WHO WILL FOLLOW THIS NOTICE. This Notice describes the privacy practices of Peninsula, a division of Parkwest Medical Center ("Peninsula") as well as any health care professional authorized to enter information into a Peninsula healthcare record; all Peninsula departments and units; any member of a volunteer group that Peninsula allows to help patients while in Peninsula's care; business associates of Peninsula; and all Peninsula employees, staff, and personnel.

Peninsula, its employees, staff, and personnel, and the health care professionals providing services at Peninsula participate in an "organized health care arrangement" that permits sharing of protected health information ("PHI") to carry out treatment, payment and health care operations related to the arrangement. Additionally, Peninsula and the members of its organized health care arrangement participate in a master organized health care arrangement with other wholly owned subsidiaries of Covenant Health that permits Peninsula to share PHI for the same purposes under similar arrangements. Each of the participants in the organized health care arrangements remains solely responsible and liable for its/his/her own acts and omissions. These organized health care arrangements do not create a joint venture, partnership, agency, or employment relationship, and joint and several liability is not intended.

RECORDS THIS NOTICE COVERS. This Notice applies to all records of your PHI maintained by Peninsula, whether made by Peninsula personnel or received by Peninsula from other health or mental health care providers. Other health or mental health care providers may have different policies and notices regarding use and disclosure of PHI which they maintain.

CONFIDENTIALITY. The confidentiality of patient records maintained by Peninsula in connection with any substance abuse program is protected by federal law and regulations. Generally, a substance abuse program may not disclose to a person outside the program that a patient attends the program, or disclose any information identifying a patient as an alcohol or drug abuser unless: (1) the patient consents in writing; (2) the disclosure is allowed by a court order; or (3) the disclosure is made to medical personnel in a medical emergency or to qualified personnel for research, audit, or program evaluation. Violation of the federal law and regulations by a program is a crime. Suspected violations may be reported to appropriate authorities in accordance with federal regulations. Federal law and regulations do not protect any information about a crime committed by a patient either at the program or against any person who works for the program or about any threat to commit such a crime. Further, federal laws and regulations do not protect any information about suspected child abuse or neglect from being reported under state law to appropriate state or local authorities. (42 U.S.C.§§ 290dd-3 & 290ee-3; 42 C.F.R. part 2.)

OUR OBLIGATIONS. Peninsula is required by law to keep PHI it maintains private, to provide this Notice of our legal duties and privacy practices with respect to PHI, and to follow the terms of the Notice currently in effect.

HOW WE MAY USE AND DISCLOSE PHI. The following categories describe different ways that Peninsula uses and discloses PHI. Although not every use or disclosure in a category will be listed, all of the ways we are permitted to use and disclose PHI will fall within one or more of the categories.

Treatment. We may use PHI to provide medical treatment. We may disclose PHI to doctors, nurses, technicians, medical students, or other healthcare personnel involved in a patient's care at Peninsula. For example, different departments of Peninsula may share PHI to coordinate the different things a patient needs, such as prescriptions and lab work. We may disclose PHI to other health or mental health care providers and other individuals if necessary to assure treatment and care to you by the least drastic means appropriate to your liberty and interests. We may disclose PHI as necessary for your continued treatment and care when your treatment and care moves to other health or mental health providers.

Payment. We may use and disclose PHI as reasonably necessary to create bills and to process and obtain payments. PHI will be disclosed to an organization which may pay for patient treatment on the condition that the organization will not make further disclosure of PHI without patient (or representative) consent. For example, we may provide a health insurer with information about a treatment a patient received so the insurer will pay for the treatment. We may also tell a health insurer about a treatment a patient will receive to obtain prior approval, or to determine whether the insurer will cover the treatment. Peninsula may disclose records of a substance abuse diagnosis, maintained in connection with a substance abuse program, to obtain payment, with patient consent; but patient consent may not be not required if the patient lacks capacity to consent. Peninsula may rely upon consent to disclose a substance abuse diagnosis, which was given before or during treatment, in order to obtain payment.

