JOINT NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED BY GERBER MEMORIAL HEALTH SERVICES AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.

THIS NOTICE APPLIES TO THE PRIVACY PRACTICES OF:

• Spectrum Health Gerber Memorial
• Any health care professional authorized to enter information into your hospital chart.
• All departments and units of the Hospital.
• Any member of a volunteer group we allow to help you while you are in the hospital.
• All employees, staff, and other hospital personnel

In this Notice, each reference to “we” is meant to include all of the above entities, providers, sites, and locations. Any or all of these entities, providers, sites and locations may share information about you for treatment, payment or health care operation purposes described in this Notice.

USING AND DISCLOSING YOUR HEALTH INFORMATION
Each time you visit a hospital, physician, or other health provider, a record of your visit and the care provided to you during that visit is made. Typically, this record contains information regarding your health history, symptoms, examinations and tests performed including the results of those tests, any diagnoses or treatment and any plan for future care or follow-up with respect to your condition or treatment. Some of this information may be collected from other health care providers. This information is often referred to as your health or medical record. When we create a record or collect this type of health information about you, we use it for current and future treatment purposes, to obtain payment for treatment provided to you, for administrative and operational purposes, and to evaluate the quality of the care provided to you. By way of example, we may use or disclose certain identifiable health information about you, without your authorization for other reasons such as:

• A means of communication with other health professionals who contribute to or participate in your care while you are our patient including doctors, nurses, technicians, medical students, and other clinical personnel involved in taking care of you, as well as people outside of our organization who may be involved in your medical care after you leave our facilities, such as family members, clergy or others who provide services that are part of your care. For example, we may need to disclose information about whether you have diabetes to a doctor treating you for a broken bone or an infection because diabetes can slow the healing process;
• A means for preparing documentation relating to your treatment that we are required by law to maintain and, in some cases, give out for public health purposes, abuse or neglect reporting, auditing purposes, research studies, funeral arrangements and organ donation, workers’ compensation purposes and emergencies;
• A means by which you or a third party payor can verify services provided to you so that we may bill for or receive payment from you, an insurance company or other third party payor, or person responsible for paying for any of your care. For example, we may need to give your health plan information about treatment you received in our emergency department so the plan will pay us for the care we provided;
• A source of data in our daily operations as a health care provider. For example, we may need to use your health information and record as a tool in educating and assessing the competency of physicians, nurses, and technicians who provide care here;
• A source of data for contacting you and reminding you of appointments for treatment or care;
• A source of data for advising you of possible treatment options or alternatives and other health-related benefits or services that may be of interest to you;
• A source of data for a facility directory to be used while you are a patient of ours, including your name, location in the facility, your general condition and religious affiliation. This information may be released to people who ask about you by name, although your religious affiliation will only be disclosed to members of the clergy (even if they do not ask for you by name);
• A source of information for public health officials charged with improving the health of our city, state, and nation, or responsible for averting a serious threat to the health or safety of you, another person or the public;
• A tool used to assess and continually work toward improving the overall quality of care we render and the outcomes we achieve;
• Information required to be disclosed by federal, state or local law;
• A source of data for organizations that handle organ procurement, transplant or donation as necessary, to facilitate appropriate donation and transplant in the event you are an organ donor;
• We may use certain information (name, address, telephone number, dates of service, age and gender) to contact you in the future to raise money for Spectrum Health Gerber Memorial. The money raised will be used to expand and improve the services and programs we provide the community;
• For members of domestic or foreign armed forces, to comply with the requirements of domestic or foreign military command authorities;
• A source of data and information for health oversight agencies in connection with legally authorized activities related to the investigation, inspection and licensure of health care providers; and/or
• A source of data and information in connection with a legal dispute or lawsuit in which you are involved, in response to a court or administrative order, subpoena or other discovery request, as permitted by law.

We routinely provide patient health information when otherwise required by law, such as when law enforcement officials are entitled to such information in specific circumstances. In many other instances, we will ask for written authorization before using or disclosing any identifiable health information about you. If we request an authorization and you choose to sign one to disclose your protected health information, you can later revoke that authorization to stop future uses and disclosure of that information without your consent.

We may change our policies or practices regarding the use of your health information from time to time. Before we make a significant change in our policies or practices, we will change our notice and post the new notice in waiting areas and on our web site at www.gerberhospital.org. You have a right to a written copy of and may always request a copy of our current notice, at any time. For more information about our privacy practices and policies, please contact the individual and office listed at the end of this Notice.

YOUR HEALTH INFORMATION RIGHTS
Although your health record is the physical property of Spectrum Health Gerber Memorial, the information contained within your health record belongs to you. You have a right to request the restriction of certain uses and disclosures of your information. You also have the right to amend and request changes in the information contained within your health record and to obtain an accounting of disclosures of your health information when such disclosures are made for other than treatment, payment, or related administrative or operating purposes as described above. Any request to amend your record must be made in writing and we may deny your request if it:

• is not in writing;
• does not include a reason to support the request;
• was created by another health care provider;
• is not part of the health information kept by or for our organization;
• is not part of the health information you would be permitted to inspect or copy; or
• is accurate and complete as is.

Any request for an accounting of disclosures of your information must be in writing, can be for a time period no longer than six years and may not include a period prior to April 14, 2003. The first disclosure list you request within a 12-month period is free. For any additional request, we may charge you for the cost of providing the list.

You may request, in writing, that we not use or disclose your information for treatment, payment or administrative purposes except when specifically authorized by you, when required by law, or emergency circumstances. We will consider your request, but you should be aware that we are not legally required to accept it and may, if we deem your request too restrictive, elect not to treat you or to disregard it in an emergency situation. You have the right, with limited exceptions, to inspect and obtain a copy of your health record. Usually, this includes medical and billing records, but may not include records such as psychotherapy notes.

If you request copies of your health records, the request must be in writing and we will charge you five dollars ($5.00) for the first 3 pages and fifty cents ($.50) for each page thereafter for such copies. This charge is directly attributable to the administrative and copying costs associated with meeting your request. If your request for copies of your health record is, in your opinion, an emergency, please let us know as we do not intend to deny you access to your health records or information in an emergency circumstance and we will work with you to meet these emergency needs.

You also have the right to request that we communicate with you about medical matters in certain ways or at certain locations. Again, this request should be in writing and should be specific as to how and where you wish to be contacted. We do not need to know the reasons for your request.

YOUR COMPLAINTS
We are required by law to maintain the privacy of your health information, provide you with this notice of our legal duties and privacy practices, and to abide by the terms of this notice.

If you are concerned that we have violated your privacy rights or our own policies as summarized in this notice, or if you disagree with a decision we made about access to your records, you may contact the person listed at the end of this Notice. You may also send a written complaint to the United States Department of Health & Human Services. The person and office listed below can provide you with the appropriate address upon request. You will not suffer any retaliation for filing a complaint.

OUR RESPONSIBILITIES
We are required by law to protect the privacy of your information and to provide you with this notice about our information practices. We are also required to abide by the terms of this notice and to notify you if we are unable to agree to a requested restriction you have made relative to the use or disclosure of your information. In addition, we are required to accommodate reasonable requests you make regarding the communication of your health information by alternate means or at alternative locations.

If you have any questions regarding this notice, our use or disclosure of your health information, or wish to file a complaint regarding our use or disclosure of your health information, please contact:

Privacy Officer
Spectrum Health Gerber Memorial
212 South Sullivan Street
Fremont, MI 49412
(231) 924-3300

Effective Date of this Notice: April 14, 2003