COUNCIL FOR EXTENDED CARE, INC.
Notice of Privacy Practices  |  Effective: April 14, 2003
                                     Revised 12/29/03

[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.]

Each time you visit a doctor, hospital, pharmacist or any other person that provides you health care services, a record of your visit is made. Typically this record contains information about you, such as reasons why you are seeking medical care, a plan for future care and billing information. Council for Extended Care, Inc. understands that this information, often referred to as your "medical information" or "health information," is personal.

Council for Extended Care, Inc. is required by law to maintain the privacy of your health information, and to provide you with a notice of our legal duties and privacy practices with respect to such information. This Notice of Privacy Practices ("Notice") describes your legal rights, advises you of our privacy practices, and lets you know how Council for Extended Care is permitted to use and disclose your health information. We will provide you with a copy of the current Notice the first time you receive services from Council for Extended Care, Inc. on or after April 14, 2003. We will also post a copy of the current Notice in our facility.

Council for Extended Care, Inc. is required to abide by the terms of the Notice currently in effect. In most situations we may use this information as described in this Notice without your permission (known as an "authorization"), but there are some situations where we may use it only after we obtain your written authorization, if law requires that we do so.

Council for Extended Care, Inc. reserves the right to change our privacy practices and revise our Notice. Such changes will be effective immediately and will apply to all health information that we maintain. The Notice will contain the effective date on the first page. If we have already provided you with a copy of the Notice, and later our privacy practices change and we revise our Notice, you may obtain a copy of the revised Notice by (1) asking for a copy of the current Notice to take home with you the next time you visit or receive health care services from Council for Extended Care, Inc., (2) downloading the current Notice from our website at www.sunnyhilladventures.org, or (3) contacting (314) 781-4950, and/or submitting your request in writing to Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110.

HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION

The following categories describe different ways that we may use and disclose your health information, and include some examples to explain such uses and disclosures. Not every use or disclosure in a category will be listed.

Some uses and disclosures of health information may be subject to additional restrictions under federal and state laws and regulations, such as those that apply to substance abuse treatment, HIV/AIDS testing and treatment, and mental health treatment. For example, if you are receiving alcohol or drug abuse services, information that would identify you as a person seeking help for a substance abuse problem is protected under a separate set of federal regulations known as "Confidentiality of Alcohol and Drug Abuse Patient Records," 42 C.F.R. Part 2. Under certain circumstances these regulations will provide your health information with additional privacy protections beyond what is described in this Notice.

For Treatment. We may use and disclose your health information to provide, coordinate and manage the services, supports, and health care you receive from us and other providers. We may disclose your health information to doctors, nurses, qualified mental retardation professionals (QMRPs), psychologists, social workers, direct support staff and other agency staff, volunteers and other persons who are involved in supporting you or providing care. We may share your health information with other health care providers when we consult with them about your care. For example, our staff may discuss your health information to develop and carry out your person centered plan, and to coordinate needed services, such as medical tests, transportation, physical therapy, etc. In some instances, our staff may need to disclose your health information to entities outside of our organization (for example, to another provider or a state/local agency) to obtain new services for you.

For Payment. We may use and disclose your health information so we can be paid for the services we provide to you. This can include billing a third party, such as Medicaid or other state agency (for example, the Department of Mental Health) or your insurance company. For example, we may need to provide the Department of Mental Health with information about the services we provide to you so we will be reimbursed for those services. We also may need to provide the state Medicaid program with information to ensure you are eligible for services you are receiving. We may also provide your health information to another health care provider or entity for their payment activities (such as the physician that provides you treatment).

For Health Care Operations. We may use and disclose your health information as necessary for us to operate Council for Extended Care, Inc. and to maintain the quality of services that we provide to our consumers. For example, we may use your health information to review the services we provide and the performance of our employees supporting you. We may disclose your health information to train our staff, students and volunteers. We also may use health information to study ways to more efficiently manage our organization, for accreditation or licensing activities or for our continuous quality improvement. There are also some circumstances that we are permitted to disclose your health information to another health care provider (such as a physician to which we refer you to) for his or her own health care operations.

Business Associates. We may disclose your health information to certain individuals and companies that we contract with (our "business associates") so that they can perform the job we have asked then to do. For example, we may contract with a billing company to assist us with billing insurance companies and third party payors so that we can be paid for the services that we provide to you. To protect your health information, however, we require our business associates to appropriately safeguard your health information and to meet the same confidentiality standards that we are required to meet.

Appointment Reminders, Treatment and Service Alternatives and Health Related Benefits and Services. We may use and disclose your health information to contact you to remind you of a scheduled appointment or to contact you about treatment and service alternatives or health-related benefits and services that may be of interest to you.

