Notice of Hill View Retirement Center
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.

We respect the privacy of your protected health information and are committed to maintaining your confidentiality. This Notice applies to all information and records related to your care that Hill View Retirement Center (referred to hereafter as Hill View) has received or created. It extends to information received or created by our employees, staff, volunteers and physicians. This Notice informs you about the possible uses and disclosures of your protected health information. It also describes your rights and obligations regarding your protected health information.

Hill View may share your protected health information among its departments for treatment, payment and/or health care operations.

We are required by the Privacy Rule of the Administrative Simplification provisions of the Health Insurance Portability and Accountability Act of 1966 law to:

• Maintain the privacy of your protected health information;
• Provide to you this detailed Notice of our legal duties and privacy practices relating to your protected health information; and
• Abide by the terms of the Notice that are currently in effect.

I. WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION FOR TREATMENT, PAYMENT AND HEALTH CARE OPERATIONS

For Treatment. We will use and disclose your protected health information in providing you with treatment and services. We may disclose your protected health information to Hill View and non-Hill View personnel who may be involved in your care, such as nurses, physicians, nurse aides, physical therapists, or students, trainees, and practitioners in training programs. For example, a nurse caring for you will report any change in your condition to your physician. We may also disclose protected health information to individuals who will be involved in your care after you leave Hill View.

For Payment. We may use and disclose your protected health information so that we can bill and receive payment for the treatment and services you receive at Hill View. For billing and payment purposes, we may disclose your protected health information to your representative, an insurance or managed care company, Medicare, Medicaid or another third party payor. For example, we may contact Medicare or your health plan to confirm your coverage or to request prior approval for a proposed treatment or service.

For Health Care Operations. We may use and disclose your protected health information for Hill View operations. These uses and disclosures are necessary to manage Hill View and to monitor our quality of care. For example, we may use protected health information to evaluate our services, including the performance of our staff.

II. WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU FOR OTHER SPECIFIC PURPOSES

Hill View Directories Unless you object, we may include certain limited information about you in our directories. This information may include your name, address, and phone number. Our directories do not include specific medical information about you. We may release information in our directories to people who ask for you by name.

Birthday (month/day) and Anniversary Dates may be listed in internal communications.

Death Notices/Funeral Arrangements may be posted.

Clergy Information. We may provide your name, address, phone number, general condition and religious affiliation, to any member of the clergy.

Individuals Involved in Your Care or Payment for Your Care. Unless you object, we may disclose your protected health information to a family member or close personal friend, including clergy, who is involved in your care.

Disaster Relief. We may disclose your protected health information to an organization assisting in a disaster relief effort.

As Required by Law. We may disclose your protected health information when required by law to do so.

Public Health Activities. We may disclose your protected health information for public health activities. These activities may include, for example:

• reporting to a public health or other government authority for preventing or controlling disease, injury or disability, or reporting child abuse or neglect;
• reporting to the federal Food and Drug Administration (FDA) concerning adverse events or problems with products for tracking products in certain circumstances, to enable product recalls or to comply with other FDA requirements;
• to notify 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 or
• for certain purposes involving workplace illness or injuries.

Reporting Victims of Abuse, Neglect or Domestic Violence. If we believe that you have been a victim of abuse, neglect or domestic violence, we may use and disclose your protected health information to notify a government authority if required or authorized by law, or if you agree to the report.

Health Oversight Activities. We may disclose your protected health information to a health oversight agency for oversight activities authorized by law. These may include, for example, audits, investigations, inspections and licensure actions or other legal proceedings. These activities are necessary for government oversight of the health care system, government payment or regulatory programs, and compliance with civil rights laws.

Judicial and Administrative Procedures. We may disclose your protected health information in response to a court or administrative order. We also may disclose information in response to a subpoena, discovery request, or other lawful process; efforts must be made to contact you about the request or to obtain an order or agreement protecting the information.

Law Enforcement. We may disclose your protected health information for certain law enforcement purposes, including

• as required by law to comply with reporting requirements;
• to comply with a court order, warrant, subpoena, summons, investigative demand or similar legal process;
• to identify or locate a suspect, fugitive, material witness, or missing person;
• when information is requested about the victim of a crime if the individual agrees or under other limited circumstances;
• to report information about a suspicious death;
• to provide information about criminal conduct occurring within Hill View;
• to report information in emergency circumstances about a crime; or
• where necessary to identify or apprehend an individual in relation to a violent crime or an escape from lawful custody.

Research. We may allow your protected health information to be used or disclosed for research purposes provided that the researcher adheres to certain privacy protections. Your protected health information may be used for research purposes only if the privacy aspects of the research have been reviewed and approved by a special Privacy Board or Institutional Review Board, if the researcher is collecting information in preparing a research proposal, if the research occurs after your death, or if you authorize the use or disclosure.

Coroners, Medical Examiners, Funeral Directors, Organ Procurement Organizations. We may release your protected health information to a coroner, medical examiner, funeral director or, if you are an organ donor, to an organization involved in the donation of organs and tissue.

To Avert a Serious Threat to Health or Safety. We may use and disclose your protected health information when necessary to prevent a serious threat to your health or safety or the health and safety of the public or another person. However, any disclosure would be made only to someone able to help prevent the threat.

