NOTICE OF PRIVACY PRACTICES

Effective Date:  August 1, 2006

Please review it carefully.

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. If you have any questions about this notice, please contact the Health Information Management Department at (334) 732-3078 during regular business hours.

Who Will Follow This Notice:

• This notice describes our hospital’s practices and that of:

• The physician members of the hospital’s medical staff and credentialed, non-physician health care professionals who may provide care in the hospital.

• All departments and units of the hospital.

• Any volunteers who perform volunteer work in the hospital.

• All employees, staff and other hospital personnel.

• All entities, sites and locations follow the terms of this notice. In addition, these entities, sites, and locations may share medical information with each other for treatment, payment or hospital operations purposes described in this notice.

Our Pledge Regarding Medical Information:

We understand that medical information about you and your health is personal. We are committed to protecting medical information about you. We create a record of the care and services you receive at the hospital to provide you with quality care and to comply with certain legal requirements. This notice applies to all of the records of your care generated by the hospital, whether made by hospital personnel or your personal doctor. Your personal doctor may have different policies or notices regarding the doctor’s use and disclosure of your medical information created in the doctor’s own office or clinic.

This notice will tell you about the ways in which we may use and disclose medical information about you. We also describe your rights and certain obligations we have regarding the use and disclosure of medical information.

We are required by law to:

• keep private medical information that identifies you;

• give you this notice of our legal duties and privacy practices with respect to medical information about you; and

• follow the terms of the Notice of Privacy Rights currently in effect.

How We May Use and Disclose Medical Information About You:

The following categories describe different ways that we use and disclose medical information. For better understanding, we have provided some examples in each category. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

• For Treatment:  We may use medical information about you to provide you with medical treatment or services. We may disclose medical information about you to doctors, nurses, technicians, medical students, students in other health care fields, or other hospital personnel who are involved in taking care of you at the hospital. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can arrange for appropriate meals. Different departments of the hospital also may share medical information about you in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We may disclose medical information about you to people outside the hospital who may be involved in your medical care after you leave the hospital, such as family members assisting you or other health care providers, such as nursing homes, home health care agencies, or medical equipment providers. We also may use your medical information to contact you to check that you are progressing in your recovery.

• For Payment:  We may use and disclose medical information about you so that the treatment and services you receive at the hospital may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about surgery you received at the hospital so your health plan will pay us or reimburse you for the surgery. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment. We may share your information with other health care providers who treat you during your stay in the hospital, such as an ambulance service or a physician who serves as a consultant during your treatment.

• For Health Care Operations:  We may use and disclose medical information about you for hospital operations. These uses and disclosures are necessary to run the hospital and make sure that all of our patients receive quality care. For example, we may use medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information about many hospital patients to decide what additional services the hospital should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, technicians, medical students, students in other health care fields, and other hospital personnel for review and learning purposes. We may also combine the medical information we have with medical information from other hospitals to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning who the specific patients are.

• Photographs:  We may photograph patients, including newborn babies, for security and identification purposes.

• Patient Satisfaction Surveys:  We may use a limited amount of information about you to conduct patient satisfaction surveys by telephone and written communications.

• Health Awareness Materials:  We may use your demographic information to send general health information to you to create awareness in the community of important health topics.

• Health Fairs / Screenings:  We may use your information to contact you with the results of any screenings that are not available on the day of the health fair/screening. We may keep a copy of your screenings to verify that you received screenings at a health fair.

• Personal Representatives:  If you or a court has authorized another individual to act on your behalf, we will share information regarding your treatment with your personal representative unless we believe that the sharing of information would jeopardize your health or safety.
• Appointment Reminders:  We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at the hospital. This practice includes contacting you by telephone.

• Treatment Alternatives:  We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that may be of interest to you. This includes reviewing your medical information to see if you meet the criteria to be eligible to participate in clinical trials.