Marketing Communications. We may use and disclose your health information to tell you about a product or service to encourage you to purchase the product or service. For example, we may send you a newsletter or other mailing about certain educational programs. We will not, however, sell or distribute your health information to third parties who do not have a relationship with us unless we have obtained an authorization from you. For instance, we would not release information or patient lists to pharmaceutical companies for those companies' drug promotions unless we have your authorization to do so.

Fundraising. We may use and disclose your health information so that we (or one of our business associates) can contact you to raise funds for the benefit of Council for Extended Care. We will only release demographic information, such as your name and address, and the dates you received treatment or services from us. If you do not want Council for Extended Care to contact you for fundraising purposes, please notify Angela Jackson, 5257 Shaw Ave. Suite 305, St. Louis Mo. 63110.

Disclosures to Family and Others. We may disclose your health information to one of your family members relatives or close personal friends or to any other person identified by you, but we will only disclose information which we feel is relevant to that person's involvement in your care or the payment for your care. If you are feeling well enough to make decisions about your care, we will follow your directions as to who is sufficiently involved in your care to receive information. If you are not present or cannot make these decisions, we will make a decision based on our experience as to whether it is in your best interest for a family member or friend to receive information about you and how much information they should receive. If there is a family member, other relative, or close personal friend that you do not want use to disclose your health information to, please notify the staff that assists you.

We may disclose your health information to an entity assisting in disaster relief efforts (for example, the American Red Cross) so your family can be notified about your condition, status and location in an emergency.

Required by Law. We will disclose your health information when we are required to do so by federal, state or local law. For instance, we are obligated to report suspected child abuse to the proper authorities.

Public Health Activities. We may disclose your health information for public health activities and purposes. For example, we may report health information to a public health authority that is authorized by law to collect or receive the information for purposes of preventing or controlling disease, neglect, reporting reactions to medications or problems with health care products, or notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition.

Victims of Abuse, Neglect or Domestic Violence. We may disclose health information to a government authority authorized by law to receive reports of abuse, neglect, or domestic violence, if we believe you are a victim of abuse, neglect, or domestic violence. We will make every effort to obtain your permission before releasing this information, but in some cases we may be required or authorized to act without your permission.

Health Oversight Activities. We may disclose health information to a health oversight agency for activities authorized by law, including audits, investigations, inspections, licensure or disciplinary actions. These and similar types of activities are necessary for appropriate oversight of the health care system, government benefit programs, and entities subject to various government regulations. For example, we must make our books, records and other information available to the government agencies in charge of overseeing Medicare and Medicaid so that we can show these agencies that we are complying with Medicare and Medicaid provider requirements.

Judicial and Administrative Proceedings. We may disclose your health information if we are ordered to do so by a court or administrative tribunal. We may also disclose your health information in response to a subpoena, discovery request, or other lawful process, but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

Disclosures for Law Enforcement Purposes. We may release your health information to a properly identified law enforcement official in the following situations:

• As required by law.
• In response to a court order, subpoena, warrant, summons or similar process.
• To assist law enforcement to identify or locate a suspect, fugitive, material witness or missing person.
• In certain limited circumstances, if you are, or we suspect you are, the victim of a crime and we are unable to obtain your agreement.
• If we believe that a death may be the result of criminal conduct.
• If we believe that the information constitutes evidence of criminal conduct occurring at our facility.
• In emergency circumstances to report a crime, if it appears necessary to disclose the information related to the commission and nature of a crime, the location of the crime or victims, or the identity, description or location of the person who committed the crime.

Uses and Disclosures About Decedents. We may release information about a deceased person to a coroner or medical examiner to identify the person, determine the cause of death or perform other duties recognized by law. We may also release a deceased person's health information to funeral directors as necessary to carry out their duties.

Organ, Eye or Tissue Donation. If you are an organ donor, we may disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue.

Research. Under certain circumstances, we may use or disclose your health information for research. Before we disclose health information for research, the research will have been approved through an approval process that evaluates the needs of the research project with your needs for privacy of your health information. We may, however, disclose your health information to a person who is preparing to conduct research to permit them to prepare for the project, but no health information will leave Council for Extended Care during that person's review of the information. Enrollment in most of these research projects can only occur after you have been informed about the study, had an opportunity to ask questions, and indicated your willingness to participate in the study by signing a consent form. Other studies may be performed using your health information without requiring your consent. These studies will not affect your treatment or welfare, and your health information will continue to be protected. For example, a research study may involve comparing the health and recovery of all patients who received one medication to those who received another for the same condition.

