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Policy Overview

The Family Educational Rights and Privacy Act (FERPA) of 1974, as amended, sets out requirements designed to afford students certain rights with respect to their education records. In addition, it puts limits on what information the institution may disclose to third parties without receiving prior written consent from the student via a FERPA release form, an authorized signature on another document or a lawfully-issued subpoena or judicial order.

The Registrar’s office maintains student educational records, provides students access to their records, and keeps information contained in those records confidential as required by FERPA. The Act covers anyone who is or has been enrolled at the institution.

Education records are defined as official records that are directly related to a student and maintained by the Registrar. When a record contains personally identifiable information about more than one student, the student may inspect and review only the information that relates to them personally.

Cummings Graduate Institute is committed to protecting the privacy of our students, full-time faculty, adjunct faculty, board members, team members, alumni, and any other stakeholders in all communications and documents in the institution’s possession. This information includes, but is not limited to, social security numbers, credit card numbers and check information, personal and financial information, academic transcripts from schools, academic records at this institution, and/or emails. Such information belongs exclusively to the individual and cannot be released outside of the institution without the prior written approval of the individual who owns these records, except as provided under the Family Educational Rights and Privacy Act (FERPA).

Cummings Graduate Institute maintains student educational records, provides students access to their records, and keeps information contained in those records confidential as required by FERPA. FERPA covers anyone who is or has been enrolled at the institution, including the following:

  • Active students currently enrolled in a program
  • Former students and alumni
  • Administrative staff members, full-time faculty members, and adjunct faculty members

When operating websites, Cummings Graduate Institute takes special measures to ensure the confidentiality of the information is protected. A privacy statement appears on the websites that explains what information Cummings Graduate Institute may collect through our websites, why the institution collects such information, how the information is protected, and the choices stakeholders have about how Cummings Graduate Institute uses the information.

Cummings Graduate Institute has the obligation to safeguard this information and to ensure the stakeholders are protected.

Disclosure of Educational Records

Generally, schools must have written permission from the eligible student in order to release any information from a student’s education record. However, FERPA allows schools to disclose those records, without consent, to the following parties or under the following conditions (34 CFR § 99.31):

  • School officials with legitimate educational interest
  • State and Federal Regulatory Agencies
  • Other schools to which a student is transferring
  • Specified officials for audit or evaluation purposes
  • Appropriate parties in connection with financial assistance to a student
  • Organizations conducting certain studies for or on behalf of the school
  • Accrediting organizations
  • Compliance with a judicial order or lawfully-issued subpoena
  • Appropriate officials in cases of health and safety emergencies or crises
  • State and local authorities, within a juvenile justice system, pursuant to specific State law

The Cummings Graduate Institute has designated certain types of information as “Directory Information,” which may be disclosed without a student’s consent.

Directory Information

The term “Directory Information” means information contained in a student record that would not generally be considered harmful or an invasion of privacy if disclosed to the public. The following information has been designated by Cummings Graduate Institute as Directory Information:

  • Student’s name
  • Email address
  • Major field of study
  • Dates of attendance
  • Enrollment status
  • Graduation status

This information may be released to interested parties who request for purposes of, but not limited to, the following:

  • Employment
  • Volunteer opportunities
  • Rental/credit checks
  • Verification of degree conferral
  • Gathering for research.

Per the Personally Identifiable Information Policy, new and continuing students at Cummings Graduate Institute can contact the Registrar at registrar@cgi.edu to adjust what they want as Directory Information.

Cummings Graduate Institute will annually notify students of their rights under FERPA. Students may request nondisclosure of student directory information by completing a FERPA – Nondisclosure Form. Failure to request nondisclosure of directory information may result in disclosure of one or more of the above-designated categories of directory information.

Non-Directory Information

Non-directory information is considered any information that is not listed as directory information. This information may not be released without the prior written consent of the current or former students. Students can request consent by completing a FERPA – Authorization of Information Release Form. Once the completed form is submitted, The Registrar follows up via phone to legitimize all information and consent.

Policy Responsibility

Student Responsibility

It is the responsibility of the student to review the policy and submit any FERPA forms as needed.

