines. If a client is discharged from the program for violation of this policy, the prim ary clinician with the assistance of the adm inistrative director (or designate) will be responsible for follow-up to determ ine with the client whether further services are needed and to offer or refer to needed services, when possible. Nonviolent Practices It is the policy of Cornerstone Behavioral Health that no seclusion, restraints, or intrusive procedures be used at anytim e during the course of treatm ent. In a situation of threatening, aggressive, or assaultive individuals, em ergency personnel should be contacted im mediately by calling 911. Em ergency intervention will then be conducted by emergency personnel/police department. Smoking & Smokeless Tobacco Use MRSI/Cornerstone Behavioral Health is officially a sm oke-free/tobacco-free facility. Sm oking, chewing, or the sale of tobacco products is strictly prohibited in owned or rented buildings with the exception of designated areas at each location. Failure to adhere to this guideline is a serious offense and may result in discharge from the program. Butts must be deposited in provided receptacles. Abstinence Abstinence is the primary goal of Cornerstone Behavioral Health Substance Abuse program s, unless contraindicated by the assessed special needs of the clients. Clients m ust agree to rem ain abstinent from all m ood altering drugs/alcohol including prescription m edication. In order to assure ongoing abstinence, the clients are tested frequently and at random. Individuals will be randomly selected each week for testing. The individual urinalysis tests are FDA cleared and have a m ulti-drug screening device with a built-in tim er for error-proof testing. The client and/or parent/guardian will not be responsible for the cost of the random urinalysis unless or until follow-up testing is done, at the discretion of the clinician, which typically occurs when the urinalysis test result is positive. In the event of a positive test, the client and/or parent/ guardian will be required to pay a fee to cover the cost of the laboratory testing. This fee is required at the time the service is provided. If the laboratory test results do not confirm the positive urinalysis results, the fee will be refunded. If a client is unable to provide an urine sample, they will be tested using the Oral Alert Saliva Tests. The client and/or guardian will be responsible for the cost of the Oral Alert Saliva test as well as any confirmation costs which will be added to their account. The chain of custody for urinalysis tests are as follows: 1. The clinician (or designee) will personally observe clients void into a collection bottle except where the collector and the client are not of the same sex or where it is virtually impossible to collect an observed specim en. (For unobserved specim ens, an adulteration panel test m ay be requested.) 2. The clinician will follow the directions of the urinalysis tests. Testing will be com pleted in the presence of the client. If the test has a negative result, the specimen will be discarded. 3. For those tests that read positive, the urine sample is sent to Redwood Toxicology for confirmation. The urine sam ple will be transferred into the specim en bottle supplied by Redwood Toxicology. The specim en bottle will be placed in the specim en bag with appropriate labels, identifying inform ation, and security labels then sent to the lab. If appropriate chain of custody labels are not affixed the test will be determ ined to be invalid by Redwood Toxicology. Tests are confirm ed via GC/MS.

14 4. W hen applicable, the supervising/referring agency (Probation & Parole, Drug Court, courts, etc.) are notified when positive tests are confirm ed by Redwood Toxicology. Alcohol and/or Other Drugs and Psychiatric Disabilities The use of alcohol and/or other drugs and their interactions with the client s psychiatric disabilities/disorders should be addressed by the designated clinician at the initial screening, in the individual plan, progress reports, and transition/discharge planning. Clients participating in any substance abuse program offered at Cornerstone Behavioral Health m ust agree to rem ain abstinent from all m ood altering drugs/alcohol to include prescription m edications (refer to policy on Abstinence). A client m ay be discharged from any substance abuse program as a result of taking prescribed m edication which is contraindicated in the client s success at remaining abstinent from all mood altering chemicals. Controlled Substances at Cornerstone Cornerstone Behavioral Health seeks to provide a safe, com fortable, drug-free, and effective treatm ent environm ent. In the event a client disrupts the treatm ent setting by bringing a controlled substance into the program area, the following procedures will be followed. 1. Upon intake, each client will sign a contract to abstain from use of and not to be in possession of any illicit drugs. Adolescents (persons under 18 years old) additionally will sign a contract agreeing not to use or bring tobacco onto the treatment premises. 2. Discovery of possession or use of any illicit substance during the course of treatm ent will: a. Be considered a violation of the core rules of the program. b. Necessitate re-evaluation of appropriateness of the particular treatment program for that individual. 3. The Evanston Police Department will be contacted and requested to come to the scene. a. Upon police arrival, the person in possession will be asked to go to the counselor s office in order to protect the confidentiality of the other group m embers. b. The police will handle any search or seizure of the substance. The statem ent given by the counselor will be strictly limited to the minimal facts necessary to explain the discovery of the alleged illicit substance. Use of Special Treatment Intervention Cornerstone mental health and substance abuse professionals use interventions that are within the standard of care for their professions, and if used, are individually applied based on the specific needs of the clients and as determined safe and effective. Cornerstone does not place restrictions on the privileges or rights of clients, nor will any event, behavior, or attitude lead to the loss of rights or privileges for the client. Clients are asked to sign an Emergency Treatment Release for medical/psychiatric emergency treatment, should pursuit of such treatment become necessary at any time. The Emergency Treatment Release is signed prior to the initial screening and remains in effect throughout the individual s treatment. The Emergency Treatment Release contains information about the person to contact in the event of an emergency, including the name, address, and telephone number. The Emergency Treatment Release also contains information about the individual s primary care physician, including the name, address, and telephone number, when available. Grievance Procedure If you feel there is some impediment to your participation or that you have a legitimate grievance with the staff or other clients, a grievance procedure is available to you. The following grievance procedure is an upward process intended to prom ote and foster healthy conflict resolution and problem solving. At any point

