Notice of Privacy Practices

Effective April 14, 2003, Concord Medical is required by law to maintain the privacy of certain confidential health care information known as Protected Health information or PHI, and to provide you with a notice of our legal duties and privacy practices with respect to your PHI. Concord Medical is also required to abide by the terms of this Notice currently in effect. We reserve the right to change the terms of this Notice at any time, making the new provisions effective for all health information and records that we have and continue to maintain. All changes in this Notice will be prominently displayed and available at our office.

Uses and Disclosures of PHI: Concord Medical may use PHI for the purpose of treatment, payment, and health care operations, in most cases without your written permission.
Examples of our use of your PHI are as follows:

1) For Treatment
We will use your health information to make decisions about the provision, coordination or management of your healthcare, including analyzing or diagnosing your condition and determining the appropriate treatment for that condition. It may also be necessary to share your health information with another health care provider whom we need to consult with respect to your care. We may contact you from time to time to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. These are only examples of uses and disclosures of medical information for treatment purposes that may or may not be necessary in your case.

2) For Payment
We may need to use or disclose information in your health record to obtain reimbursement from you, from your health-insurance carrier, or from another insurer for our services rendered to you. This may include determinations of eligibility or coverage under the appropriate health plan, pre-certification and pre-authorization of services or review of services for the purpose of reimbursement. This information may also be used for billing, claims management and collection purposes, and related healthcare data processing through our system.

3) For Health Care Operations
Your health records may be used in our business planning and development operations, including improvements in our methods of operation, and general administrative functions. We may also use the information in our overall compliance planning, healthcare review activities, and arranging for legal and auditing functions.

Use and Disclosure of PHI Without Your Authorization
Concord Medical is permitted to use PHI without your written authorization, or opportunity to object, in certain situations, and unless prohibited by a more stringent state law including:

• For the treatment, payment or healthcare operations activities of another health care provider who treats
you For health care and legal compliance activities

• To a family member, or other relative, or close personal friend or other individual involved in your care if we obtain your verbal agreement to do so or if we give you an opportunity to object to such disclosure and you
do not raise an objection

• In certain circumstances where we are unable to obtain your agreement (due to communication barriers or other reasons) and we determine using professional judgement, that the disclosure is in your best interest
For emergency treatment situations – if this happens, we will try to obtain your consent as soon as
reasonable possible after the delivery of treatment

• If we are required by law or as a matter of necessity to treat you, and we have attempted to obtain your
consent but have been unable to do so we may still use or disclose you PHI to treat you

• To a public health authority in certain situations as required by law (such as to report abuse, neglect or
domestic violence)

• For health oversight activities including audits or government investigations, inspections, disciplinary
proceedings, and other administrative or judicial actions undertaken by the government (or their contractors) by law to oversee the health care system

• For judicial and administrative proceedings as required by a court or administrative order, or in some cases in response to a subpoena or other legal process

• For law enforcement activities in limited situations, such as when responding to a warrant
For military, national defense and security and other special government functions

• To avert a serious threat to the health and safety of a person or the public at large

• For workers’ compensation purposes, and in compliance with workers’ compensation laws

• To coroners, medical examiners, and funeral directors for identifying a deceased person, determining cause of death, or carrying on their duties as authorized by law

• We may also use or disclose health information about you in a way that does not personally identify you or
reveal who you are

Except as indicated above, your health information will not be used or disclosed to any other person or entity without your specific Authorization, which may be revoked at any time. In particular, except to the extent disclosure has been made to governmental entities required by law to maintain the confidentiality of the information, information will not be further disclosed to any other person or entity with respect to information concerning mental-health treatment, drug and alcohol abuse, HIV/AIDS or sexually transmitted diseases that may be contained in your health records. We likewise will not disclose your health-record information to an employer for purposes of making employment decisions, to a liability insurer or attorney as a result of injuries sustained in an automobile accident, or to educational authorities, without you written authorization.

Patient Rights: As a patient, you have a number of rights with respect to your PHI including:

The Right to Access, Copy or Inspect Your PHI
You have the right to inspect & copy your health records. Access to your health records will not include psychotherapy notes contained in them, or information compiled in anticipation of or for use in a civil, criminal or administrative action or proceeding to which your access is restricted by law. We will charge a reasonable fee for providing a copy of your health records, or a summary of those records, at your written request, which includes the cost of copying, postage, and preparation or an explanation or summary of the information.

The Right to Amend Your PHI
You have the right to ask us to amend written medical information that we may have about you. We will generally amend your information within 60 days of your written request and will notify you when we have amended the information. We are permitted by law to deny your request only in certain circumstances, like when we believe the information you have asked us to amend is correct

The Right to Request an Accounting
You have a limited right to receive an accounting of all disclosures we make to other persons or entities of your health information except for disclosures required for treatment, payment and healthcare operations, disclosures that require an Authorization, disclosure incidental to another permissible use or disclosure, and otherwise as allowed by law. We will not charge you for the first accounting in any twelve-month period; however, we will charge you a reasonable fee for each subsequent request for an accounting within the same twelve-month period.

The Right That we Restrict the use and Disclosure of Your PHI
You may request that we restrict the uses and disclosures of your health record information for treatment, payment and operations, or restrictions involving your care or payment related to that care. We are not required to agree to the restriction; however, if we agree, we will comply with it, except with regard to emergencies, disclosure of the information to you, or if we are otherwise required by law to make a full disclosure without restriction.

The Right to request receipt of confidential communications of your medical information by an alternative means or at an alternative location
If you require such an accommodation, the request must be received in writing. You may be charged a fee for the accommodation and will be required to specify the alternative address or method of contact and how payment will be handled.

All requests listed above must be in writing
All requests related to your rights under this Notice, must be made in writing and addressed to the Privacy Officer at our address. We will respond to your request in a timely fashion.

You may file a written complaint to us or to the Secretary of Health and Human Services if you believe that your privacy rights with respect to confidential information in your health records have been violated. All complaints must be in writing and must be addressed to the Privacy Officer (in the case of complaints to us) or to the person designated by the U.S. Department of Health and Human Services if we cannot resolve your concerns. You will not be retaliated against for filing such a complaint. More information is available about complaints at the government’s web site, HYPERLINK "http://www.hhs.gov/ocr/hipaa" http://www.hhs.gov/ocr/hipaa.

All questions concerning this Notice or requests made pursuant to it should be addressed to:

PRIVACY OFFICER
Concord Medical
6 Sharpley Road,
Wilmington, DE 19803