Health Care Operations.* We may use and disclose PHI for the operation of Peninsula. These uses and disclosures are necessary to run Peninsula and to ensure that all patients receive quality care. For example, we may use PHI for internal review of treatment and services and to evaluate staff performance. We may combine PHI about many of our patients to decide what additional services Peninsula should offer, what services are not needed, and whether certain new treatments are effective. Peninsula also may use PHI to conduct overall quality assessment and improvement activities, to review the competence or qualifications of health care professionals, and to conduct fraud and abuse detection programs. We may also disclose PHI to doctors, nurses, technicians, medical students, and other Peninsula personnel for review and learning purposes. We may also combine the PHI we have with PHI from other behavioral health organizations to compare how we are doing and see where we can make improvements in the care and services we offer. *Note. We may remove from PHI information that identifies individuals so it may be used without learning the identity of specific patients.

Patient Contacts. We may contact patients to remind them of appointments for treatment or care or to recommend possible treatment options or alternatives. We may also contact patients to discuss health-related benefits or services of interest.

Individuals Involved in Patient Care or Payment for Care: Disaster Relief Agencies. As necessary, we may release PHI to a family member or friend involved in a patient's care or payment for such care. Also, we may release PHI to notify a family member, a friend, or a person responsible for a patient's care of the patient's location and general condition. We may disclose PHI to a custodial agent for a state agency having custody of a patient, if necessary for the agent to properly perform its duties. We may disclose PHI to a disaster relief agency so a patient's family can be notified of the patient's condition, status, and location.

Research.* With consent, we may use and disclose PHI necessary for research purposes. All research projects are subject to a special approval process that evaluates a proposed research project and its use of PHI, trying to balance the research needs with patients' right to privacy. Before we use or disclose PHI for research, the project will have been approved through this research approval process. With consent, we may also disclose PHI to people preparing to conduct a research project (for example, to help them look for patients with specific medical needs), so long as the medical information they review does not leave Peninsula. In almost all other cases, we will obtain specific authorization if the researcher will have access to a patient's name, address, or other information that reveals who the patient is. *Note. We may remove from PHI information that identifies individuals so that it may be used without learning the identity of specific patients.

As Required By Law or To Avert a Serious Threat to Health or Safety. We will disclose PHI when required by law. We are required to disclose information requested by a federally mandated protection and advocacy agency for a federally mandated function. We may disclose PHI to comply with laws regarding child abuse, sexual abuse, neglect as well as abuse, neglect, and exploitation of certain adults to state or local authorities without obtaining consent. Some other examples of disclosures required by law include reports of deaths, drug overdoses in students and certain kinds of wounds or poisonings. Also, we may use and disclose PHI, if necessary, to prevent or lessen a serious and imminent threat to the health or safety of the patient, another person, or the public. Any disclosure would only be to someone able to help prevent or lessen the threat, which may include disclosure to the person threatened.

Public Health Activities. We may disclose PHI for certain public health activities, such as prevention or control of disease, injury, or disability; reporting births and deaths; reporting reactions to medications or problems with products; providing recall notification for products; notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition and notifying the appropriate government authority if we believe a patient is the victim of abuse, neglect, or domestic violence.

Health Oversight Activities. We may disclose PHI to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure actions. Under certain circumstances, and for purposes of audit and evaluation only, Peninsula may disclose PHI without specific consent to a health oversight agency conducting audit and evaluation on behalf of a federal, state, or local governmental agency that provides financial assistance to Peninsula or that is authorized by law to regulate Peninsula's activities.

Law Enforcement. We may release PHI to law enforcement to comply with a court order, subpoena, warrant, summons, or similar process authorized by law. We may disclose PHI to report certain crimes committed on Peninsula premises (e.g., felonious acts of bodily harm and certain sexual offenses) and to give law enforcement authorities the names and access to potential witnesses, potential suspects, and the location of the crime. We also may disclose PHI to law enforcement to comply with laws regarding the reporting of suspicious wounds and deaths.

Disclosures for Court and Administrative Legal Proceedings. We may disclose PHI in response to certain court or administrative orders and subpoenas for information related to disclosures required by law such as information regarding child or adult abuse, sexual abuse, neglect or exploitation. Peninsula may disclose PHI to the extent necessary for involuntary hospitalization proceedings (commitment). Such disclosures may be made to health care providers, courts, attorneys, and witnesses involved in the commitment proceedings. Peninsula is required to notify a patient's parent (unemancipated minor patients), conservator, spouse, or adult next of kin that a patient has been committed, the basis of the commitment, and about legal proceedings for the commitment.