15 during the grievance proceeding(s), you m ay utilize counsel or other representation. An adm inistrative record of all grievances is maintained for review by federal and state licensing and accreditation agencies. INFORM AL Step 1: In most cases, a candid discussion between the client/consumer and the staff member(s) involved m ay resolve the situation in a responsible and reasonable fashion. If the com plaint is not resolved to your mutual satisfaction, you may proceed to Step 2. Step 2: You submit your complaint/problem in writing to the next level of authority (staff member s supervisor). This should be done within ten working days after the completion of Step 1. W ithin five working days after receipt of the written com plaint/problem, the next level of authority (staff m em ber s supervisor) will review the com plaint/problem, m eet with the individuals involved to gather inform ation and assist the parties in resolving the com plaint/problem. If the complaint/problem is not resolved to your satisfaction at Step 2, you may consider accessing the Formal Grievance Procedure. FORMAL Step 1: W ithin ten working days of the informal procedure, you must submit your grievance to the Clinical Director and the Executive Vice President in writing, with copies to the person with whom you have a grievance. W ithin five working days, the Clinical Director and the Executive Vice President will review the grievance and interview individuals involved in the grievance. A resolution to the com plaint/problem will then be issued in writing. If the com plaint/problem is not resolved by Step 1, you may proceed to Step 2. Step 2: If the grievance is not resolved by Step 1, you must submit your grievance in writing to the President of Mountain Regional Services, Inc., d.b.a. Cornerstone Behavioral Health within five working days. W ithin five working days after receipt of the grievance, the President will review the inform ation and call a meeting of all concerned to resolve the grievance. Other outside parties may be called upon in certain situations to appropriately represent members of minority or other advocacy groups. W ithin five working days, the President will notify all concerned in writing as to his decision/resolution. The decision/resolution of the President will be final. (Signature obtained) For clients participating in the substance abuse program s, if the client is not satisfied with the results of this process, the client make a formal complaint in writing to the Division by writing to: W yoming Department of Health Behavioral Health Division 6101 Yellowstone Road, Suite 220 Cheyenne, W Y Important Health Announcement If you are a moderate to heavy consumer of alcoholic beverages, or if you have ever used any type of IV drugs in the past, you are at higher risk for contracting tuberculosis and/or HIV/AIDS. W e recomm end you contact your personal physician or your local County Public Health unit for tuberculosis and /or HIV/AIDS identification test. The local health unit is Uinta County Public Health 350 City View Drive, Suite 101, Evanston W Y 82930, (307)

16 Cornerstone Staff M ikaela Bernthaler, Psy.D., M S.Ed, M.B.A Staff Psychologist Dr. Bernthaler earned her doctoral degree in clinical psychology from the George W ashington University and com pleted an APA accredited internship at the Albert Einstein College of Medicine - Bronx Psychiatric Center, a state inpatient facility specialized in the psychodynam ic treatm ent of chronically m entally ill and forensic clients. She also com pleted a one year fellowship at the Baltim ore-w ashington Institute for Psychoanalysis. Throughout her training, she worked prim arily in residential and inpatient settings with chronic, m ulti-problem, under-served and culturally diverse adults and their fam ilies, who presented with a wide array of diagnoses including substance use disorders. In these settings, she provided individual and fam ily psychotherapy, psycho-diagnostic assessm ents and led groups. Dr. Bernthaler also holds a Masters Degree in Marriage and Family Therapy from the University of Miami and provided couples and family therapy from a system s perspective. Throughout her training, she has also worked with children and adolescents and was a volunteer in the Guardian ad Litem Program at the 11th Judicial Circuit in Florida. She has considerable experience working with the Hispanic com m unity and is able to provide psychotherapy in Spanish. Dr. Bernthaler is a member of the APA Division of Psychoanalysis. Her primary interests are in psychodynam ic psychotherapy, traum a, gender, group psychology and culture. Ashleigh Bott, Psy.D. Staff Psychologist Dr. Bott com pleted her undergraduate studies in psychology at Indiana University. She continued on to earn a doctoral degree in clinical psychology at the Illinois School of Professional Psychology in Chicago, Illinois. Dr. Bott received training in psychodynam ic theory and practice, and she enjoys working with individuals across the lifespan. She has focused on serving individuals from underserved populations in an inpatient state hospital and residential treatm ent facilities. She com pleted an APA accredited predoctoral internship at Cornerstone Behavioral Health where she rem ains as a licensed psychologist. Dr. Bott s interests include both brief and long-term psychodynam ic psychotherapy, serving individuals with intellectual disabilities, substance abuse and dependency issues, and child and adolescent psychopathology. She also enjoys training future psychologists in psychodynam ic theory and technique, psychodiagnostic assessm ents, and personal and professional development. Cora Courage, Psy. D. Director of Child & Adolescent Services Dr. Courage holds a doctoral degree in clinical psychology from the Minnesota School of Professional Psychology and received training in psychodynam ic theory and practice during several field training experiences. She brings twenty years of experience in dual diagnoses to her practice. The APA accredited predoctoral internship at the VA Medical Center of the Black Hills in South Dakota she com pleted em phasized outreach to rural, under-served, culturally diverse com m unities, and treatm ent of m inority populations. Her m asters degree in counseling psychology from Saint Mary's University integrated the application of psychodynam ic orientation with fam ily system s approaches in the treatm ent of addictions. Her prim ary interests are in psychodynam ic theory and therapy with children and adolescents, trauma and critical incidents, sexuality/gender issues, and the im pact of m ulti-cultural diversity in psychoanalysis. She is a licensed psychologist and a member of the American Psychological Association (Div. 33, 39, 53). Dr. Courage is a Team Leader for the state of W yoming in the Child Trauma Treatment Network of the Intermountain W est, part of the National Child Traumatic Stress Initiative, as well as many local organizations serving the needs of children and adolescents. Dr. Courage is also a com m issioned officer in the Medical Service Corps, serving as the psychologist for the 34th Infantry Division of the Minnesota Arm y National Guard, and a mem ber of the National Health Service Corps.

