IF YOU HAVE ANY QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT OUR PRIVACY OFFICER.

Protected Health Information (PHI) is information, including demographic information, that may identify you and that relates to health care services provided to you, the payment of health care services provided to you, or your physical or mental health or condition, in the past, present or future. This Notice of Privacy Practices describes how we may use and disclose your PHI. It also describes your rights to access and control your PHI.

As a health care provider we are required by Federal law to maintain the privacy of PHI and to provide you with this notice of our legal duties and privacy practices.

We are required to abide by the terms of this Notice of Privacy Practices, but reserve the right to change the Notice at any time. Any change in the terms of this Notice will be effective for al PHI that we are maintaining at that time. If a change is made to this Notice, a copy of the revised Notice will be provided to you.

PERMITTED USES AND DISCLOSURES

Treatment, Payment and Health Care Operations

Federal law allows a health care provider to use and disclose PHI, for the purposes of treatment, payment and health care operations, without your consent of authorization. Examples of the uses and disclosures that we may make under each section are listed below:

• Treatment. Treatment refers to the provision and coordination of health care by a doctor, hospital or other health care provider. For example, we may disclose PHI to another health care provider who is involved in your treatment.
• Payment. Payment refers to the activities of a group health plan in remitting claims for reimbursement and for collecting fees for health care services you receive. Examples of uses and disclosures under this section include the sending of PHI to an external medical review company to determine the medical necessity or experimental status of a treatment; sharing PHI with insurers to determine coordination of benefits or settle subrogation claims; providing PHI to an insurer's UR Company for precertification or case management services; providing PHI in the billing, collection and payment of premiums and fees to insurance plan vendors such as PPO Networks, UR Companies, Prescription Drug Card Companies and reinsurance carriers.
• Health Care Operations. Health Care Operations refers to the basic business functions necessary to operate a health care provider practice. Examples of uses and disclosures under this section include conducting quality assessment studies to evaluate the performance of a particular provider; the use of PHI in determining the cost impact of service changes; the disclosure of PHI to consultants who provide legal, actuarial and auditing services; and use of PHI in general date analysis used in the long term management and planning for the company.

Other Uses and Disclosures Allowed Without Authorization

Federal law also allows a health care provider to use and disclose PHI, without your consent or authorization, in the following ways:

• Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have any appointment for treatment or medical care.
• Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
• To you, as the covered individual.
• To a personal representative designated by you to receive PHI or a personal representative designated by law such as the parent or legal guardian of a child, or the surviving family members or representative of the estate of a deceased individual.
• To the secretary of Health and Human Services (HHS) or any employee of HHS as part of an investigation to determine our compliance with the HIPAA Privacy Rules.
• To a Business Associate as part of a contracted agreement to perform services.
• To a health oversight agency, such as the Department of Labor (DOL), the Internal Revenue Service (IRS) and the Insurance Commissioner's Office, to respond to inquiries or investigations, requests for audit, or to obtain necessary licenses.
• In response to a court order, subpoena, discovery request or other lawful judicial or administrative proceeding.
• As required for law enforcement purposes. For example to notify authorities of a criminal act.
• As required to comply with Workers' Compensation or other similar programs established by law.
• In providing you with information about treatment alternatives and health services that may be of interest to you as a result of a specific condition.

The examples of permitted uses and disclosures listed above are not provided as an all inclusive list of the ways in which PHI may be used. They are provided to describe in general the types of uses and disclosures that may be made.

OTHER USES AND DISCLOSURES

Other uses and disclosures of your PHI will only be made upon receiving your written authorization. You may revoke an authorization at any time by providing written notice to us that you wish to revoke an authorization. We will honor a request to revoke as of the day it is received and to the extent that we have not already used or disclosed your PHI in good faith with the authorization.

YOUR RIGHTS IN RELATION TO PROTECTED HEALTH INFORMATION

You have the right to request that we limit our uses and disclosures of PHI in relation to treatment, payment and health care operations or not use or disclose your PHI for third reasons at all. You also have the right to request that we restrict the use or disclosure of your PHI to family members or personal representatives. Any such request must be made in writing to our Privacy Officer and must state the specific restriction requested and to whom that restriction would apply.

We are not required to agree to a restriction that you request. However, if we do agree to the requested restriction, we may not violate that restriction except as necessary to allow the provision of emergency medical care to you.

RIGHT TO RECEIVE CONFIDENTIAL COMMUNICATIONS

You have the right to request that communications involving PHI be provided to you at an alternative location or by an alternative means of communication. We require to accommodate any reasonable request if the normal method of disclosure would endanger you and that danger is stated in your request. Any such request must be made in writing to our Privacy Officer.

RIGHT TO ACCESS TO YOUR PROTECTED HEALTH INFORMATION

You have the right to inspect and copy your HI as long as we maintain the PHI. Federal law does prohibit you from having access to the following records; psychotherapy notes; information complied in reasonable anticipation of, or for use in a civil, criminal or administrative action or proceeding; and PHI that is subject to a law that prohibits access to that information. If your request for access is denied, you may have a right to have that decision reviewed. Requests for access to your PHI should be directed to our Privacy Officer.

RIGHT TO AMEND PROTECTED HEALTH INFORMATION

You have the right to request that your PHI be amended for as long as we maintain the PHI. We may deny your request for amendment if we determine that the PHI was not created by us, is not information that is available for inspection, or that the PHI is accurate and complete. If your request for amendment is declined, you have the right to have a statement of disagreement included with the PHI and we have a right to include a rebuttal to your statement, a copy of which will be provided to you. Requests for amendment of your PHI should be directed to our Privacy Officer.

RIGHT TO RECEIVE AN ACCOUNTING OF DISCLOSURES

You have the right to receive an accounting of all disclosures of your PHI made by us, if any, for reasons other than disclosures for treatment, payment and health care operations, as described above, and disclosures made to you or your personal representative. Your right to an accounting of disclosures applies only to PHI created after April 14, 2003 and cannot exceed a period of six years prior to the date of your request. Requests for an accounting of disclosures of your PHI should be directed to our Privacy Officer.

RIGHT TO RECEIVE A PAPER COPY OF THIS NOTICE

You have the right to receive a paper copy of this Notice upon request. This right applies even if you have previously agreed to accept this Notice electronically. Requests for a paper copy of this Notice should be directed to our Privacy Officer.

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with the plan or the Secretary of Halth and Human Services. Complaints should be filed in writing with our Privacy Officer. We may not retaliate against you for filing a complaint.

PRIVACY CONTACT

You may contact our privacy Officer at (708) 423-5990.

EFFECTIVE DATE OF NOTICE

This notice published and becomes effective on April 14, 2003.