Consolidated Health Enterprises
d/b/a Medical Office Pharmacy
520 North Mayo Trail
Paintsville, Kentucky 41240

Notice of Privacy Practices

Effective date: April 14, 2003

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED OR DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Health information is received or created by Health Care Providers in the course of the treatment, payment and health care operations associated with your health care. Consolidated Health Systems and Highlands Regional Medical Center (CHS/HRMC) are permitted to use or disclose health information for treatment, payment and health care operations. All other uses unless otherwise required or permitted by law will require your written authorization. As such, an authorization can be revoked, in writing, at any time.

The Difference Between “Use” and “Disclosure”
“Use” refers to the release, transfer, provision of access to or otherwise divulging in any manner information within CHS/HRMC.

“Disclosure” refers to the release, transfer, provision of access to or divulging in any manner information outside CHS/HRMC.

Treatment, Payment and Health Care Operations

Treatment is the provision, coordination or management of health care and related services. We may use medical information about you to provide you with medical treatment or services. We may disclose medical information about you to doctors, dentists, nurses, technicians, students, or other CHS/HRMC personnel who are involved in taking care of you. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals. Different departments or sites of CHS/HRMC also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We also may disclose medical information about you to people outside CHS/HRMC who may be involved in your continued care, such as family members, nursing service providers or others we use to provide services that are part of your care.

Payment includes those activities that a Health Care Provider such as CHS/HRMC undertakes to obtain reimbursement for providing health care services. We may use and disclose medical information about you so that the treatment and services you receive at CHS/HRMC may be billed to and payment may be collected from you, an insurance company, a third party or a State or Federal Program. For example, we may need to give your health plan information about surgery you received at the hospital so your health plan will pay us or reimburse you for the surgery. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.

Health care operations are activities that do not include treatment but are important for the continued administrative, operational, regulatory and fiscal functions normally performed by CHS/HRMC. These uses and disclosures are necessary to run CHS/HRMC and make sure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many CHS/HRMC patients to decide what additional services we should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, dentists, nurses, technicians, students, and other CHS/HRMC personnel for review and learning purposes. We may also combine the information we have with medical information from other providers of care to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.

Other Uses and Disclosures
There are many other complementary services that CHS/HRMC will provide to our patients. Those services include:

Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have appointment for treatment or care at CHS/HRMC.

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.

Health-Related Benefits and Services. We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

Fundraising Activities. We may contact you in an effort to raise money for Highlands Regional Medical Center.

Hospital Directory: We may include certain limited information about you in the Highlands Regional Medical Center patient list while you are a patient at the hospital. This information may include your name, location in the hospital and your religious affiliation. The information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy even if they don’t ask for you by name. This is so your family, friends and clergy can visit you in the hospital. If you don’t wish to be included on our patient list, please notify the unit manager or designee.

Individuals Involved in Your Care or Payment for Your Care. We may release medical information about you to a friend or family member that you indicate is involved in your care or the payment for your care unless you object in whole or in part. Information is not released routinely about patients on the Psychiatric Units. In addition, we may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.

Research. Under certain circumstances, we may use and disclose medical information about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of your information, trying to balance the research needs with patients' need for privacy of their medical information. Before we use or disclose information for research, the project will have been approved through this research approval process. We may, however, disclose medical information about you to people preparing to conduct a research project. For example, this information may help researchers look for patients with specific medical needs. This information will remain within the institution. We will ask for your specific permission to give a researcher your name, address or other information that reveals who you are. In rare cases, your permission may be waived as directed by federal, state, and local law.

As Required By Law. We will disclose medical information about you when required to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety. We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to help prevent the threat.

Organ and Tissue Donation: If you are an organ donor, we may release medical information to organizations that handle organ, eye or tissue procurement/ transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

Military and Veterans: If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release information about foreign military personnel to the appropriate foreign military authority.

Workers' Compensation: We may release medical information about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illness.

Public Health Risks: We may disclose medical information about you for public health activities. These activities generally include the following:

•To report births and deaths;
•To report child or elder abuse;
•To report reactions to medications or problems with products;
•To notify people of recalls of products they may be using;
•To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition.

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

We may disclose medical information to notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.

Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you to comply with a subpoena, court order, or other lawful process by someone else involved in the dispute, provided that the request meets all of the legal requirements and is valid.