Registrar

It is the responsibility of the Registrar to respond to all student inquiries within the time limits set out by the policy.

Policy and Compliance Office

It is the responsibility of the Policy and Compliance Office to audit the compliance of the FERPA policy.

Staff, Faculty, Board of Directors, and Students

It is the responsibility of the staff, faculty, Board of Directors, and students to ensure the privacy of all students, according to the FERPA Policy.

Policy Procedure

Procedure to Inspect and Retrieve Education Records

Under FERPA, students have the right to inspect and review their education records. A student who wishes to inspect and review their records should submit an email request to the Registrar at registrar@cgi.edu.

All records requests will be responded to within 14 calendar days from the date of receipt of the request. If the requested records are subject to inspection and review by the student, arrangements for access will be made within a reasonable period of time, but in no case more than 45 calendar days after the request was made.

Request to Correct Education Records

Students have the right to request an amendment of education records if they believe the records are inaccurate or misleading. The request for amendment must be made in writing and include a notarized signature. The request must be sent to the attention of the Registrar, via email at registrar@cgi.edu or mail to the administrative offices, and must identify the part(s) of the education records to be amended and specifying the reasons why the student believes the information is inaccurate or misleading.

The Registrar shall notify the student of the decision within 15 calendar days of the receipt of the request. If the Registrar denies the student’s request to correct education records, the student has the right to file a grievance. If a student wishes to file a grievance, they should review the Complaint and Grievance Policy.

Forms

FERPA – Authorization of Information Release Form

FERPA – Non Disclosure Form

Approvals/Revision History

Policy was revised on: June 15th, 2020

Policy was approved by: Amanda Harrison, Chief Operating Officer

Testimonials

The totally online DBH program offered by Cummings Graduate Institute of Behavioral Health Studies is focused on the professional I have grown into: a synergistic disrupter for the healthcare industry, who is passionate about Wholistic Healthcare (e.g., health, behavioral health, and Social Determinants of Health and Mental Health), rendered skillfully through interprofessional teams. The program pillars of medical literacy, integrated behavioral health interventions, and entrepreneurship resonate loudly with me. The healthcare industry will continue to change, with doctoral level professionals needed to play a major role in any successful transformation. My goal is to further advance my knowledge-base, professional standing, and industry commitment to be part of these transformational efforts. In this way I can heed the Quadruple Aim: assuring quality-driven patient-centric care is rendered at the right time, through the right population-based treatment processes, at the right cost, and by empowered professionals embracing the work and committed to their charge.

Ellen Fink-Samnick MSW, ACSW, LCSW, CCM, CRPDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - March 11, 2020

In the time that I have been a student at CGI, I have learned that integrated healthcare is no longer the exception; providers want behavioral health clinicians on their team. My courses demonstrate that the services that a DBH can offer are valuable and the opportunities abound. I’m learning that as a DBH, I can work to create a new norm in healthcare, one that promotes holistic care provided by a collaborative team delivering diverse services. I now view behavioral healthcare as a crucial piece of the medical care puzzle, rather than a separate entity. I can see the gaps in care that a DBH can fill and why including a DBH in treatment is critical. I am beginning to see how I will play a role in disrupting healthcare to provide quality treatment while advocating for my patients. Although I may still have to explain my role at times, I am learning that once I do, others will seek out my services. I am gaining confidence in what I bring to the medical team and am continuously expanding my knowledge of what else I can do.

Jennifer KellyDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - July 26, 2020

As a Social Worker, I believe my main mission includes advocating for and empowering patients. The DBH degree will allow me to fully integrate the “medical side of the house” with the “behavioral health side”. My experience working side-by-side with medical providers (PCM’s, ED docs, Hospitalists, etc…) has shown that most of them do not understand behavioral health issues nor how medical symptoms or diagnoses can effect a patients’ mental health and vice-versa. Alternatively, I have worked with a multitude of behavioral health providers who have very limited knowledge of how medical issues might affect their clients. I have often wondered how many patients I have had who were diagnosed with depression or anxiety or other DSM-V diagnosis when in reality the origin was medical. Earning a DBH will allow me to push the envelope when it comes to consulting with medical providers and promote the inclusion of “behavioral healthcare” within “healthcare” as its ALL healthcare! As Mahatma Ghandi said “be the change you wish to see in the world”; earning a DBH will enhance my ability to “change the world” – even if it’s one medical provider or one patient at a time.