Coroners; Medical Examiners; and Funeral Directors. We may release PHI to a coroner, medical examiner, and with consent to a funeral director.

Organ and Tissue Donation. With consent, we may release PHI to organizations that handle organ procurement or organ, eye, or tissue transplantation.

Worker's Compensation. PHI may be released to a worker's compensation insurer or employer upon consent, as required by law, or as reasonably necessary to obtain payment.

YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU. You have the following rights regarding the PHI Peninsula maintains about you:

Right to Inspect and Copy. You may inspect and copy PHI used to make decisions about your care. Usually, this includes medical and billing records, but does not include certain materials excepted by law. To inspect and copy medical and mental health records used to make decisions about you, you must submit your request in writing to a Peninsula Privacy Officer (contact 865-380-1432 for more information). If you request a copy of the information, we may charge a reasonable fee for the costs of copying, mailing, or other supplies associated with your request. We may deny your request to inspect and copy in limited circumstances. For example, if you have been accused of abusing or neglecting a patient who is a child, you may be denied access to the child's records even though you are the child's parent, guardian, or custodian. Also, if access by you or a person acting in your behalf to part of your PHI poses a substantial risk of serious harm to the health or safety of the patient or another person, then Peninsula may refuse access to that part of the PHI. If you are denied access to PHI, you may request that the denial be reviewed. Another licensed health care professional chosen by Peninsula 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 Amend. If you feel that PHI we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for Peninsula. To request an amendment, your request must be submitted in writing and submitted to a Peninsula Privacy Officer (contact 865-380-1432 for more information). In addition, 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. Also, we may deny your request if it ask to amend information that was not created by Peninsula (unless the person or entity that created the information is no longer available to act on your request).Peninsula may deny your request to amend if the information is not part of the PHI kept by or for Peninsula; is not part of the information which you would be permitted to inspect and copy; or is accurate and complete.

Right to an Accounting of Disclosures. You may request an "accounting of disclosures." This is a list of certain disclosures we made of your PHI. To request this list or accounting of disclosures, you must submit your request in writing to a Peninsula Privacy Officer (contact 865-380-1432 for more information). Your request must state a time period that 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 the cost involved, and you may choose to withdraw or modify your request at that time before any costs are incurred. Peninsula is not required to account for certain types of disclosures and such disclosures may not be included in any list provided to you.

Right to Request Restrictions. You have the right to request a restriction or limitation on 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 to someone who is involved in your care or the payment for your care, like a family member or friend. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. To request restrictions, you must make your request in writing to a Peninsula Privacy Officer (contact 865-380-1432 for more information). In your request, you must tell us what information you want to limit; whether you want to limit our use, disclosure, or both; and to whom you want the limits to apply.

Right to Request Confidential Communications. You have the right to request that we communicate with you about health 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 in writing to a Peninsula Privacy Officer (contact 865-380-1432 for more information). 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, http://www.covenanthealth.com/aboutus/Peninsula/Peninsula.cfm. To obtain a paper copy of this Notice, please request it from Peninsula.

CHANGES TO THIS NOTICE. We reserve the right to change this Notice. We reserve the right to make the revised or changed Notice effective for PHI we already have about you, as well as any information we receive in the future. We will post a copy of the current Notice and provide you with a new notice on request. The Notice will contain on the first page, in the top right-hand corner, the effective date. In addition, each time you register at or are admitted to Peninsula for treatment or health care services as an inpatient or outpatient, we will offer you a copy of the current Notice in effect.

COMPLAINTS. If you believe your privacy rights have been violated, you may file a complaint with Peninsula or with the Secretary of the Department of Health and Human Services. To file a complaint with Peninsula, contact a Peninsula Privacy Officer (call 865-380-1432 for more information). You may also contact the Covenant Health Integrity-Compliance Department Report line at (888) 731-3115. We may request that your complaint be submitted in writing. You will not be retaliated against for filing a complaint.