17 Adam K. Fuller, Ph.D. Clinical Director Director of Internship Training Dr. Fuller earned his doctoral degree in clinical psychology from the Department of Clinical and Health Psychology at the University of Florida. He com pleted an APA accredited predoctoral internship at the State University of New York, Health Science Center in Syracuse (SUNY Upstate Medical Center). In both settings he received extensive experience in outpatient and inpatient psychotherapy and psychodiagnostic testing with adults, adolescents, and children. Other inpatient experiences include group psychotherapy, crisis intervention, and psychotherapy with individuals who had severe and persistent mental disorders. Prior to joining Mountain Regional Services, he worked in a group private practice which provided him the practical experience of applying a psychologist s skills within a m anaged care environm ent. Dr. Fuller s special interests are related to psychoanalytic theory and therapy, the em pirical basis for psychoanalytic principles and treatm ent, and applications of psychodynam ic concepts in brief psychotherapy. He is a member of APA (Divisions 12, 29, and 39) and the W yoming Psychological Association. Patrick J. Lewis, Psy.D. Staff Psychologist Dr. Lewis com pleted his undergraduate studies at W ashington University in St. Louis before earning his m asters and doctoral degrees in Clinical Psychology at The Chicago School of Professional Psychology. Dr. Lewis com pleted an APA-accredited predoctoral internship at Cornerstone Behavioral Health, where he has rem ained as a licensed psychologist. He has pursued training in psychodynamic theory and practice and has applied this specific training and knowledge in his work with individuals, groups, adults, children, fam ilies, and couples. Dr. Lewis has pursued extensive training in working with underserved populations in both urban and rural settings and is interested in psychodynam ic psychotherapy with a relational em phasis. He has also sought extensive training in substance abuse treatm ent and provides substance abuse group therapy at Cornerstone. He is also interested in the im pact of culture and difference in psychotherapy, the experience of depression, the treatment of the disease of addiction, the process of loss and m ourning, sexual orientation and gender issues, and supporting clients in their efforts to live m ore purposeful and satisfying lives. Robert Matzelle, Psy.D. Staff Psychologist Dr. Matzelle com pleted his undergraduate studies at the University of St. Thom as in Houston, Texas. He continued his education at John Jay College of Crim inal Justice earning a Masters degree in Forensic Psychology. Dr. Matzelle com pleted an APA pre-doctoral internship at Cornerstone Behavioral Health where he has rem ained as a licensed psycholoigst. Dr. Matzelle received training in psychodynam ic theory and practice throughout his graduate studies. He has worked with a wide variety of populations from this perspective, including children, fam ilies, couples, and adults. Dr. Matzelle's areas of interest include psychodynam ic psychotherapy with an interpersonal em phasis, traum a and posttraum atic stress, couples therapy, sexual orientation and gender issues. Additionally, Dr. Matzelle has focused on working with underserved populations throughout his training and clinical experiences. Suzanne Petren, Ph.D. Staff Psychologist Dr. Petren holds a Ph.D. degree in counseling psychology from the University of Missouri in Kansas City, Missouri. She is also a licensed attorney, having earned her J.D. degree from the University of Missouri School of Law, where she distinguished herself as Administrative Editor of the Law Review as well as speaker and Appellate writer on the National Moot Court Team. She completed her APA accredited internship at Cornerstone Behavioral Health, where she received training in psychoanalytic theory and substance abuse, working with individuals and groups. W hile at the University of Missouri, she received training in existential phenom enology, biofeedback, and worked extensively with individuals and their supporters through all stages of the cancer experience. Her clinical interests are in psychoanalytic theory

