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.

USE AND DISCLOSURE OF HEALTH INFORMATION
Visiting Nurse Association (VNA) 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 after the Visiting Nurse Association (VNA) has obtained your written consent. The Visiting Nurse Association (VNA) has established a policy 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 AFTER YOU HAVE PROVIDED YOUR WRITTEN CONSENT:

To Provide Treatment. The Visiting Nurse Association (VNA) may use your health information to coordinate care within the Visiting Nurse Association (VNA) and others involved in your care, such as your attending physician, members of the Visiting Nurse Associataion (VNA) interdisciplinary team and other health care professionals who have agreed to assist the Visiting Nurse Association (VNA) in coordinating care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. The Visiting Nurse Association (VNA) may also disclose your health care information to individuals outside of the Visiting Nurse Association (VNA) involved in your care including family members, clergy whom you have designated, pharmacists, suppliers of medical equipment or other health care professionals that the Visiting Nurse Association (VNA) uses in order to coordinate your care.

To Obtain Payment. The Visiting Nurse Association (VNA) may include your health information in invoices to collect payment from third parties for the care you may receive from the Visiting Nurse Association (VNA). For example, the Visiting Nurse Association (VNA) may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or the Visiting Nurse Association (VNA). The Visiting Nurse Association (VNA) also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for Visiting Nurse Association (VNA) care and the services that will be provided to you.

To Conduct Health Care Operation . The Visiting Nurse Association (VNA) may use and disclose health care information for its own operations in order to facilitate the function of the Visiting Nurse Association (VNA) and as necessary to provide quality care to all of the the Visiting Nurse Association (VNA)'s patients. Health care operations include 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 compliance programs.
• Business planning and development including cost management and planning related analyses and formulary development.
• Business management and general administrative activities of the Visiting Nurse Association (VNA).
• Fundraising for the benefit of the Visiting Nurse Association (VNA) and certain marketing practices.

For example, the Visiting Nurse Association (VNA) may use your health information to evaluate its staff performance, combine your health information with other Visiting Nurse Association (VNA) patients in evaluating how to effectively serve all Visiting Nurse Association (VNA) patients, disclose your health information to Visiting Nurse Association (VNA) 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).

For Fundraising Activities. The Visiting Nurse Association (VNA) may use information about you including your name, address, phone number and the dates you received care at the Visiting Nurse Association (VNA) in order to contact you or your family to raise money for the Visiting Nurse Association (VNA). The Visiting Nurse Association (VNA) may also release this information to a related Visiting Nurse Association (VNA) foundation. If you do not want the Visiting Nurse Association (VNA) to contact you or your family, notify the Privacy Protection Officer at (810) 984-4131 and indicate that you do not wish to be contacted.

For Appointment Reminders: The VNA may also use and disclose your health information to contact you as a reminder that you have an appointment for a home visit.

For Treatment Alternatives. The VNA may use and disclose your health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

FEDERAL PRIVACY RULES ALLOW THE VISITING NURSE ASSOCIATION (VNA) TO USE OR DISCLOSE YOUR HEALTH INFORMATION WITHOUT YOUR CONSENT OR AUTHORIZATION FOR A NUMBER OF REASONS:

When Legally Required: The Visiting Nurse Association (VNA) 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 Visiting Nurse Association (VNA) 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 report adverse events, product defects, to track products or enable product recalls, repairs and replacements and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
• 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 required.

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

To Conduct Health Oversight Activities. The Visiting Nurse Association (VNA) may disclose your health information to a health oversight agency for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. The Visiting Nurse Association (VNA), 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 Conjunction With Judicial And Adminstrative Proceedings . The Visiting Nurse Association (VNA) may disclose your health information in the course of any judicial or adminstrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only when the Visiting Nurse Association (VNA) makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information.

For Law Enforcement Purposes: The Visiting Nurse Association (VNA) 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 Visiting Nurse Association (VNA) has a suspicion that your death was the result of criminal conduct including criminal conduct at the Visiting Nurse Association (VNA).
• In an emergency in order to report a crime.

To Coroners and Medical Examiners. The Visiting Nurse Association (VNA) may disclose your health information to coroners and medical examiners for the purposes of determining your cause of death or for other duties, as authorized by law.