Military and Veterans. If you are a member of the armed forces, we may use and disclose your protected health information as required by military command authorities. We may also use and disclose protected health information about foreign military personnel as required by the appropriate foreign military authority.

Workers' Compensation. We may use and disclose your protected health information to comply with laws relating to workers' compensation or similar programs.

National Security and Intelligence Activities: Protective Services for the President and Others. We may disclose protected health information to authorized federal officials conducting national security and intelligence activities or as needed to provide protection to the President of the United States, certain other persons or foreign heads of states or to conduct certain special investigations.

Fundraising Activities. We may use certain protected health information to contact you in an effort to raise money for Hill View and its operations. We may disclose protected health information to a foundation related to Hill View so that the foundation may contact you in raising money for Hill View. In doing so, we would only release contact information, such as your name, address and phone number and the dates your received treatment or services at Hill View. The money raised will be used to expand and improve the services and programs we provide the community and you. You have the right to "opt-out" of receiving fund raising materials and may do so by sending your request to the Hill View Development Department, 1610 Twenty eighth Street, Portsmouth, Ohio 45662. All reasonable efforts will be taken to ensure that you will not receive any fund raising communications from us.

Appointment Reminders. We may use or disclose protected health information to remind you about appointments.

Treatment Alternatives. We may use or disclose protected health information to inform you about treatment alternatives that may be of interest to you.

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

III. YOUR AUTHORIZATION IS REQUIRED FOR OTHER USES OF PROTECTED HEALTH INFORMATION
We will use and disclose protected health information (other than as described in this Notice or required by law) only with your written Authorization. You may revoke your Authorization to use or disclose protected health information in writing, at any time. If you revoke your Authorization, we will no longer use or disclose your protected health information for the purposes covered by the Authorization except where we have already relied on the Authorization.

IV. YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION
You have the following rights regarding your protected health information at Hill View:

Right to Request Restrictions. You have the right to request restrictions on our use or disclosure of your protected health information for treatment, payment or health care operations. You also have the right to restrict the protected health information we disclose about you to a family member, friend or other person who is involved in your care or the payment for your care.

We are required to agree to your requested restriction unless you are being transferred to another health care institution, the release of records is required by law, or the release of information is needed to provide you emergency treatment.

Right of Access to Protected Health Information. You have the right to request, either orally or in writing, your medical or billing records or other written information that may be used to make decisions about your care. We must allow you to inspect your records within 24 hours of your request. If you request copies of the records, we must provide you with copies within 2 days of that request. We may charge a reasonable fee for our costs in copying and mailing your requested information.

Right to Request Amendment. You have the right to request Hill View to amend any protected health information maintained by us for as long as the information is kept by or for Hill View. You must make the request in writing and must state the reason for the requested amendment.

We may deny your request for amendment if the information
• Was not created by Hill View, unless the originator of the information is no longer available to act on your request;
• Is not part of the protected health information maintained by or for Hill View;
• Is not part of the information to which you have a right of access; or
• Is already accurate and complete as determined by Hill View.

If we deny your request for amendment, we will give you a written denial including the reasons for the denial and the right to submit a written statement disagreeing with the denial.

Right to an Accounting of Disclosures. You have the right to request an "accounting" of our disclosures of your protected health information. This is a listing of certain disclosures of your protected health information made by Hill View or by others on our behalf, but does not include disclosures for treatment, payment and health care operations or certain other exception.

To request an accounting of disclosures, you must submit a request in writing, stating a time periods beginning after April 13, 2003 that is within six years from the date of your request. An accounting will include, if requested; the disclosure date; the name of the person or entity that received the information and address, if known; a brief description of the information disclosed; a brief statement of the purpose of the disclosure or a copy of the authorization or request; or certain summary information concerning multiple similar disclosures. The first accounting period provided within a 12-month period will be free; for further requests, we may charge you our costs.

Right to a Paper Copy of This Notice. You have the right to obtain a paper copy of this Notice, even if you have agreed to receive this Notice electronically. You may request a copy of this Notice at any time. (You may obtain a copy of this Notice at our website, www.hillviewretirement.org).

Right to Request Confidential Communications. You have the right to request that we communicate with you concerning protected health matters in a certain manner or at a certain location. For example, you can request that we contact you only at a certain phone number. We will accommodate your reasonable requests.

V. COMPLAINTS
If you believe that your privacy rights have been violated, you may file a complaint in writing with Hill View or with the Office of Civil Rights in the U.S. Department of Health and Human Services.

To file a complaint with Hill View, please contact the HIPAA Privacy Officer:
Hill View Retirement Center
1610 Twenty-eighth Street
Portsmouth, Ohio 45662
Attention: Administrator/Privacy Officer

We will not retaliate against you if you file a complaint.

VI. CHANGES TO THIS NOTICE
We will promptly revise and distribute this Notice whenever there is a material change to the uses or disclosures, your individual rights, our legal duties, or other privacy practices stated in this Notice. We reserve the right to change this Notice and to make the revised or new Notice provisions effective for all protected health information already received and maintained by Hill View as well as for all protected health information we receive in the future. We will post copies of the current Notice throughout Hill View. In addition, you will be notified in writing, as necessary.

VII. FOR FURTHER INFORMATION
If you have any questions about this Notice or would like further information concerning your privacy rights, please contact the Privacy officer at (740) 351-1012.