18 and in working with individuals suffering from severe and chronic m ental illness as well as substance abuse. She has a long-standing interest in working with groups. Her publications are in the areas of emotion and group treatment m ethods. She received a National Institute of Health (NIH) Predoctoral Fellowship in the research area of the psychophysiology of em otion. Suzanne Petren was a Fellow of the Am erican Psychoanalytic Association for Outstanding Early Career Psychologist. Brian Schaffer, Psy.D. Staff Psychologist Dr. Brian Schaffer com pleted his doctoral degree at Nova Southeastern University in Fort Lauderdale, Florida. W hile at Nova, Dr. Schaffer received training in understanding the com plex underlying m otivations, emotions, and other factors which can contribute to or impede mental well-being. He has experience working in a variety of settings, including com m unity mental health centers, inpatient and com m unity based treatm ent centers, and private practice. He has worked with individuals suffering from a wide range of psychological disorders such as depression, substance abuse disorders, bi-polar illness, as well as those who are sim ply interested in learning more about them selves. Dr. Schaffer has specialized interest in treating individuals with a developm ental disability, as well as in unique approaches to m anaging severe disorders such as schizophrenia. Dr. Schaffer also takes part in training future psychologists as part of an APA accredited internship program, in which he focuses on the application of psychodynam ic theory in a pragm atic fashion, as it applies to both clinical work and facilitation of effective treatment team functioning. Mountain Regional Services, Inc. Code of Ethics The Board of Directors, management and staff of Mountain Regional Services, Inc. (MRSI) are committed to the highest level of perform ance, professionalism and ethical conduct in every aspect of service delivery. All actions are guided by the organization s m ission of assisting each person served in achieving the highest quality of life, and seek to deliver outcomes that reflect client choice, dignity and well-being.! Qualified individuals shall have access to services and will not be discrim inated against based on race, color, religion, age, sexual orientation, disability or national origin. Client rights, as documented in MRSI s Client Handbook and each Individual Plan of Care, will be respected at all tim es. Services will be designed around the needs of clients and delivered in a respectful, professional m anner.! Board members, management and staff will keep as a priority the welfare of those receiving services. Professional em ployees are expected to adhere to the rules and regulations governing their profession. All em ployees m ust represent their credentials, com petency, education, training and experience in a truthful and accurate m anner.! Every employee is expected to be vigilant with regard to issues of abuse, fraud, waste, etc. MRSI adheres to a no reprisal policy for reporting im proprieties whereby em ployees are encouraged to report concerns in the workplace, including violations of the law, regulations, ethical standards, and com pany policies, and seek clarification and guidance when in doubt. MRSI s m anagem ent and/or Board of Directors will investigate reported wrongdoings in a timely manner.! MRSI will strive to provide em ployees with a productive, satisfying work experience and will advocate for continued career developm ent and self-improvem ent. MRSI s Em ployee Guidelines and training program s (i.e., CPI/APT, Abuse & Neglect) provide employees with com prehensive information regarding staff rights, responsibilities, and ethical codes of conduct.! Business and financial practices will be conducted in accordance with all applicable laws, regulations and recognized ethical business practices. MRSI follows closely the code of professional ethics of the Am erican Institute of Certified Public Accountants and the W yom ing Society of Certified Public Accountants. This includes but is not lim ited to the obligation to prom ote

19 sound and inform ative financial decisions and reporting. MRSI recognizes that it has a responsibility to the public which consists of clients, creditors, governm ents, em ployees and the business/financial community. The organization requires that a CPA hold the position of CFO and adhere to all ethical requirem ents of the position. Contractual relationships will be in accordance with all laws and legal requirements, sound business principals and moral and ethical conduct.! The organization s marketing activities will be driven by a commitment to represent persons with disabilities in a dignified m anner. Marketing activities will com plim ent MRSI s m ission, and client choice and confidentiality will be respected and serve as a guide for all prom otional activities. All m arketing actions will be undertaken with the intent of positively influencing society with regard to persons served and services offered, with the ultim ate goal of achieving understanding, acceptance and integration.! MRSI will take every opportunity to promote opportunities for individuals with disabilities. Educational efforts will include the general public, service clubs, local/state/national legislators, etc., and will focus on rights, funding and acceptance. Additionally, the organization will engage in com m unity activities that highlight the beneficial im pact disability service providers have on com m unities were business is conducted.! Any person associated/em ployed with MRSI who is accused of violating MRSI s Code of Ethics, with due process, may be dismissed or sanctioned. Cornerstone s hours of operation for mental health services are as follows: Monday - Friday8:00 AM - 5:00 PM* Hours may be extended depending on client need Cornerstone s hours of operation for substance abuse treatment programs are as follows: Adolescent Outpatient (AOP) Monday 4:00 PM -6:00 PM* Adolescent Intensive Outpatient Program (AIOP) Monday, Tuesday, Friday 3:45 PM - 5:45 PM* Thursday 3:45 PM - 6:45 PM* Adolescent Aftercare Tuesday 4:00 PM - 6:00 PM* Minor in Possession School (MIP) Saturday (Every other month) 8:00 AM - 5:00 PM Adult Outpatient (OP) Monday 6:00 PM - 8:00 PM* Adult Intensive Outpatient Program (IOP) Monday, Tuesday, Friday 6:00 PM - 9:00 PM* Adult Aftercare W ednesday 5:15 PM - 7:15 PM*