To Funeral Directors. The Visiting Nurse Association (VNA) 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 Visiting Nurse Association (VNA) may disclose your health information prior to and in reasonable anticipation of your death.

For Organ, Eye Or Tissue Donation. The Visiting Nurse Association (VNA) 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 Visiting Nurse Association (VNA) may, under very select circumstances, use your health information for research. Before the Visiting Nurse Association (VNA) discloses any of your health information for such research purposes, the project will be subject to an extensive approval process. The Visiting Nurse Association (VNA) will ask your permission if any researcher will be granted access to your individually identifying health information.

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

For Specified Government Functions In certain circumstances, the Federal regulations authorize the Visiting Nurse Association (VNA) to use or disclose your health information to facilitate specified governments 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 Compensations. The Visiting Nurse Association (VNA) may release your health information for worker's compensation or similar programs

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION
Other than stated above, the Visiting Nurse Association (VNA) will not disclose your health information other than with your written authorization. If you or your representative authorizes the Visiting Nurse Association (VNA) 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 the following rights regarding your health information that the Visiting Nurse Association (VNA) maintains:
Right to request restrictions. You may request restrictions on certain uses and disclosures of your health information. You have the the right to request a limit on the Visiting Nurse Association (VNA)'s disclosure of your health information to someone who is involved in your care or the payment of your care. However, the Visiting Nurse Association (VNA) is not required to agree to your request. If you wish to make a request for restrictions, please contact the agency's Privacy Protection Compliance Office at (810) 984-4131.
Right to receive confidential communications. You have the right to request the the Visiting Nurse Association (VNA) communicate with you in a certain way. For example, you may ask the the Visiting Nurse Association (VNA) 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 agency's Privacy Protection Compliance Officer at (810) 984-4131. The Visiting Nurse Association (VNA) 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 agency's Privacy Protection Compliance Officer at (810) 984-4131. If you request a copy of your health information, the Visiting Nurse Association (VNA) 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 care records are incorrect or incomplete, you may request that the Visiting Nurse Association (VNA) amend the records. That request may be made as long as the information is maintained by the Visitng Nurse Association (VNA). A request for an amendment of records must be made in writing to the agency's Privacy Protection Compliance Officer at (810) 984-4131. The Visiting Nurse Association (VNA) 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 Visiting Nurse Association (VNA), if the records you are requesting are not part of the Visiting Nurse Assoication (VNA)'s records, if the health information you wish to amend is not part of the health information or your representative are permitted to inspect and copy, or if, in the opinion of the Visiting Nurse Association (VNA), 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 disclosures of your health information made by the Visiting Nurse Association (VNA) for any reason other than for treatment, payment or health operations. The request for an accounting must be made in writing to the agency's Privacy Protection Compliance Officer . 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 Visiting Nurse Association (VNA) 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 agency's Privacy Protection Compliance Officer at (810) 984-4131.
DUTIES OF THE VISITING NURSE ASSOCIATION (VNA)
The Visiting Nurse Association (VNA) is required by law to maintain the privacy of your health information and to provide you and your representative this Notice of its duties and privacy practices. The Visiting Nurse Association (VNA) is required to abide by terms of this Notice as may be amended from time to time. The Visiting Nurse Association (VNA) 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 Visiting Nurse Association (VNA) changes its Notice, the Visiting Nurse Association (VNA) will provide a copy of the revised Notice to you and your appointed representative. You or your personal representative have the right to express complaints to the Visiting Nurse Association (VNA) and to the Secretary of Health and Human Services if you or a representative believe that your privacy rights have been violated. Any complaints to the Visiting Nurse Association (VNA) should be made in writing to the Privacy Officer. The Visiting Nurse Association (VNA) 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.

CONTACT PERSON
The Visiting Nurse Association (VNA)'s contact person for all issues regarding patient privacy and your rights under the Federal privacy standards is the Privacy Protection Compliance Officer at 1430 Military Street Suite A Port Huron, MI 48060 (810) 984-4131 or 1-800-959-4131.

EFFECTIVE DATE
This Notice is effective April 14, 2003.

IF YOU HAVE ANY QUESTIONS REGARDING THIS NOTICE, PLEASE CONTACT:
PRIVACY PROTECTION COMPLIANCE OFFICER
1430 Military Street Suite A Street
Port Huron, MI 48060
(810) 984-4131 OR 1-800-959-4131