Law Enforcement: We may release medical information if asked to do so by a law enforcement official:

•In response to a court order, subpoena, warrant, summons or similar process;
•To identify or locate a suspect, fugitive, material witness, or missing person;
•About a victim or the suspected victim of a crime.
•About a death we believe may be the result of criminal conduct;
•About criminal conduct at the hospital; and
•In certain 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 medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information about patients of the hospital to funeral directors as necessary to carry out their duties.

National Security and Intelligence Activities: We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Protective Services for the President and Others: We may disclose medical information about you to authorized federal officials so they may provide protection to the President, other authorized persons or foreign heads of state or conduct special investigations.

Patients under Custody of Law Enforcement: If you are under the custody of a law enforcement official, we may release medical information about you to the law enforcement official. This release would be necessary for the institution to provide you with health care and/or to protect your health and safety or the health and safety of others.

Your Rights:
As a patient, you have many rights reserved for you. Those rights are:

Right to Inspect and Copy. You have the right to inspect and have copied information that is considered part of your medical, dental and billing records that may be used to make decisions about your care. To inspect and have copied medical information about you, you must submit your request in writing to the Director of the Medical Records Department. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We will respond within 30 days of receiving your written request. We may deny your request to inspect and copy in certain very limited circumstances. In certain circumstances, if you are denied access to your information, you may request that the denial be reviewed. Another licensed health care professional chosen by the CHS/HRMC will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.

Right to Correct or Update. For as long as your protected health information is kept by or for CHS/HRMC you have the right to request a correction if you feel that this information is incorrect or incomplete. To request a correction or update, your request must be made in writing with a reason to support the request and submitted to the Director of the Medical Records Department. We will respond within 60 days of receiving your written request. We may deny your request if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

•Was not created by us, unless the person or entity that created the information is no longer available to make the amendment;
•Is not part of the information kept by or for CHS/HRMC;
•Is not part of the information which you would be permitted to inspect and have copied or
•Is accurate and complete.
Any agreed upon correction will be included as an addition to, and not a replacement of, already existing records.

Right to a List of Disclosures We Have Made About You. You have the right to request an accounting of the disclosures we made of your medical, dental, and billing information except for disclosures made for treatment, payment and health care operations as defined above. We are not obligated to list all disclosures made about you. To request this list of disclosures, you must submit your request in writing to The Director of the Medical Records Department. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of costs involved and you may alter your request before any costs are incurred.

Right to Request Restrictions. You have the right to request a restriction or limitation on the medical, dental and billing information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had. If you request a restriction limiting our ability to bill for payment for your care, we will require you to make private payment arrangements. We are not required to agree to your request. However, if we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. 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, for example, disclosures to your spouse.

Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request at the time of registration or by calling the Registration Department. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

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. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. You may obtain a copy of this notice at our website, www.hrmc.org. You may obtain a paper copy of this notice at any CHS/HRMC registration area. We will ask that you acknowledge receipt of this notice in writing.

CHS/HRMC’S DUTIES
Not only are we required by law to protect your health information and to provide you this Notice of Privacy Practices, we are committed to maintaining the privacy of your health information. We are required to abide, and fully intend to abide, by the terms of the Notice of Privacy Practices as it is currently in effect.

RIGHT TO CHANGE THE TERMS OF THE NOTICE OF PRIVACY PRACTICES
In order to make any changes to our Notice of Privacy Practices, we reserve the right to change the terms of this notice and to make the new provisions of the Notice of Privacy Practices effective for all of the protected health information that we maintain. You can obtain a copy of the Notice of Privacy Practices by calling or writing the contact listed below, or simply pick up another copy on your next visit to CHS/HRMC.

WHO TO CONTACT WITH ANY QUESTIONS OR CONCERNS
You will not be penalized for filing a complaint. If you believe your privacy rights have been violated, you may file a complaint with CHS/HRMC or with the Secretary of the Federal Department of Health and Human Services (DHHS).
To ask questions concerning our privacy practices or to file a complaint with Consolidated Health Systems or Highlands Regional Medical Center, contact the Public Relations Office at (606) 886-7586 or at the following address: 5000 KY RT. 321, P.O. Box 668, Prestonsburg, Kentucky, 41653. All complaints must be submitted in writing.

OTHER USES OF MEDICAL INFORMATION. Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to use or disclose medical information about you, you may revoke it, in writing, at any time. If you revoke it, we will no longer use or disclose medical information about you for the reasons covered by your written authorization, unless required by law. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain our records of the care that we provided to you.