• Health-Related Benefits and Services:  We may use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

• Fund Raising Activities:  We may use your demographic information and other limited information to contact you in an effort to raise money for the hospital and its operations. We may disclose information to a foundation related to the hospital so that the foundation may contact you in raising money for the hospital. We only would release contact information, such as your name, address and phone number and the dates you received treatment or services at the hospital. If you do not want the foundation to contact you for fund raising efforts, you must notify the hospital in writing. Correspondence may be sent to 4401 River Chase Drive, Phenix City, Alabama 36867.

• Hospital Directory:  We may include certain limited information about you in the hospital directory while you are a patient at the hospital so your family and friends can visit you in the hospital and generally know how you are doing. This information includes your name, location in the hospital, and your general condition (e.g., good, satisfactory, critical, etc.). The directory information may be released to people who ask for you by name, unless you specifically request that we do not include you in the hospital directory. Additionally, your religious affiliation during registration, if you provide it to us at registration, may be given to a minister of your faith even if they do not ask for you by name. This allows you to receive visits from a clergy of your faith. If you do not provide us with your religious affiliation during registration, your name will not be given to any visiting clergy.

• Individuals Involved in Your Care or Payment for Your Care:  We may release medical information about you to a friend or family member who is involved with your medical care or payment for services, unless you inform us that you object to such disclosure. (However, you may not use such an objection to avoid payment for services by a responsible party.) We may use or disclose information about you to locate and notify your family, personal representative or other person responsible for your care that you are in the hospital and your general condition. In the event of a disaster, we may disclose medical information about you to an entity assisting in a disaster relief effort (such as the Red Cross) so that your family can be notified about your condition, status and location.

In situations where you are not capable of giving consent (because you are not present or due to your incapacity or medical emergency), we may, using our professional judgment, determine that a disclosure to your family member or friend is in your best interest. In that situation, we will disclose only health information relevant to the person’s involvement in your care. For example, we may inform the person who accompanied you to the emergency room that you suffered a heart attack and provide updates on your progress and prognosis. We may also use our professional judgment and experience to make reasonable inferences that it is in your best interest to allow another person to act on your behalf to pick up, for example, filled prescriptions, medical supplies, or X-rays.

• Research:  Under certain circumstances, we may use and disclose medical information about you for records-based research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process, using an Institutional Review Board (IRB). This process evaluates a proposed research project and its use of medical information, trying to balance the research needs with patients’ need for privacy of their medical information. Before we disclose medical information contained in medical records to a researcher, the project will have been approved through this research approval process and the researcher will have submitted a plan to protect the confidentiality of patient information.

• As Required By Law:  We will disclose medical information about you when required to do so by federal, state or local law.

• To Avert a Serious Threat to Health or Safety:  We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.

• Special Situations:

• Organ and Tissue Donation:  If you are an organ donor, we may release medical information to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

• Access by Parents:  Some state laws concerning minors permit or require disclosure of protected health information to parents, guardians, and persons acting in similar legal status. We will act consistently with the law of the state where the treatment is provided and will make disclosures following such laws.

• Military and Veterans:  If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.

• Workers’ Compensation:  We may release medical information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.

• Medical Surveillance of the Workplace:  If you are an employee who is being evaluated at the request of your employer for medical surveillance of the workplace or in relation to a work-related illness or injury, we may share information obtained from such evaluation with your employer.

• Public Health Risks:  We may disclose medical information about you for public health activities. These activities generally include the following:

• to prevent or control disease, injury or disability;

• to report births and deaths;

• to report suspected child or adult abuse or neglect;

• to report reactions to medications or problems with products;

• to notify people of recalls of products they may be using;

• to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition;

• to notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.

• Health Oversight Activities:  We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights and other laws, regulations, and regulatory advice. We may also disclose medical information to lawyers or consultants who are providing services to the hospital or related entity regarding a legal or regulatory matter.

• Lawsuits and Disputes:  If you are involved in a lawsuit or a dispute, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if we receive written assurances that the party seeking your medical information as made efforts to tell you about the request or to obtain an order protecting the information requested. We may use your medical information to defend a legal action against the hospital or other related legal entity.