20 DUI School Saturday (Every other month) 8:00 AM - 5:00 PM * Session times may be extended based on group dynamics General Information Cornerstone Behavioral Health is nationally accredited by CARF and the State of W yom ing Behavioral Health Departm ent. Treatm ent providers at Cornerstone are expected to adhere to the rules and regulations governing their professions as well as those mandated by CARF and the W yoming Department of Health. Funding for Cornerstone programs is provided in part by The W yoming Department of Health, Behavioral Health Departm ent. In the event individuals receiving services at Cornerstone Behavioral Health need after hours or emergency assistance, they should contact the following providers: High Country Behavioral Health Evanston Regional Hospital Emergency Services 911 Poison Center M ountain Regional Services Inc. (M RSI) Also dba Cornerstone Behavioral Health NOTICE OF PRIVACY PRACTICES Effective: April 14, 2003 Amended: February 1, 2006 Amended: April 1, 2011 THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION PLEASE REVIEW IT CAREFULLY This notice will tell you how we may use and disclose protected health information about you. Protected health information means any health information about you that identifies you or for which there is a reasonable basis to believe the information can be used to identify you. This notice also will tell you about your rights and our duties with respect to protected health information about you. In addition, it will tell you how to complain to us if you believe we have violated your privacy rights. How We May Use and Disclose Protected Health Information About You. We use and disclose protected health information about you for a number of different purposes. Each of those purposes is described below. For Treatment (45 CFR (b)(1)(ii)(a) We may use protected health information about you to provide, coordinate or manage your health care and related services by both us and other health care providers. We may disclose protected health information

21 about you to doctors, nurses, hospitals and other health facilities who become involved in your care. We may consult with other health care providers concerning you and as part of the consultation share your protected health information with them. Similarly, we may refer you to another health care provider and as part of the referral share protected health information about you with that provider. For example, we may conclude you need to receive services from a physician with a particular specialty. When we refer you to that physician, we also will contact that physician s office and provide protected health information about you to them so they have information they need to provide services for you. For Payment. (45 CFR (b)(1)(ii)(a) We may use and disclose protected health information about you so we can be paid for the services we provide to you. This can include billing you, your insurance company, or a third party payer. For example, we may need to give your insurance company information about the health care services we provide to you so your insurance company will pay us for those services or reimburse you for amounts you have paid. We also may need to provide your insurance company or a government program, such as Medicare or Medicaid, with information about your medical condition and the health care you need to receive to obtain and determine if you are covered by that insurance or program. For Health Care Operations. (45 CFR (b) (1) (ii) (A) We may use and disclose protected health information about you for our own health care operations. These are necessary for us to operate MRSI and to maintain quality health care for our patients. For example, we may use protected health information about you to review the services we provide and the performance of our employees in caring for you. We may disclose protected health information about you to train our staff and students working with MRSI. We may also use the information to study ways to more efficiently manage our organization. How we will contact you. Unless you tell us otherwise in writing, we may contact you by either telephone or by mail at either your home or your office. At either location, we may leave messages for you on the answering machine or voice mail. If you want to request that we communicate to you in a certain way or at a certain location, see A Right to Receive Confidential Communications on page five of this Notice. Appointment Reminders. (45 CFR (b) (1) (iii) (A) We may use and disclose protected health information about you to contact you to remind you of an appointment you have with us. Treatment Alternatives. (45 CFR (b) (1) (iii) (A) We may use and disclose protected health information about you to contact you about treatment alternatives that may be of interest to you. Health Related Benefits and Services. (45 CFR (b) (1) (iii) (A) We may use and disclose protected health information about you to contact you about health related benefits and services that may be of interest to you. Individuals Involved in Your Care. (45 CFR (b) We may disclose to a family member, other relative, a close personal friend, or any other person identified by you, protected health information about you that is directly relevant to that person s involvement with your care or payment related to your care. We also may use or disclose protected health information about you to notify, or assist in notifying, those persons of your location, general condition, or death. If there is a family member, other relative, or close personal friend that you do not want us to disclose protected health information about you, please notify or tell our staff member who is providing care to you. Personal Representatives. (45 CFR (g)(1) In general, MRSI must treat a personal representative as the individual with respect to protected health information under the Privacy Rule unless an exception applies. Personal representatives are those people who, under applicable law, have the authority to act on behalf of an individual in making health care decisions for the individual. Types of Personal Representatives 1. Persons who have broad authority to act on the behalf of a living individual in making health care decisions.

