Privacy Practices...

NOTICE OF PRIVACY PRACTICES

CARO COMMUNITY HOSPITAL

AND AFFILIATED CLINICS

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND

DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.

PLEASE REVIEW IT CAREFULLY.

IF YOU HAVE ANY QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT:

Sue Morris, R.N.

Privacy Officer

401 N. Hooper Street, P.O. Box 435

Caro, MI 48723

(989) 673-3141

THE PROVISIONS OF THIS NOTICE ARE EFFECTIVE AS OF APRIL 14, 2003

PURPOSE

This Notice of Privacy Practices describes how we may use and disclose your "Protected Health Information" (or "PHI") to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law. PHI is information about you that may identify you and that relates to your past, present or future physical or mental health or conditions and related health care services. This Notice also describes your rights in regard to your PHI, including your rights to access and control such information.

• This Notice describes our practices and those of:
• All employees, medical staff and other personnel of Caro Community Hospital;
• All departments and affiliates of Caro Community Hospital including but not limited to Caro Medical Clinic, Hill Medical Center and Health Services.
• Any health care professional authorized to enter information into your hospital chart, including staff physicians who are not our employees;
• Any member of a volunteer group we allow to help you while you are in the hospital;
• All fellows, residents, medical students, and other trainees of, or affiliated with, Caro Community Hospital.

WE ARE REQUIRED BY LAW TO:

• Make sure that your medical information is protected;
• Give you this Notice describing our legal duties and privacy practices with respect to medical information about you; and
• Follow the terms of the Notice that are currently in effect.

USES AND DISCLOSURES OF YOUR PROTECTED HEALTH INFORMATION

Following is a description of different types of uses and disclosures of your PHI. Not every possible use or disclosure will be listed.

Treatment. We may use and disclose your PHI to provide medical treatment or services. In the course of providing medical treatment or services, we may use or disclose your PHI to doctors, nurses, technicians, students or other individuals involved in your care. For example, in preparation for surgery, your doctor may need to tell the anesthetist you are allergic to a particular type of drug. Your medical information may also be shared to coordinate services, such as prescriptions, lab work, x-rays and dietary needs. If you require continuing treatment after leaving our facility, your PHI may be provided to home health care personnel or a physician to ensure that these individuals have the necessary information to diagnose or treat you.

Payment. We may use and disclose your PHI for billing or collection from you, an insurance company or other third party for treatment and services that we provide to you. For example, we may provide your insurance carrier with information related to a procedure in order to receive payment for that procedure. In some instances, your PHI will be disclosed in order to receive pre-approval for a particular course of action. For example, we may need to disclose your PHI to a Health Maintenance Organization (HMO) or other entity in order to receive approval for a hospital stay.

Health Care Operations.
We may use and disclose your PHI for health care operations in order to support the business activities of our facility and ensure that our patients receive quality care. These activities may include, but are not limited to, quality assessment, employee review, service evaluation, training, licensing, marketing, fundraising and conducting or arranging for other business activities. For example, we may compare your file with other patient files to evaluate the quality and similarity of treatment. We may also share your PHI with third party "business associates" that perform various activities for us.

Other Uses and Disclosures.
As part of treatment, payment and healthcare operations, we may use and disclose to you PHI for the following purposes:

• To remind you of an appointment.
• To inform you of possible treatment options or alternatives.
• To inform you about health-related benefits or services that may be of interest to you.
• To contact you to raise funds for the facility or an institutional foundation related to the facility.

Facility Directory.
We may use and disclose certain limited PHI as part of our facility directory. This information includes your name, location in our facility, your general condition, and your religious affiliation. The directory information, except for your religious affiliation, may be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they do not ask for you by name. You may restrict or prohibit the use or disclosure of this information by contacting our Privacy Officer.

Individuals Involved in Your Care or Payment for Your Care.

• We may release PHI under the following circumstances:
• To a friend or family member who is involved in your medical care.
• To someone who helps pay for your care.
• To inform your family or friends that you are in our facility and your condition.
• To an entity assisting in disaster relief efforts so that your family is notified of your condition, status and location.

SPECIAL SITUATIONS

Required By Law.
We will disclose your PHI when required to do so by federal, state or local law.

Public Health Activities.
PHI may be used or disclosed to a public health authority that is authorized by law to collect or receive such information to prevent or control disease, injury or disability; or to report births and deaths. PHI may be used or disclosed to a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition when required or authorized by law.

Abuse, Neglect and Domestic Violence.
We may disclose your PHI to a public health or other appropriate government authority authorized by law to receive reports of child abuse or neglect. Further, we may disclose PHI about an individual whom we believe to be a victim of abuse, neglect or domestic violence when required or authorized by law.

Food and Drug Administration.
We may disclose your PHI when required by the Food and Drug Administration to report adverse events, product defects or problems, or biologic product deviations. Additionally, your PHI may be used to track products, enable product recalls, make repairs or replacements, or to conduct post marketing surveillance.

Health Oversight Activities.
We may disclose your PHI to a health oversight agency for activities authorized by law and as necessary for the government to monitor the health care system, government programs and compliance with civil rights laws. These oversight activities may include audits, investigations, inspections and licensure evaluation.

Lawsuits and Disputes.
We may disclose your PHI in response to a court or administrative order such as in response to a subpoena, discovery request, or other lawful process by someone else involved in a lawsuit or dispute.