• Law Enforcement:  We may release medical information if asked to do so by a law enforcement official:

• In response to a court order, subpoena, warrant, summons or similar process;

• To identify or locate a suspect, fugitive, material witness, or missing person;

• About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;

• About a death we believe may be the result of criminal conduct;

• About criminal conduct at the hospital; and

• In emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.

• Coroners, Medical Examiners and Funeral Directors:  We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release medical information about patients of the hospital to funeral directors as necessary to carry out their duties.

• National Security and Intelligence Activities:  We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

• Inmates:  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release medical information about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

Your Rights Regarding Medical Information About You:

• Right to Inspect and Copy:  You have the right to inspect and copy medical information used to make decisions about your care. Usually, this generally includes medical and billing records.

To inspect and copy medical information used to make decisions about you, you must submit your request in writing to the hospital’s Health Information Management Department for medical records or to the hospital’s Business/Billing Office for billing records. You have the right to request a copy of your medical information in paper or electronic format. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request.

We may deny your request to inspect and copy in certain, limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. Another licensed health care professional chosen by the hospital 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:  If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for the hospital.

To request an amendment, your request must be made in writing and submitted to the hospital’s Health Information Management Department, Attention: Privacy Officer. In addition, you must provide a reason that supports your request.

We may deny your request for an amendment if it is not in writing or does not include a reason to support the 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 medical information kept by or for the hospital;

• Is not part of the information which you would be permitted to inspect and copy; or

• Is accurate and complete.

If we deny or partially deny your request for amendment, we will provide the reason(s) in writing within 60 days.

• Right to an Accounting of Disclosures:  You have the right to request an “accounting of disclosures.” This is a list of the disclosures we made of medical information about you for reasons other than treatment, payment or health care operations. For example, an accounting of disclosures would include disclosures that we are required by law to make, such as reporting communicable diseases to the county health department.

To request this accounting of disclosures, you must submit your request in writing to the hospital’s Health Information Management Department, Attention: Privacy Officer. Your request must state a time period, which may not be longer than six years. Your request should indicate in what form you want the list (paper or electronic). The first list you request within a 12 month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

• Right to Request Restrictions:  You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations.

We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment or if disclosure is required by law.

We are required to agree to your request if you pay for treatment, services, supplies and prescriptions “out of pocket” and you request the information not to be communicated to your health plan for payment or health care operations purposes.

To request restrictions, you must make your request in writing to this facility. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply.

• Right to Request Confidential Communications:  You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work. However, you must provide us an address to which we can send all written correspondence, including your bill.

At the time of registration in the hospital, you will be requested to provide one mailing address and one phone number which are acceptable to you for receiving communications from us.

Following your discharge from the hospital, you may request a change to your confidential communications address and phone number by submitting a written request to the Health Information Management Department, Attention: Privacy Officer. We will not ask you the reason for your request. We will accommodate reasonable requests. Your request must specify how or where you wish to be contacted.

• Right to a Paper Copy of This Notice:  You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time.

Paper copies of this notice are available in each facility’s registration area. If you are receiving care from a non-hospital entity, you may request a copy of the Notice from your health care provider.

• Changes to This Notice:

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice in the hospital. The notice will contain on the first page, top center, the effective date.

• Breach of Information:

We will inform you if there is a breach of your unsecured health information.

• Complaints:

If you believe your privacy rights have been violated, you may file a complaint with the hospital or with the US Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Ave, S.W. Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/. To file a privacy complaint with the hospital, contact the Privacy Officer at (334) 732-3078, or submit in writing to 4401 River Chase Drive, Phenix City, Alabama 36867, Attention: Privacy Officer.

You will not be penalized for filing a complaint.

• Other Uses of Medical Information:

Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your authorization, and that we are required to retain our records of the care that we provided to you.

We also will not use or disclose your health information for the following purposes:

• Marketing purposes. This does not including face-to-face communication about products or services that may be of benefit to you and about prescriptions you have already been prescribed.

• Purpose of selling your health information. We may receive payment for sharing your information for, as an example, public health purposes, research, and releases to you or others you authorize a release to as long as payment is reasonable and related to the cost of providing your health information.