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.USE AND DISCLOSURE OF HEALTH INFORMATION

Hospice of Michigan (the "Hospice") may use your health information for purposes of providing you treatment, obtaining payment for your care and conducting health care operations. Your health information may be used or disclosed only for those purposes unless the Hospice has obtained an authorization or if otherwise permitted by the regulations. The Hospice has implemented policies to protect the confidentiality of your health information and to guard against unnecessary disclosure of your health information.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:

To Provide Treatment. The Hospice may use your health information to coordinate care within the Hospice and share your health information with others involved in your care, such as your attending physician, members of the Hospice interdisciplinary team and other health care professionals who have agreed to assist the Hospice in coordinating care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. The Hospice also may disclose your health care information to individuals outside of the Hospice involved in your care including family members, clergy whom you have designated, pharmacists, suppliers of medical equipment or other health care professionals that the Hospice uses in order to coordinate your care. In some cases, the Hospice may also disclose your health information to an outside treatment provider for purposed of the treatment activities of the other provider.

To Obtain Payment. The Hospice may use and disclose your health information for purposes of obtaining payment for the services provided. The Hospice may include your health information in invoices to collect payment from third parties for the care you may receive from the Hospice. For example, the Hospice may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or the Hospice. The Hospice may also be required to submit your medical records or portions of your records to the insurer in order to receive payment. The Hospice also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for hospice care and the services that will be provided to you. The Hospice may also need to use and disclose your health information in various appeals processes to defend the necessity of services provided in the past. The Hospice may also disclose your health information to another covered entity or provider for their payment activities.

To Conduct Health Care Operations. The Hospice may use and disclose health care information for its own operations in order to facilitate the function of the Hospice and as necessary to provide quality care to all of the Hospice's patients. Health care operations includes such activities as:

• Quality assessment and improvement activities.
• Activities designed to improve health or reduce health care costs.
• Protocol development, case management and care coordination.
• Contacting health care providers and patients with information about treatment alternatives and other related functions that do not include treatment.
• Professional review and performance evaluation.
• Training programs including those in which students, trainees or practitioners in health care learn under supervision.
• Training of non-health care professionals.
• Accreditation, certification, licensing or credentialing activities.
• Review and auditing, including compliance reviews, medical reviews, legal services and maintaining compliance programs.
• Business planning and development including cost management and planning related analyses and formulary development.
• Business management and general administrative activities of the Hospice.
• Fundraising for the benefit of the Hospice and certain limited marketing activities.

For example, the Hospice may use your health information to evaluate its staff's performance; combine your health information with other Hospice patients in evaluating how to more effectively serve all Hospice patients; disclose your health information to independent reviewers as part of the Hospice's compliance activities; disclose your health information to outside accreditation agencies for purposes of evaluating the Hospice's performance with regard to its accreditation status; disclose your health information to Hospice staff and contracted personnel for training purposes; use your health information to contact you as a reminder regarding a visit to you or contact you or your family as part of general fundraising and community information mailings (unless you tell us you do not want to be contacted).

The Hospice is also permitted to disclose your health information to another covered entity for the operations of the other entity if the Hospice and the other entity both have a relationship with you and the disclosure is related to quality assessment and improvement activities or training programs or credentialing and similar activities.

The Hospice may disclose certain information about you including your name, your general health status, your religious affiliation and where you are in the Hospice facility in a Hospice directory while you are in the Hospice in-patient facility. The Hospice may disclose this information to people who ask for you by name. Please inform us if you do not want your information to be included in the directory.

The Hospice may also use or disclose your patient information to provide appointment reminders or information about treatment alternatives or other health-related benefits.

For Fundraising Activities. The Hospice may use information about you including your name, address, phone number and the dates you received care at the Hospice in order to contact you or your family to raise money for the Hospice. The Hospice may also release this information to a related Hospice foundation. If you do not want the Hospice to contact you or your family, notify the Corporate Clinical Quality Specialist and indicate that you do not wish to be contacted.

Permitted Uses/Disclosures-Authorization or Opportunity to Agree/ Object is Not Required. Federal privacy rules allow the Hospice to use or disclose your health information without your permission or authorization for a number of reasons, including the following:

When Legally Required. The Hospice will disclose your health information when it is required to do so by any federal, state or local law.

When There Are Risks to Public Health. The Hospice may disclose your health information for public activities and purposes in order to:

• Prevent or control disease, injury or disability, report disease, injury, vital events such as birth or death and the conduct of public health surveillance, investigations and interventions.
• To collect or report adverse events, track FDA-regulated products, enable product recalls, repairs or replacements to the FDA and to conduct post-marketing surveillance to the FDA.
• To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
• To an employer about an individual who is a member of the workforce as legally permitted or required.

To Report Abuse, Neglect or Domestic Violence. The Hospice is allowed to notify government authorities if the Hospice believes a patient is the victim of abuse, neglect or domestic violence. The Hospice will make this disclosure only when specifically required or authorized by law or when the patient agrees to the disclosure.

To Conduct Health Oversight Activities. The Hospice may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. For example, the Hospice may allow the Michigan Department of Community Health or the Michigan Department of Consumer and Industry Services to access medical records as required by law. The Hospice, however, may not disclose your health information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.

In Connection with Judicial and Administrative Proceedings. The Hospice may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a signed authorization (in a format approved by the Michigan Court Administrator or the HIPAA regulations.)

