Pathways Home Health & Hospice

NOTICE OF PRIVACY PRACTICES

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.

As a patient receiving health services and care, we understand you may be concerned about how your medical and other health-related information may be handled. That is why we, as an organization, are committed to ensuring patient privacy and confidentiality for you and others that we serve.

USE AND DISCLOSURE OF HEALTH INFORMATION
Pathways Home Health & Hospice may use your health information, information that constitutes protected health information as defined in the Privacy Rule of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act (HIPAA) of 1996, for purposes of providing you treatment, obtaining payment for your care and conducting health care operations. Pathways Home Health & Hospice has established policies 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. Pathways may use your health information to coordinate care within Pathways and with others involved in your care, such as your attending physician, members of the care team and other health care professionals who have agreed to assist Pathways in coordinating care. Some examples include providing physicians involved in your care with information about your symptoms in order to prescribe appropriate medications or treatment; disclosing your health care information to individuals involved in your care and outside of Pathways including family members, pharmacists, suppliers of medical equipment, or other health care professionals; to an interpreter if using the professional interpreting service line.

To Obtain Payment. Pathways may include your health information in invoices to collect payment from third parties for the care you receive from Pathways. For example, Pathways may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or Pathways. Pathways also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for the services that will be provided to you. We will only disclose that Protected Health Information which is minimally necessary to ensure proper and timely payment of claims.

To Conduct Health Care Operations. Pathways may use and disclose health
information for its own purposes in order to facilitate the operations of Pathways and as
necessary to provide quality care to all of Pathways’ patients. Some examples of health
care operations includes activities such as: quality assessment and improvement
activities; activities designed to improve health care; protocol development, case
management and care coordination; 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 compliance programs;
business planning and development including cost management.

For Appointment Reminders And Information On Treatment Alternatives.
Pathways may use and/or disclose your Protected Health information, as appropriate,
for appointment reminders or to provide you with information about treatment
alternatives or other health-related benefits and services.

For Fundraising Activities. To the extent permitted by the Privacy Rules,
Pathways may use demographic information such as your name, address, phone
number and the dates you received care in order to send newsletters and fundraising
information to you or your family. If you do not want Pathways to contact you or your
family, notify the Privacy Officer in the administrative offices in Sunnyvale at 1-800-789-
8055 and indicate that you do not wish to be contacted.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND
PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY ALSO BE USED AND
DISCLOSED.
The law permits us to use or disclose Protected Health Information for specific
purposes where we are not required to obtain your advance written Consent or
Authorization. Whenever doing so, we are committed to make sure that we meet the
necessary prerequisites before using/disclosing your Protected Health Information and
to not use or disclose more of your Protected Health Information than is required or
permitted under the law.

Emergency circumstances may dictate our need to use and/or disclose Protected
Health Information without obtaining a Consent or Authorization to properly treat and
care for patients. In other cases, the law emphasizes society’s need for disclosing
Protected Health Information, without first requiring patients to sign a Consent or
Authorization. Following are some examples of these types of disclosures: When
legally required; for health oversight purposes; for FDA related purposes; for certain
public health and safety purposes; for funeral/funeral director purposes; for judicial or
administrative proceedings in response to a properly executed request such as a
subpoena or other lawful process; for purposes of facilitating organ, eye and tissue
donations to organ procurement organizations; for coroner/medical examiner purposes;
to assist victims of abuse, neglect or domestic violence; for worker’s compensation or
similar programs; to properly assist law enforcement to carry out their duties; to facilitate
specific government functions relating to military, veterans, national security,
intelligence activities, protective services for the President and others high ranking
officials; to correctional institutions/law enforcement officials acting in a custodial
capacity; under very select circumstances for research purposes and then only after an
extensive approval process.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION
Other than is stated above, Pathways will not disclose your health information
other than with your written authorization. If you or your representative authorizes
Pathways to use or disclose your health information, you may revoke that authorization
in writing at any time.
YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION
You have the following rights regarding your health information that Pathways
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
Pathways disclosure of your health information to someone who is involved in
your care or the payment of your care. However, Pathways is not required to
agree to your request. If you wish to make a request for restrictions, contact the
Privacy Officer. Please see Contact Information at the end of this Notice.

Right to receive confidential communications. You have the right to request
that Pathways communicate with you in a certain way. For example, you may
ask that Pathways 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 notify your case manager and put
your request in writing. Pathways 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
Privacy Officer. See Contact Information at the end of this Notice. If you request
a copy of your health information, Pathways may charge a reasonable fee for
copying and assembling costs associated with your request.

Right to amend health care information. You or your representative have the right to
request that Pathways amend (but not obliterate or totally remove documentation) your
records, if you believe that your health information is incorrect or incomplete. That
request may be made as long as the information is maintained by Pathways. A request
for an amendment of records must be made in writing to the Privacy Officer. See
Contact Information at the end of this Notice. Pathways 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 Pathways, if the records
you are requesting are not part of Pathways’ 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 Pathways, the records containing your health
information are accurate and complete. When the original documentation is used or
disclosed, the “amendment” will accompany any released copies of your records.

Right to an accounting. You or your representative have the right to request an
accounting of disclosures of your health information made by Pathways for
certain reasons, including reasons related to public purposes authorized by
law and certain research. The request for an accounting must be made in
writing to the Privacy Officer. See Contact Information at the end of this
Notice. The request should specify the time period for the accounting.
Accounting requests are limited to six years prior to the date of the request
and may not extend further back than April 14, 2003. Pathways 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 Privacy Officer. See Contact Information at
the end of this Notice. The patient or a patient’s representative may also
obtain a copy of the current version of Pathways’ Notice of Privacy Practices
at its website, www.pathwayshealth.org.

DUTIES OF Pathways Home Health & Hospice
Pathways is required by law to maintain the privacy of your health information
and to provide to you and your representative this Notice of its duties and privacy
practices. Pathways is required to abide by the terms of this Notice as may be
amended from time to time. Pathways 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 Pathways changes its Notice, Pathways will provide a copy of the revised
Notice to you or your appointed representative while you are receiving services from us.
You or your personal representative have the right to express complaints to Pathways.
To register a complaint with us, contact the Privacy Officer. Please see Contact
Information at the end of this Notice.

Pathways Home Health & Hospice provides privacy training for all current and new
employees and volunteers who have contact with protected health information. We
apply appropriate sanctions against any staff member who violates the organization’s
privacy practices.

If you believe we have not been attentive and have violated your privacy rights, you
have the right to contact the United States Department of Health and Human Services
about us as follows: Medical Privacy, Complaint Division, Office of
Civil Rights, United States Department of Health and Human Services, 200
Independence Avenue, S.W., Room 509F, HHH Building, Washington, D.C. 20201;
Voice Hotline Number (800) 368-1019; Internet Address www.hhs.gov/ocr.

CONTACT INFORMATION
Privacy Officer
585 North Mary Avenue
Sunnyvale, CA 94085
1-800-789-8055

Pathways encourages you to express any concerns you may have regarding the privacy
of your information. It is against our policies and procedures to retaliate against any
patient or representative who has filed a privacy complaint, either with us or with the
Department of Health and Human Services.

EFFECTIVE DATE
This Notice is effective April 14, 2003.