To Avert Serious Threat to Health or Safety. We may use or disclose your health information if we believe the use or disclosure is necessary to prevent or lessen a serious or imminent threat to the health or safety of a person or the public. In such cases, we will only share your information with someone able to help prevent the threat. We also may release your health information if we believe the disclosure is necessary for law enforcement authorities to identify or apprehend an individual who admitted participation in a violent crime or who is an escapee from a correctional institution or from lawful custody.

For Specified Government Functions. In certain circumstances, federal regulations authorize us 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, inmates and law enforcement custody. For example, if you are a member of the Armed Forces, we may use and disclose your health information to appropriate military command authorities for activities they deem necessary to carry out their military mission.

Workers Compensation. We may disclose your health information as authorized by, and to the extent necessary to comply with, laws relating to workers' compensation or similar programs that provide benefits for work-related injuries or illness.

Uses and Disclosure Requiring your Written Permission. Other uses and disclosures of your health information not covered by this Notice or the laws that apply to us will be made only with your specific written permission (sometimes known as an "authorization"). If you provide us permission to use or disclose your health information, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose your health information for the reasons covered by your written permission. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION.

Although your health record is the physical property of Council for Extended Care, Inc., the information contained in the record belongs to you. The following describes your rights with respect to your health information that we maintain.

Right to Request Restrictions. You have the right to request that we restrict the uses or disclosures of your health information that we may make to carry out treatment, payment, or health care operations. You also have the right to request that we restrict the uses or disclosures we make to a family member, other relative, a close personal friend or any other person identified by you. For example, you could ask that we not disclose your health information to your brother or sister who comes in to talk to us. To request a restriction, you may do so at any time. If you request a restriction, you should do so by submitting your request in writing to Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110 and tell us: (a) what information you want to limit, (b) whether you want to limit use or disclosure or both, and (c) to whom you want the limits to apply (for example, disclosures to your spouse).

We are not required to agree to any requested restriction. However, if we do agree, we will follow that restriction unless the information is needed to provide emergency treatment. Even if we agree to a restriction, you can let us know later that you do not want us to continue to comply with your request.

Right to Receive Confidential Communications. You have the right to request that we communicate your health information to you in a certain way or at a certain location. For example, you can ask that we only contact you by mail or at work. We will not require you to tell us why you are asking for the confidential communication. If you want to request confidential communication, you must do so in writing to Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110. Your request must state how or where you can be contacted.

We will use our best efforts to accommodate all reasonable requests. However, we may, if necessary, require information from you concerning how payment will be handled. We also may require an alternate address or other method to contact you.

Right to Inspect and Copy. With a few very limited exceptions, you have the right to inspect and obtain a copy of your health information that we maintain. To inspect or copy of your health information, you must submit your request in writing to Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110. Your request should state specifically what health information you want to inspect or copy. If you request a copy of the information, we may charge a fee for the costs of copying and, if you ask that it be mailed to you, the cost of mailing. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to your health information, you may request that the denial be reviewed. Another licensed health care professional chosen by us 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. You have the right to request an amendment (correction) to your health record if you feel that the information we have about you is incorrect or incomplete. You have the right to request an amendment for as long as we keep the information. To request an amendment, you must submit your request in writing to Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110. In addition, you must provide a reason that supports your request. Although you are permitted to request that we amend your health information, we may deny your request if it is not in writing or does not include a reason to support your 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 health information we keep;
• 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 have the right to an "accounting of disclosures." An accounting of disclosures is a list of the disclosures of your health information that we have made, with some exceptions. To request this list, you must submit your request in writing to Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110. Your request must state a time period which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a twelve month period will be free. For additional lists, we may charge you for the costs of providing the list.

Right to Copy of this Notice. You have the right to obtain a paper copy of our Notice of Privacy Practices. You may obtain a paper copy even though you agreed to receive the notice electronically. You may request a copy of our current Notice of Privacy Practices at any time by (1) asking for a copy of the Notice to take home with you the next time you visit or receive health care services at our facility, [(2) contacting (314) 781-4950,] or (3) submitting your request in writing to Privacy Officer at Council for Extended Care.

You may also obtain a copy of our Notice of Privacy Practices over the Internet at our web site, www.sunnyhilladventures.org

Complaints. If you believe your privacy rights have been violated, you can file a complaint with us and with the Secretary of the U.S. Department of Health and Human Services.

To file a written complaint with us, contact Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110, (314) 781-4950.

To file a complaint with the Secretary of the U.S. Department of Health and Human Services, send your complaint to him or her in care of the U.S. Department of Health and Human Services - Office for Civil Rights, 601 East 12th Street - Room 248, Kansas City, Missouri 64106 or call (816) 426-7278.

Questions and Information. If you have any questions or want more information concerning this Notice of Privacy Practices, please contact Privacy Officer/CO Council for Extended Care, 5257 Shaw Avenue Suite 305, St. Louis, MO 63110, (314) 781-4950.