Law Enforcement.
We may release your PHI if asked to do so by a law enforcement official in situations including, but not limited to the following:

• As required by law for reporting of certain types of wounds or other physical injuries;
• In response to a court order, subpoena, warrant, summons or similar process;
• To identify or locate a suspect, fugitive, material witness, or missing person;
• To provide information about the victim of a crime if, under certain limited circumstances, we are unable to obtain the person's agreement;
• To provide information about a death we believe may be the result of criminal conduct;
• To provide information about criminal conduct at our facility; and
• Under emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.

Coroners, Medical Examiners and Funeral Directors.
We may release PHI to a coroner or medical examiner for the purpose of identification, determination of a cause of death, or for other legal duties. We may also release your PHI to funeral directors as necessary to carry out their duties.

Organ and Tissue Donation.
If you are an organ donor, we may release your PHI to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organ, eye or tissue for the purpose of facilitating organ, eye or tissue donation and transplantation.

To Avert a Serious Threat to Health or Safety.
We may use and disclose your PHI when necessary to prevent or lessen a serious threat to the health and safety of a person or the public. Any disclosure would only be to someone able to prevent or lessen the threat.

Specialized Government Functions.
We may disclose the PHI of Armed Forces personnel, veterans and foreign military personnel for authorized activities. Further, your PHI may be disclosed to authorized federal officials for the conduct of lawful intelligence, counterintelligence, and other national security activities and special investigations, including the provision of protective services to the President, other authorized persons or foreign heads of state, as authorized by law.

Workers' Compensation.
We may release PHI about you in connection with workers' compensation proceedings.

Inmates.
We may release your PHI to a correctional institution or law enforcement official if you are an inmate of a correctional institution or under the custody of a law enforcement official if necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Research.
We may disclose your PHI to researchers when their research has been approved by an institutional review board that has reviewed the research proposal and established protocols to ensure the privacy of your PHI.

YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION

Following is an outline of patient rights. If you have a specific request or question, please contact Sue Morris, R.N., Privacy Officer, 401 N. Hooper Street, P.O. Box 435, Caro, Michigan 48723, (989) 673-3141.

Right to Inspect and Copy.
With certain limited exceptions, you have the right to inspect and copy designated record sets containing your PHI for as long as we maintain the record. A "designated record set" is considered to be the medical record file or billing record file, with the exception of psychotherapy notes, used for making decisions about individuals. In order to inspect or copy a designated record set, you must submit a written request to our Privacy Officer. If you request a copy of the information, we may charge a fee associated with the costs of your request. Your request to inspect and copy your PHI may be denied under limited circumstances. If your request is denied, you may request that the denial be reviewed.

Right to Amend.
You may ask us to amend your PHI in a designated record set if you feel that the information is incomplete or inaccurate. The right to request an amendment exists for as long as the information is kept by or for our facility. To request an amendment, you must submit a written request to our Privacy Officer. You must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. If you are denied the ability to amend your PHI, you may request a review of the denial. Possible reasons for denying your request to amend include, but are not limited to:

• The information was not created by us, unless you provide a reasonable basis to believe that the person or entity that created the information is no longer available to make the amendment;
• The information is not part of the designated record set maintained by our facility;
• The information is not part of the designated record set which you would be permitted to inspect; or
• The request pertains to information that is accurate and complete.

Right to an Accounting of Disclosures.
You have the right to request an "accounting of disclosures" listing the disclosures we made of your PHI. To request an accounting of disclosures, you must submit a written request to our Privacy Officer. Your request must state a time period which may not be longer than six years and may not include dates before April 14, 2003. The first accounting will be provided without charge. We may charge you for the costs of providing subsequent accountings within a 12 month period.

Right to Request Restrictions.
You have the right to request a restriction or limitation on certain parts of the PHI we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the PHI we disclose about you for notification purposes or to individuals involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not disclose information about a condition you have to your spouse or children. We are not required to agree to your request. Under certain circumstances, we may terminate our agreement to a restriction. You may also terminate a restriction at a later date. Make your written request for restrictions to our Privacy Officer. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply. You may contact our Privacy Officer to terminate a restriction.

Right to Request Confidential Communications.
You have the right to request that we communicate with you about medical matters in a certain manner or location. We will accommodate all reasonable requests. For example, you can ask that we only contact you at home or not to send certain items in the mail. To request confidential communications, you must make your request in writing to our Privacy Officer. Your request, however, must be specific as to your requested accommodations.

Right to a Paper Copy of This Notice.
You have the right to a paper copy of this Notice. You may ask us to give you a copy of this Notice at any time.

OTHER USES OF PROTECTED HEALTH INFORMATION

Other uses and disclosures of your PHI not covered by this Notice or the laws that apply to us will be made only with your written permission. An authorization to use or disclose your PHI may be revoked in writing at any time. If you revoke an authorization, we cannot take back any disclosure previously made.

THIS NOTICE MAY BE AMENDED AT ANY TIME

We may change the terms of this Notice at any time. Any revised Notice will be effective for all PHI that we maintain at the time the revision is adopted. The effective date of a revised Notice will be noted on its first page. A copy of the current Notice in effect will be posted. You may request a copy of the current Notice at any time.

COMPLAINTS

If you believe your privacy rights have been violated or that our facility has otherwise not complied with the terms of this Notice, you may file a complaint by contacting our Privacy Officer for further information. All complaints must be submitted in writing. You will not be penalized for filing a complaint. If you feel uncomfortable filing a complaint with us, you may contact the Secretary of the United States Department of Health and Human Services.