22 The covered entity must treat this type of personal representative as the individual for all purposes under the Privacy Rule, unless an exception applies. Example: A parent with respect to a minor child or a legal guardian of a mentally incompetent adult. 2. Persons who have the authority to act on behalf of a living individual in only limited health care situations. The covered entity should only treat this type of personal representative as the individual under the Privacy Rule with respect to protected health information related to the limited health care situation for which the personal representative has authority to act. Example: A person has an individual s limited health care power of attorney only regarding the individual s use of artificial life support. In this example, the covered entity should only treat the personal representative as the individual, under the Privacy Rule, with respect to protected health information relevant to the use of artificial life support, and not for other health care decisions. 3. Persons who have the authority to act on behalf of a deceased individual or his/her estate, which does not have to include the authority to make decisions related to health care. Example: A person may be the executor of an individual s estate - in such a case, the covered entity must treat this type of personal representative as the individual for all purposes under the Privacy Rule. Exceptions to the General Rule 1. The Privacy Rule specifies three circumstances in which the parent, guardian, or other person acting in loco parentis (parent) is not the personal representative with respect to certain health information about his or her unemancipated minor child. In these situations, the parent does not control the unemancipated minor s health care decisions and, thus, under the Privacy Rule, does not control the protected health information related to that care. The three exceptional circumstances when a parent is not the unemancipated minor s personal representative are: a. When State or other law does not require the consent of a parent or other person before a minor can obtain a particular health care service, and the minor consents to the health care service. Example: A State law provides an adolescent the right to obtain mental health treatment without the consent of his or her parent, and the adolescent has consented to such treatment without the parent s consent. b. When a court determines or other law authorizes someone other than the parent to make treatment decisions for a minor. Example: A court may grant authority to make health care decision(s) for the minor to an adult other than the parent or to the minor, or the court may make the decision(s) itself. c. When a parent agrees to a confidential relationship between the minor and the physician. Example: A physician asks the parent of a 16-year-old if the physician can talk with the child confidentially about a medical condition and the parent agrees. Important Note: Even in these three exceptional circumstances in which the parent is not the personal representative of the minor under the Privacy Rule and is not treated as the individual under the Privacy Rule, the Privacy Rule permits the covered entity to disclose to a parent, or provide the parent access to, an unemancipated minor s protected health information, if there is State of other law that requires or permits such disclosure or access. Likewise, even in these three exceptional circumstances, the Privacy Rule permits the covered entity to refuse to disclose to a parent, or refuse to provide the parent access to, an unemancipated minor s protected health information, if there is State or other law that prohibits such disclosure or access. Further, in these three exceptional circumstances, if State or other law is silent or unclear concerning parental access to the minor s protected health information, the Privacy Rule permits a covered entity to have discretion to provide or deny a parent with access to the unemancipated minor s protected health information, if doing so is consistent with State or other applicable law, and provided the decision is made by a licensed health care professional in the exercise of professional judgment. 2. When a physician or other covered entity reasonably believes that an individual, including an unemancipated minor, has been or may be subjected to domestic violence, abuse or neglect by the personal representative, or that treating a person as an individual s personal representative could endanger the

23 individual, the covered entity may choose not to treat that person as the individual s personal representative, if in the exercise of professional judgment, doing so would not be in the best interests of the individual. Disaster Relief. (45 CFR (b) (4) We may use or disclose protected health information about you to a public or private entity authorized by law or by its charter to assist in disaster relief efforts. This will be done to coordinate with those entities in notifying a family member, other relative, close personal friend, or other person identified by you of your location, general condition or death. Required by Law. (45 CFR (a) We may use or disclose protected health information about you when we are required to do so by law. Public Health Activities. (45 CFR (b) We may disclose protected health information about you for public health activities and purposes. This includes reporting medical information to a public health authority that is authorized by law to collect or receive the information for purposes of preventing or controlling disease. Or, one that is authorized to receive reports of child abuse and neglect. Victims of Abuse, Neglect or Domestic Violence. (45 CFR We may disclose protected health information about you to a government authority authorized by law to receive reports of abuse, neglect, or domestic violence, if we believe you are a victim of abuse, neglect, or domestic violence. This will occur to the extent the disclosure is: (a) required by law; (b) agreed to by you; or,(c) authorized by law and we believe the disclosure is necessary to prevent serious harm to you or to other potential victims, or, if you are incapacitated and certain other conditions are met, a law enforcement or other public official represents that immediate enforcement activity depends on the disclosure. Health Oversight Activities. (45 CFR (d) We may disclose protected health information about you to a health oversight agency for activities authorized by law, including audits, investigations, inspections, licensure or disciplinary actions. These and similar types of activities are necessary for appropriate oversight of the health care system, government benefit programs, and entities subject to various government regulations. Judicial and Administrative Proceedings. (45 CFR (e) We may disclose protected health information about you in the course of any judicial or administrative proceeding in response to an order of the court or administrative tribunal. We also may disclose protected health information about you in response to a subpoena, discovery request, or other legal process but only if efforts have been made to tell you about the request or to obtain an order protecting the information to be disclosed. Disclosures for Law Enforcement Purposes. (45 CFR (f) We may disclose protected health information about you to a law enforcement official for law enforcement purposes: As required by law. a. In response to a court, grand jury or administrative order, warrant or subpoena. b. To identify or locate a suspect, fugitive, material witness or missing person. c. About an actual or suspected victim of a crime and that person agrees to the disclosure. If we are d. unable to obtain that person s agreement, in limited circumstances, the information may still be disclosed. To alert law enforcement officials to a death if we suspect the death may have resulted from criminal e. conduct. About crimes that occur at our facility. f. To report a crime in emergency circumstances. g.