Diane Scott, MSW, LCSWDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - August 7, 2020

My friend and I were talking about the challenges and frustrations that we face daily in our careers with the clear divide between mental health and physical health and how we wished we had the knowledge and skills to shake up healthcare and bridge the gap. She brought up researching doctorate programs and how interested she was in the DBH. My reponse was, “What on earth is a DBH?” She laughed and said it was a newer doctorate degree in behavioral health, that focused directly on integrated care and doing exactly what we were dreaming of doing….shaking up healthcare and bridging the gap and treating the person as a whole. I had a hard time believing her. It sounded too good to be true. How was there a degree out there that fit my goals and aspirations to a T without me knowing about it? I had been looking periodically throughout my 20 year journey in behavioral health for a program that resonated with me. It was here all this time? How had I missed it? I immediately spent hours scouring the internet to find any crumb of information that I could about the Doctorate of Behavioral Health and the programs associated with it. Then I hit the jackpot. I found the Cummings Graduate Institute for Behavioral Health Studies.

Amy McConnell, LCSWDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - September 18, 2020

During my tenure as a student at CGI, I wrote a book review that was published in the International Journal of Integrated Care. One of my papers became a newsletter article, a pitch for my population health class became a poster presented at a CFHA conference, a book chapter was developed based on a paper I wrote for my independent study, and I am submitting my CP project to a journal this weekend. So, everything that you write during the program is potentially publishable! You have the advantage of having faculty read and give you feedback on it before submitting it. Take risks! The worst that can happen if you submit a paper for publication is receiving a rejection letter. Well, if you don’t send it you’re already acting as if the paper had been rejected. 😉 Plus, if you receive a rejection letter, it usually comes with feedback, so you can improve your paper and send it again!

Dr. Liliane de Aguiar-Rocha, DBH, BCBADBH Alumni, Cummings Graduate Institute for Behavioral Health Studies - October 9, 2020

There is a substantial need for integrating care between our physical, and mental health. The gap between these domains are more so overlooked among those with developmental delays and intellectual disabilities – the very population I serve as a Behavior Analyst. Filling these gaps entails work that demands for a DBH who is competent, empathetic, and altruistic.

Pauline Pablo, BCBADBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - November 11, 2020

My interest in a DBH degree grew out of frustration and hope. On one hand, I grew frustrated with the quality of care my clients with intellectual and developmental disabilities were receiving. As members of a marginalized population who lack the skills to advocate for themselves, the clients I serve receive subpar medical care, mental health care, and behavioral health care. Many healthcare providers are not trained to address the unique language and cognitive challenges present when serving a person with Autism and I/DD.

On the other hand, as I learned more about the DBH program, a potential solution came into view. I believe this program will allow me to acquire the knowledge and skills to become a better advocate for my clients, and new job opportunities will open up in positions in which I will be able to make a bigger impact on a system level, thus improving quality of life for many clients. A DBH degree will command interest and respect from other healthcare professionals who are evaluating their practices and noticing areas in which they are not being effective, namely the behavioral health side of the equation. As we are learning in our first classes about the Biodyne Model, the Integrated Care Model is not widely accepted or known in the healthcare field, despite its proven track record. I believe a DBH degree provides the necessary tool to change the landscape of healthcare provision by arming my passion for this topic with knowledge and concrete strategies.

Valeria ParejoDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - January 15, 2021

As a Doctorate of Behavioral Health (DBH) student my vision for healthcare is to disrupt the current model, close gaps to care and create healthcare improvements. In the evolving world of healthcare I believe behavioral healthcare providers (BCP) are essential to the development of integrative healthcare. Once I obtain a DBH degree, I know I will gain a leadership role and be able to add quality to the creation of integration efforts worldwide. I know I will graduate with the essential tools I need to stand at the forefront of integrated healthcare. I want to create healthcare improvements for marginalized populations that are typically underserved or forgotten. As an individual of two minority groups; woman and African American, I am very passionate about helping reduce cultural, ethnic, social economic and geographic disparities within healthcare systems.

