Solace Home Care

Notice of Privacy Practices Version 3 Effective Date: October 7th, 2013

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. WHAT IS THIS NOTICE? In order to administer our home care services Solace Home Care (SHC) must collect, process and disclose Protected Health Information (PHI). We consider this information to be private and confidential and have policies and procedures in place to protect such information against unlawful use and disclosure. This notice describes what information we may collect and how we may collect it, when and to whom we may disclose it and provides you with additional important information. Solace Home Care may not use or disclose PHI in a way that is not consistent with this Notice. If you have any questions about this notice or wish to file a privacy related complaint please contact the SHC Director of Data Management. Aaron McCall, Director of Data Management and Privacy Officer Phone: (330) 312-7902 Email: datamanagement@solacehc.com WHAT IS PROTECTED HEALTH INFORMATION (PHI)? The Health Insurance Portability and Accountability Act of 1996 (HIPAA) defines Protected Health Information as all individually identifiable health information held or transmitted by a covered entity or its business associates, in any form or media, whether electronic, paper or oral. This information may contain but is not limited to Personal data such as names, addresses, birth dates, social security number Demographic data that relates to the patients past, current or future condition, the provision of care to the individual or the past, current or future payment for the provision of care services. Any information that identifies the individual or for which there is reasonable basis to believe it can be used to identify the individual. Protected Health Information does not include publicly available information, information that is reported in a summarized or aggregate fashion or information that has been appropriately de-identified. WHAT PHI DOES SOLACE HOME CARE COLLECT? Solace Home Care may collect and process the following information in order to administer care services in an efficient manner: Personal data such as names, addresses, contact details, birth dates, social security number, insurance plan details and any financial details required for the collection of fees for services. Medical data such as past and current diagnoses, past, current and future prescription information Information on your relationship and transactions with us and our business associates.

Solace Home Care

Notice of Privacy Practices Version 3 Effective Date: October 7th, 2013

HOW DOES SOLACE HOME CARE COLLECT THIS INFORMATION? Solace Home Care may collect information about you in a variety of ways. This may include but is not limited to: Paper based forms filled out during contact with you whether this is in person, via phone calls, facsimile, face to face or electronic mail. Electronic forms filled out via Solace Home Cares website. Information transferred to us (by paper or electronically) by a third party agency. Information, notes and observations documented by Solace Home Care personnel. HOW DOES SOLACE HOME CARE PROTECT THIS INFORMATION? At Solace Home Care we restrict all access to data to those who need the information to carry out and fulfill their assigned duties. We maintain physical, electronic and procedural safeguards to protect PHI against unauthorized access and use. We have an assigned HIPAA Compliance Officer who has the overall responsibility for developing, implementing, educating personnel about and enforcing policies and procedures to safeguard PHI which are consistent with applicable law. TO WHOM AND WHY MAY WE DISCLOSE INFORMATION? Solace Home Care must use and disclose your Protected Health Information to provide information: To you or someone who has the legal right to act for you (your designated representative or someone who holds an active Power Of Attorney), To our personnel (where required) to carry out their duties, To the Secretary of the Department of Health and Human Services, if necessary, to make sure your privacy is protected and, Where required by law Solace Home Care may use and disclose your Protected Health Information for the following purposes: To State and Federal agencies that have the legal right to receive such data. For public health activities (such as reporting disease outbreaks). For government health care oversight activities (such as fraud and abuse investigations). For judicial and administrative proceedings (such as in response to a court order). For law enforcement purposes (such as providing limited information to locate missing persons). To avoid serious and imminent threats to health or safety. By law Solace Home Care must have your written permission to use or give out your Protected Health Information for any purpose that isnt set out in this notice. You may revoke your written permission at any time except if Solace Home Care has already acted based upon your permission. YOUR RIGHTS AS OUR CLIENT By law you have the following rights:

To view and obtain a copy of your Protected Health Information and any other information held by Solace Home Care. To have your Protected Health Information amended if you believe it is wrong or if information is missing. To obtain a copy of our disclosure record which records all instances of Solace Home Cares disclosures of your Protected Health Information.

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Notice of Privacy Practices Version 3 Effective Date: October 7th, 2013

This will not include disclosures made to you, your representative/POA or for law enforcement purposes. To ask Solace Home Care to communicate with you in a different manner (for example by sending your materials to a different address or different form of communication) To ask Solace Home Care to limit or place additional conditions on how your Protected Health Information is used or disclosed. Please note Solace Home Care may not always be able to agree to your request. To get a separate or additional copy of this Notice. To file a complaint with the Director of Data Management if you believe this Notice or your rights have been violated in any way. o You also have the right to not be discriminated against for making such complaint.

You may exercise any of your rights laid out in this notice by contacting the Director of Data Management at datamanagement@solacehc.com . If you do not have access to email please speak to your Care Provider or Care Manager and they will advise you of alternative contact methods. HOW WE HANDLE INFORMATION ON CLIENTS WHO STOP CARE Solace Home Care is required by law to record and maintain records on clients for six years after termination of care services. At this point all held information will be destroyed. HOW THIS NOTICE IS DISTRIBUTED? This Notice is distributed and explained to all clients at their initial point of contact with us. This will normally occur at the intake interview and assessment. The Notice will be re-distributed if a material change is made to the Notice or the laws that requires its creation. At all times this Notice will be explained to the client and/or their representative and they will be asked to sign the Notice ensuring they have understood its contents. This notice is also distributed to all personnel at their initial company orientation session and they will be required to sign the Notice. This forms part of a policies contract between Solace Home Care and the personnel. Clients and personnel may also request a copy of this Notice at any time by contacting the Director of Data Management. An up to date version will also be made available on the Solace Home Care website. WHAT SHOULD A PERSON DO IF THEY BELIEVE THIS NOTICE HAS BEEN VIOLATED? If you believe this Notice of any aspect of Solace Home Cares privacy policies have been violated with respect to you or someone else please contact the Director of Data Management using the contact information found at the beginning of this Notice. You may also contact the Secretary of the Department of Health and Human Services. The U.S. Department of Health and Human Services 200 Independence Avenue, S.W. Washington, D.C. 20201 Toll Free: 1-877-696-6775

Solace Home Care

Notice of Privacy Practices Version 3 Effective Date: October 7th, 2013