24 Coroners and Medical Examiners. (45 CFR (g) (1) We may disclose protected health information about you to a coroner or medical examiner for purposes such as identifying a deceased person and determining cause of death. Funeral Directors. (45 CFR (g)(2) We may disclose protected health information about you to funeral directors as necessary for them to carry out their duties. Organ, Eye or Tissue Donation. (45 CFR (h) To facilitate organ, eye or tissue donation and transplantation, we may disclose protected health information about you to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue. Research. (45 CFR (I) Under certain circumstances, we may use or disclose protected health information about you for research. Before we disclose protected health information for research, the research will have been approved through an approval process that evaluates the needs of the research project with your needs for privacy of your protected health information. We may, however, disclose protected health information about you to a person who is preparing to conduct research to permit them to prepare for the project, but no protected health information will leave MRSI during that person s review of the information. To Avert Serious Threat to Health or Safety. (45 CFR )(j) We may use or disclose protected health information about you if we believe the use or disclosure is necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public. We also may release information about you if we believe the disclosure is necessary for law enforcement authorities to identify or apprehend an individual who admitted participation in a violent crime or who is an escapee from a correctional institution or from lawful custody. Military. (45 CFR (k) (1) If you are a member of the Armed Forces, we may use and disclose protected health information about you for activities deemed necessary by the appropriate military command authorities to assure the proper execution of the military mission. We may also release information about foreign military personnel to the appropriate foreign military authority for the same purposes. National Security and Intelligence. (45 CFR (k)(2) We may disclose protected health information about you to authorized federal officials for the conduct of intelligence, counter-intelligence, and other national security activities authorized by law. Protective Services for the President. (45 CFR (k) (3) We may disclose protected health information about you to authorized federal officials so they can provide protection to the President of the United States, certain other federal officials, or foreign heads of state. Inmates; Persons in Custody. (45 CFR (k) (5) We may disclose protected health information about you to a correctional institution or law enforcement official having custody of you. The disclosure will be made if the disclosure is necessary: (a) to provide health care to you; (b) for the health and safety of others; or, (c) the safety, security and good order of the correctional institution. Workers Compensation. (45 CFR (l) We may disclose protected health information about you to the extent necessary to comply with workers compensation and similar laws that provide benefits for work-related injuries or illness without regard to fault. Other Uses and Disclosures. Other uses and disclosures will be made only with your written authorization. You may revoke such an authorization at any time by notifying MRSI, P.O. Box 6005, Evanston, WY 82931, in writing of your desire

25 to revoke it. However, if you revoke such an authorization, it will not have any effect on actions taken by us in reliance on it. Your Rights With Respect to Medical Information About You. You have the following rights with respect to protected health information that we maintain about you. Right to Request Restrictions. (45 CFR (b) (iv) (A); 45 CFR (a) (1) You have the right to request that we restrict the uses or disclosures of protected health information about you to carry out treatment, payment, or health care operations. You also have the right to request that we restrict the uses or disclosures we make to: (a) a family member, other relative, a close personal friend or any other person identified by you; or, (b) for public or private entities for disaster relief efforts. For example, you could ask that we not disclose protected health information about you to your brother or sister. To request a restriction, you may do so at the time you complete your consent form or at any time after that. If you request a restriction after that time, you should do so in writing to MRSI P.O. Box 6005, Evanston, WY 82931, and tell us: (a) what information you want to limit; (b) whether you want to limit use or disclosure or both; and, (c) to whom you want the limits to apply (for example, disclosures to your spouse). We are not required to agree to any requested restriction. However, if we do agree, we will follow that restriction unless the information is needed to provide emergency treatment. Even if we agree to a restriction, either you or we can later terminate the restriction. Right to Receive Confidential Communications. (45 CFR (b) (iv) (B); 45 CFR (b)(1) You have the right to request that we communicate protected health information about you to you in a certain way or at a certain location. For example, you can ask that we only contact you by mail or at work. We will not require you to tell us why you are asking for the confidential communication. If you want to request confidential communication, you must do so in writing to President, MRSI P.O. Box 6005, Evanston, WY Your request must state how or where you can be contacted. We will accommodate your request. However, we may, when appropriate, require information from you concerning how payment will be handled. Right to Inspect and Obtain a Copy. (45 CFR (b) (iv) (C); 45 CFR ) With a few very limited exceptions, such as psychotherapy notes, you have the right to inspect and obtain a copy of protected health information about you. To inspect or obtain a copy of protected health information about you, you must submit your request in writing to President, MRSI, P.O. Box 6005, Evanston, WY Your request should state specifically what protected health information you want to inspect or obtain a copy. If you request a copy of the information, we may charge a fee for the costs of copying and, if you ask that it be mailed to you, the cost of mailing. We will act on your request within thirty (30) calendar days after we receive your request. If we grant your request, in whole or in part, we will inform you of our acceptance of your request and provide access and copying. We may deny your request to inspect and copy protected health information if the protected health information involved is: a. Psychotherapy notes; b. Information compiled in anticipation of, or use in, a civil, criminal or administrative action or proceeding; If we deny your request, we will inform you of the basis for the denial, how you may have our denial reviewed, and how you may complain. If you request a review of our denial, it will be conducted by a licensed health care professional designated by us who was not directly involved in the denial. We will comply with the outcome of that review. Right to Amend. (45 CFR (b) (iv) (D); 45CFR ) You have the right to ask us to amend protected health information about you.