For Law Enforcement Purposes. The Hospice may disclose your health information to a law enforcement official for law enforcement purposes as follows:

• As required by law for reporting of certain types of wounds or other physical injuries pursuant to the court order, warrant, subpoena or summons or similar process.
• For the purpose of identifying or locating a suspect, fugitive, material witness or missing person.
• Under certain limited circumstances, when you are the victim of a crime.
• To a law enforcement official if the Hospice has a suspicion that your death was the result of criminal conduct including criminal conduct at the Hospice.
• In an emergency in order to report a crime.

To Coroners and Medical Examiners. The Hospice may disclose your health information to coroners and medical examiners for purposes of determining your cause of death or for other duties, as authorized by law.

To Funeral Directors. The Hospice may disclose your health information to funeral directors consistent with applicable law and if necessary, to carry out their duties with respect to your funeral arrangements. If necessary to carry out their duties, the Hospice may disclose your health information prior to and in reasonable anticipation of your death.

For Organ, Eye or Tissue Donation. The Hospice may use or disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue for the purpose of facilitating the donation and transplantation.

For Research Purposes. The Hospice may, under very select circumstances, use your health information for research. Before the Hospice discloses any of your health information for such research purposes, the project will be subject to an extensive approval process.

In the Event of a Serious Threat To Health or Safety. The Hospice may, consistent with applicable law and ethical standards of conduct, disclose your health information if the Hospice, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.

For Specified Government Functions. In certain circumstances, the Federal regulations authorize the Hospice to use or disclose your health information to facilitate specified government functions relating to military and veterans, national security and intelligence activities, protective services for the President and others, medical suitability determinations and inmates and law enforcement custody.

For Worker's Compensation. The Hospice may release your health information for worker's compensation or similar programs.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION

Other than is stated above, the Hospice will not disclose your health information other than with your written authorization. If you or your representative authorizes the Hospice to use or disclose your health information, you may revoke that authorization in writing at any time except to the extent that the Hospice has taken action in reliance upon the authorization.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your health information that the Hospice maintains:

• Right to request restrictions. You may request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on the Hospice's disclosure of your health information to someone who is involved in your care or the payment of your care. However, the Hospice is not required to agree to your request. If you wish to make a request for restrictions, please contact the Corporate Clinical Quality Specialist.
• Right to receive confidential communications. You have the right to request that the Hospice communicate with you in a certain way. For example, you may ask that the Hospice only conduct communications pertaining to your health information with you privately with no other family members present. If you wish to receive confidential communications, please contact the Corporate Clinical Quality Specialist. The Hospice will not request that you provide any reasons for your request and will attempt to honor your reasonable requests for confidential communications.
• Right to inspect and copy your health information. You have the right to inspect and copy your health information, including billing records. A request to inspect and copy records containing your health information may be made to the Corporate Clinical Quality Specialist. If you request a copy of your health information, the Hospice may charge a reasonable fee for copying and assembling costs associated with your request.
• Right to amend health care information. If you or your representative believes that your health information records are incorrect or incomplete, you may request that the Hospice amend the records. That request may be made as long as the information is maintained by the Hospice. A request for an amendment of records must be made in writing to the Corporate Clinical Quality Specialist. The Hospice may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by the Hospice, if the records you are requesting are not part of the Hospice's records, if the health information you wish to amend is not part of the health information you or your representative are permitted to inspect and copy, or if, in the opinion of the Hospice, the records containing your health information are accurate and complete.
• Right to an accounting. You or your representative have the right to request an accounting of certain disclosures of your health information made by the Hospice. The Hospice is not required to account for disclosures that you requested, disclosures that you agreed to by signing an authorization for, disclosures for the facility directory or certain other disclosures it is permitted to make without your authorization. The request for an accounting must be made in writing to the Corporate Clinical Quality Specialist. The request should specify the time period for the accounting starting on April 14, 2003. Accounting requests may not be made for periods of time in excess of six years. The Hospice would provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.
• Right to a paper copy of this notice. You or your representative have a right to a separate paper copy of this Notice at any time, even if you or your representative have received this Notice previously. To obtain a separate paper copy, please contact the Corporate Clinical Quality Specialist. The Hospice patient or a representative may also obtain a copy of the current version of the Hospice's Notice of privacy practices at its web site, www. hom.org

DUTIES OF THE HOSPICE

The Hospice is required by law to maintain the privacy of your health information and to provide to you and/or your representative this Notice of its duties and privacy practices. The Hospice is required to abide by terms of this Notice as may be amended from time to time. The Hospice reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all health information that it maintains. If the Hospice changes its Notice, the Hospice will provide a copy of the revised Notice to you or your appointed representative by sending a copy of the Revised Notice via regular mail or through in-person contact. You or your personal representative have the right to express complaints to the Hospice and to the Secretary of Health and Human Services if you or your representative believe that your privacy rights have been violated. Any complaints to the Hospice should be made to the Corporate Clinical Quality Specialist. The Hospice encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.

YOUR RIGHT TO FILE A COMPLAINT WITH THE SECRETARY OF HEALTH AND HUMAN SERVICES

You may file a complaint with the Secretary of the U.S. Department of Health and Human Services by writing to him at the following address:

CONTACT PERSON

Hospice of Michigan's contact person for all patient privacy issues and your rights under the federal privacy standards is:

This Notice is effective April 14, 2003.

IF YOU HAVE ANY QUESTIONS REGARDING THIS NOTICE, PLEASE CONTACT THE CORPORATE DIRECTOR OF ORGANIZATIONAL INTEGRITY AT THE ABOVE ADDRESS OR PHONE NUMBER.