NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW HEALTH INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.  THE PRIVACY OF YOUR HEALTH INFORMATION IS IMPORTANT TO US.               

Our Legal Duty

We are required by applicable federal and state law to maintain the privacy of your health information.  We are also required to give you this Notice about our privacy practices, our legal duties, and your rights concerning your health information.  We must follow the privacy practices that are described in this Notice while it is in effect.  This Notice takes effect February 12, 2003, and will remain in effect until we replace it.

We reserve the right to change our privacy practices and the terms of this Notice at any time, provided such changes are permitted by applicable law.  We reserve the right to make changes in our privacy practices and the new terms of our Notice effective for all health information that we maintain, including health information we created or received before we made the changes.  Before we make a significant change in our privacy policy practices, we will change this Notice and make the new Notice available upon request.

You may request a copy of our Notice at any time.  For information about our privacy practices, or for additional copies of this Notice, please contact us using the information at the end of this Notice.

Uses and Disclosures of Health Information

We make all reasonable efforts not to use or disclose more than the minimum amount of healthcare information necessary to accomplish the intended purpose of the use or disclosure.  We use and disclose health information about you for treatment, payment, and healthcare operations.  For example:

Treatment:  We may use or disclose your health information to a physician, case manager/therapist, or other healthcare provider providing treatment to you.

Payment:  We may use and disclose your health information to obtain payment for services we provide to you.

Healthcare Operations:  We may use and disclose your health information in connection with our healthcare operations.  Healthcare operations include quality assessment and improvement activities, reviewing the competence or qualifications of healthcare professionals, evaluating practitioner and provider performance, conducting training programs, accreditation, certification, licensing, or credentialing activities.

Your Consent:  In addition to our use of your health information for treatment, payment or healthcare operations, you may give us written consent to use your health information or to disclose it to anyone for any purpose.  If you give us consent, you may revoke it in writing at any time.  Your revocation will not affect any use or disclosures permitted by your consent while it was in effect.  Unless you give us a written consent, we cannot use or disclose your health information for any reason except those described in this Notice.

Person Involved in Care:  We may use or disclose health information to notify, or assist in the notification of (including identifying or locating) a family member, your personal representative or another person responsible for your care, of your location, your general condition, or death.  If you are present, then prior to use or disclosure of your health information, we will provide you with an opportunity to object to such uses or disclosures.  In the event of your incapacity or emergency circumstances, we will disclose health information based on a determination using our professional judgment disclosing only health information that is directly relevant to the person's involvement in your healthcare.  We will also use our professional judgment and our experience with common practice to make reasonable inferences of your best interest in allowing a person to pick up filled prescriptions, medical supplies, x-rays, or other similar forms of health information.

To Your Family and Friends:  We may disclose your health information to a family member, friend, or other person to the extent necessary to assist with your healthcare program or with payment for your healthcare.      

Appointment Reminders:  We may use or disclose your health information to provide you with appointment reminders (such as voicemail messages, postcards, or letters).

Out Reach and Post Service Follow Up:  We may use or disclose your health information to provide you with outreach or post service follow-up care (such as voicemail messages, postcards, or letters).

Fund Raising:  We may use your health information for fund-raising purposes without your written consent.

Marketing Health-Related Services:  We will not use your health information for marketing communications without your written consent.

Required by Law:  We may use or disclose your health information when we are required to do so by law.

Abuse or Neglect:  We may disclose your health information to appropriate authorities if we reasonably believe that you are a possible victim of abuse, neglect, or domestic violence or the possible victim of other crimes.  We may disclose your health information to the extent necessary to avert a serious threat to your health or safety or the health or safety of others.

National Security:  We may disclose to military authorities the health information of Armed Forces personnel under certain circumstances.  We may disclose to authorize federal officials health information required for lawful intelligence, counterintelligence, and other national security activities.  We may disclose to correctional institution or law enforcement official having lawful custody of protected health information of inmate or patient under certain circumstances.

Patient Rights

Access:  You have the right to look at or get copies of your health information, with limited exceptions.  You may request that we provide copies in a format other than photocopies.  We will use the format you request, unless we cannot practicably do so.  (You must make a request in writing to obtain access to your health information.  You may obtain a form to request access by using the contact information listed at the end of this Notice.  We will charge you a reasonable cost-based fee for expenses such as copies and postage.  You may request access by sending us a letter to the address at the end of this Notice.  If you request copies, we will charge you $0.50 for each page, and postage if you want the copies mailed to you.  If you request an alternative format, we will charge a cost-based fee for providing your health information in that format.  If you prefer, we will prepare a summary or an explanation of your health information for a fee.  Contact us using the information listed at the end of this Notice for a full explanation of our fee structure.)

Disclosure Accounting:  You have a right to receive a list of instances in which we or our business associates disclosed your health information for purposes, other than treatment, payment, healthcare operations and certain other activities, for the last 6 years, but not before April 14, 2003.  If you request this accounting more than once in a 12-month period, we may charge you a reasonable, cost-based fee for responding to these additional requests.

Restriction:  You have the right to request that we place additional restrictions on our use or disclosure of your health information.  We are not required to agree to these additional restrictions, but if we do, we will abide by our agreement (except in emergency).

Alternative Communication:  You have the right to request that we communicate with you about your health information by alternative means or to alternative locations.  (You must make your request in writing.)  Your request must specify the alternative means or location, and provide satisfactory explanation how payments will be handled under the alternative means or location you request.

Amendment:  You have the right to request that we append your health information.  (Your request must be in writing and it must explain why the information should be appended.)  We may deny your request under certain circumstances.

Electronic Notice:  If you receive this Notice on our Web site or by electronic mail (e-mail), you are entitled to receive this Notice in written form.

Questions and Complaints

If you want more information about our privacy practices or have questions or concerns, please contact our Corporate Compliance Designee at (248) 338-7458 or by fax at (248) 338-7513.  Our mailing address is 70 Lafayette, Pontiac, MI 48342.

You may also contact us through our Compliance Hotline:  (248) 253-0534.

If you are concerned that we may have violated your privacy rights, or you disagree with a decision we made about access to your health information or in response to a request you made to append or restrict the use or disclosure of your health information or to have us communicate with you by alternative means or at alternative locations, you may complain to us using the contact information listed above.  You also may submit a written complaint to the U.S. Department of Health and Human Services.  We will provide you with the address to file your complaint with the U.S. Department of Health and Human Services upon request.

We support your right to the privacy of your health information.  We will not retaliate in any way if you choose to file a complaint with us or with the U.S. Department of Health and Human Services.

Revised 12-10-04; 04-28-06