26 You have this right for as long as the protected health information is maintained by us. To request an amendment, you must submit your request in writing to; President, MRSI P.O. Box 6005, Evanston, WY Your request must state the amendment desired and provide a reason in support of that amendment. We will act on your request within sixty (60) calendar days after we receive your request. If we grant your request, in whole or in part, we will inform you of our acceptance of your request and provide access and copying. If we grant the request, in whole or in part, we will seek your identification of and agreement to share the amendment with relevant other persons. We will also make the appropriate amendment to the protected health information by appending or otherwise providing a link to the amendment. We may deny your request to amend protected health information about you. We may deny your request if it is not in writing and does not provide a reason in support of the amendment. In addition, we may deny your request to amend protected health information if we determine that the information: Was not created by us, unless the person or entity that created the information is no longer available a. to act on the requested amendment; Is not part of the protected health information maintained by us: b. Would not be available for you to inspect or copy; or, c. Is accurate and complete. d. If we deny your request, we will inform you of the basis for the denial. You will have the right to submit a statement of disagreement with our denial. Your statement may not exceed 10 pages. We may prepare a rebuttal to that statement. Your request for amendment, our denial of the request, your statement of disagreement, if any, and our rebuttal, if any, will then be appended to the protected health information involved or otherwise linked to it. All of that will then be included with any subsequent disclosure of the information, or, at our election, we may include a summary of any of that information. If you do not submit a statement of disagreement, you may ask that we include your request for amendment and our denial with any future disclosures of the information. We will include your request for amendment and our denial (or a summary of that information) with any subsequent disclosure of the protected health information involved. You also will have the right to complain about our denial of your request. Right to an Accounting of Disclosures. (45 CFR (b)(iv)(e); 45 CFR ) You have the right to receive an accounting of disclosures of protected health information about you. The accounting may be for up to six (6) years to the date on which you request the accounting but not before April 14, Certain types of disclosures are not included in such an accounting: a. Disclosures to carry out treatment, payment and health care operations; b. Disclosures of your protected health information made to you; c. Disclosures for national security or intelligence purposes; d. Disclosures to correctional institutions or law enforcement officials; e. Disclosures made prior to April 14, Under certain circumstances your right to an accounting of disclosures may be suspended for disclosures to a health oversight agency or law enforcement official. To request an accounting of disclosures, you must submit your request in writing to President, MRSI, P.O. Box 6005, Evanston, WY Your request must state a time period for the disclosures. It may not be longer than six (6) years from the date we receive your request and may not include dates before April 14, Usually, we will act on your request within sixty (60) calendar days after we receive your request. Within that time, we will either provide the accounting of disclosures to you or give you a written statement of when we will provide the accounting and why the delay is necessary. There is no charge for the first accounting we provide to you in any twelve (12) month period. For additional accountings, we may charge you for the cost of providing the list. If there will be a charge, we will notify you of the cost involved and give you an opportunity to withdraw or modify your request to avoid or reduce the fee.

27 Right to Copy of this Notice. (45 CFR (b) (iv) (F) You have the right to obtain a paper copy of our Notice of Privacy Practices. You may obtain a paper copy even though you agreed to receive the notice electronically. You may request a copy of our Notice of Privacy Practices at any time. You may obtain a copy of our Notice of Privacy Practices over the Internet at our web site To obtain a paper copy of this notice, contact MRSI, P.O. Box 6005, Evanston, WY 82931, Our Duties Generally. We are required by law to maintain the privacy of protected health information about you and to provide individuals with notice of our legal duties and privacy practices with respect to protected health information. (45 CFR (b) (v)(a) We are required to abide by the terms of our Notice of Privacy Practices in effect at the time. (45CFR (b) (v) (B) Our Right to Change Notice of Privacy Practices. We reserve the right to change this Notice of Privacy Practices. We reserve the right to make the new notice s provisions effective for all protected health information that we maintain, including that created or received by us prior to the effective date of the new notice. (45 CFR (b) (v) (C) Availability of Notice of Privacy Practices. A copy of our current Notice of Privacy Practices will be posted in our Wyoming facilities. A copy of the current notice also will be posted on our web site, In addition, each time you are admitted to services at MRSI, a copy of the current notice will be made available to you. At any time, you may obtain a copy of the current Notice of Privacy Practices by contacting MRSI, P.O. Box 6005, Evanston, WY 82931, Effective Date of Notice. The effective date of the notice will be stated on the first page of the notice. Complaints. You may complain to us and to the United States Secretary of Health and Human Services if you believe your privacy rights have been violated by us. To file a complaint with us, contact the Corporate Compliance Officer, MRSI, P.O. Box 6005, Evanston, WY 82931, All complaints should be submitted in writing. To file a complaint with the United States Secretary of Health and Human Services, send your complaint to him or her in care of: Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Avenue SW, Washington, D.C You will not be retaliated against for filing a complaint. Questions and Information. If you have any questions or want more information concerning this Notice of Privacy Practices, please contact: Mountain Regional Services President P.O. Box 6005 Evanston, WY 82931

28 Fire and other emergencies: All clients are expected to be knowledgeable of and pay strict adherence to all fire rules. This is strictly enforced for your protection. 1. You will fam iliarize yourself with the building floor plan and nearest exit from where you are located as well as fire suppression equipment and first aid kit (see map). 2. If you notice fire or smoke and the alarm has not been sounded, notify any staff person im m ediately. 3. W hen the alarm sounds, walk quickly to the nearest exit and proceed to the designated site (North East corner of Cornerstone parking lot). 4. Everyone is to remain in the designated area until the fire is out or until directed by staff person or em ergency personnel. 5. Maintain a clean, safe environm ent for yourself and others while at Cornerstone to include keeping a safe path of exit/egress in each area in case of an emergency exit. 6. Emergency drills may be given without warning, and you will need to learn to recognize the alarm system and the appropriate response for each em ergency. 7. A review of MRSI/Cornerstone Behavioral Health s Em ergency Disaster Plan for fire and other em ergency procedures is available upon request by contacting the Adm inistrative Director (or designee). NOTES

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