Ebony WatsonDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - March 30, 2021

Since beginning my studies at CGI, I have been awakened to how much I truly did not know and understand despite my specialty training in Social Work and behavioral health needs. The classes at CGI allow me to explore topics that I may not have thought to investigate and encourage me to question and think outside the “normal” delivery of behavioral health services. Services that I previously thought were quality and designed to meet the needs of special populations, I now believe to be woefully inadequate to serve the needs of the patients. Patients cannot receive the best quality, efficient, and timely care they need and deserve within institutions that are not integrated. Institutions that continue to silo and do not encourage collaboration and integration are not focused on the needs of the patient.

Amanda BarnardDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - March 30, 2021

I believe, as a DBH, I will disrupt the current healthcare systemby promotingguaranteed health care for allasa right, not a privilege.I willadvocate fora national, rather than state, licensing of providers. This will allow clinicians (medical,behavioral health, etc…) to provide care across state lines using telemedicine.Finally, the skills I have learned at Cummings Graduate Institute for Behavioral Health Studies allow me to identify healthcare delivery concerns, propose alternative interventions and cost–effective solutions and evaluate theirreturn on investment.

Diane ScottDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - March 29, 2021

Since entering CGI, I have more confidence in discussing the need for healthcare systems to have a population health approach to care, and to put in place “upstream” programming. I have always been proud of working in a hospital and delivering care, working as a multidisciplinary team member, and making a difference. I now realize I have been part of healthcare’s focus of “treating the sick” rather than being an influencer for preventative care.

Preventative care can be part of service delivery from a hospital system; we should not rely only on public health programs to tackle social determinants of health. COVID-19 is not only impacting mental health but also how we are delivering medical care. Could COVID-19 be an unintended force for healthcare policy change? Apostolopoulos et al. (2020) reports the complexity presented to the health care system by COVID-19 has created change that will continue in healthcare for years to come. The needed changes to delivery and access will require a policy shift in all levels of healthcare (Apostolopoulos et al., 2020).

Billie RatliffDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - December 13, 2021

The DBH is exactly the type of doctorate degree that I’ve been searching for. A doctorate that is clinical focused is where my interest lies. I am motivated to pursue this degree, and courses like Pathophysiology, Psychopharmacology, Neuropathophysiology, only add to that excitement. One must be motivated to complete any degree program. The Doctor of Behavioral Health fits that bill for me. In fact, I would say that I am beyond motivated.

Arthur Williams IIIDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - July 8, 2022

As a member of the AAPI community, I’m very familiar with the barriers to mental health services and the need to break through the glass wall of cultural stigma that prevents many from receiving potentially life–saving treatment. I was the only Asian American person in my master’s cohort, the only Asian American person in many of my clinical work settings, the only Asian American person to walk into many of the professional settings that I pushed myself to show up to. In my current practice, I’m constantly reminded by my patients of how difficult it is to find an Asian American mental health provider, though this reminder constantly informs me that more needs to be done for my community. Day after day, I read stories of Asian American people who die by suicide as a consequence of our culture’s avoidance of mental health topics. As a DBH, my biggest goal is to use my expertise in whole–person care to amplify the conversation around mental health and help my community understand that mental healthcare is not a privilege that we are not entitled to, it is a crucial part of our healthcare that will manifest differently in us than what many Western psychology or psychiatry textbooks will describe, and that our unique experience of mental health issues are valid, important, and is time to be part of the larger conversation.

Willam ChumDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - September 16, 2022

Pursuing a doctorate in behavioral health is essential in helping to transform my thinking as a healthcare provider; moving from a more traditional mindset, embracing change and a “different world view” of tools for successful client outcomes. This type of advanced study will equip me with the clinical and leadership skills to be a leader on the cutting edge of behavioral health. This type of training would make me an asset to the healthcare workplace; specifically to function effectively as a change agent for the successful outcomes of the workplace and its clients.

Judith AllenDBH Candidate, Cummings Graduate Institute for Behavioral Health Studies - September 23, 2022 Previous Slide

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