Reviewed and Approved by Legal Advisors

SACRAMENTO EAR, NOSE AND THROAT SURGICAL AND MEDICAL GROUP, INC.

NOTICE OF PRIVACY PRACTICES

Health Insurance Portability and Accountability Act of 1996 (HIPAA)

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.

Purpose of this Notice

In the course of doing business, Sacramento Ear, Nose & Throat Surgical and Medical Group, Inc., (“Sacramento Ear, Nose & Throat”) gathers and retains personal information about our patients. Sacramento Ear, Nose & Throat respects the privacy of your personal information and understands the importance of keeping this information confidential and secure. This Notice describes how Sacramento Ear, Nose & Throat protects the confidentiality of your personal information that we receive. Sacramento Ear, Nose & Throat has implemented policies and procedures in accordance with Federal and State confidentiality and privacy laws to protect your privacy. Sacramento Ear, Nose & Throat is obligated to maintain the privacy and confidentiality of your personal information. Sacramento Ear, Nose & Throat is also obligated to provide you with notice of its legal obligations about privacy of your personal information and to provide you notice of its policies and procedures about privacy and confidentiality. These policies and procedures apply to past, present, and future Sacramento Ear, Nose & Throat patients and past, present, and future information

What is “Personal Information?”

“Personal information” is information that identifies who you are and relates to your past, present, or future physical or mental health or condition, the provision of health care to you, or past, present, or future payment for the provision of health care to you. Personal information does not include information about you that is publicly available, or that is available or reported in summary form, but does not identify who you are.

Types of Uses and Disclosures of Personal Information Made by Sacramento Ear, Nose and Throat

Federal law allows Sacramento Ear, Nose and Throat to use and disclose your personal information in order to provide health care services to you as well as to bill and collect payments for the health care services provided to you by our physicians. Federal law also allows Sacramento Ear, Nose and Throat to use and disclose your personal information as necessary in connection with the health care operations of Sacramento Ear, Nose and Throat. For example, Sacramento Ear, Nose and Throat may use your personal information to authorize referrals to specialists and to review the quality of care provided by your physician. Sacramento Ear, Nose and Throat may disclose your personal information to health plans or other responsible parties to receive payment for the services provided by your physician. Sacramento Ear, Nose and Throat might also use your personal information in connection with any grievance or appeal that you file if you are unhappy with the care you have received. Certain governmental agencies may also request access to your personal information in order to monitor the activities of certain physicians or providers, or even to monitor your health plan or insurance company. Sacramento Ear, Nose and Throat may use your personal information in connection with disease management programs. Sacramento Ear, Nose and Throat may disclose your personal information in connection with court orders or subpoenas.

While Federal law allows Sacramento Ear, Nose and Throat and health care providers to use and disclose your personal information for treatment, payment, and health care operations, the law requires these providers to obtain your written consent to do so. Therefore, the first time you see a Sacramento Ear, Nose and Throat physician once the federal rules take effect, the physician will ask you to sign a consent form allowing the physician to use and disclose your personal information in connection with your treatment, the payment for your treatment, and the physician’s health care operations.

Sacramento Ear, Nose and Throat is also allowed by law to use and disclose your personal information without your consent or authorization for the following purposes:

When required by law;
For public health activities, such as reports about communicable diseases or work-related health issues;
In reports about child abuse, domestic violence, or neglect;
For health oversight activities, such as reports to governmental agencies that are responsible for licensing physicians or other health care providers;
In connection with court proceedings or proceedings before administrative agencies;
For law enforcement purposes, such as responding to a court order or subpoena;
In reports to coroners, medical examiners, or funeral directors;
For tissue or organ donation;
For research, with the approval of certain oversight entities; otherwise, use and disclosure of your personal information requires for research requires your authorization;
To avert a serious threat to the health or safety of a person or of the public;
For national security and intelligence activities, including the protection of the President;
In connection with services provided under worker’s compensation laws; and
For limited marketing purposes when related to your treatment.
Sacramento Ear, Nose and Throat may disclose your personal information to your family members who are involved in your care without either your consent or your authorization. However, you must be provided with an opportunity to object prior to the disclosure.

All other uses and disclosures of your personal information will be made by Sacramento Ear, Nose and Throat only with your written authorization.

How We Protect Personal Information

Sacramento Ear, Nose and Throat restricts access to your personal information to those employees who need access in order to provide services to our patients. We have established and maintain appropriate physical, electronic, and procedural safeguards to protect your personal information against unauthorized use or disclosure. We have established a training program that Sacramento Ear, Nose and Throat employees must complete and update annually. We have also established a Privacy Office, which has overall responsibility for developing, training, and overseeing the implementation and enforcement of policies and procedures to safeguard your personal information against inappropriate access, use and disclosure consistent with the applicable state and federal law.

Authorization

If an authorization is needed, Sacramento Ear, Nose and Throat will provide you with an authorization form for you or your personal representative to complete. When you receive the form, please fill it out and send it to the following address:

Sacramento Ear, Nose and Throat Surgical and Medical Group, Inc.
3810 J Street
Sacramento, CA 95816
Attn: Medical Records Department

Your Individual Rights

Access to Personal Information
As a matter of federal and state law, you have the right to review and copy your personal information received and retained by Sacramento Ear, Nose and Throat. If you desire to access your personal information, you must notify Sacramento Ear, Nose and Throat in writing. We will respond to your request and provide a time and place, within normal business operating hours, for your inspection of the personal information Sacramento Ear, Nose and Throat has in its possession. If you request a copy of the information held by Sacramento Ear, Nose and Throat, a copy can be provided. We reserve the right to charge a reasonable administrative fee for copying your personal information, as allowed by applicable law.

Right to Amend Personal Information
State and federal law allows you the right to amend your personal information held by Sacramento Ear, Nose and Throat. A request to amend your personal information must be submitted to Sacramento Ear, Nose and Throat in writing, and the amendment must be no longer than 250 words in length. Sacramento Ear, Nose and Throat will attach your amendment to the record(s) of your personal information. Your amended personal information will be made available for your review upon request.

Right to Receive an Accounting of Disclosures
State and federal law provide you the right to request an accounting of all disclosures of your personal information made by Sacramento Ear, Nose and Throat that are not directly related to your treatment, payment for your treatment, or Sacramento Ear, Nose and Throat’s health care operations as outlined above. You may request an accounting in writing. Sacramento Ear, Nose and Throat will provide this accounting to you within a reasonable period of time after your request and in accordance with the polices and procedures established by Sacramento Ear, Nose and Throat.

Right to Receive this Notice
You have the right to request and receive a copy of this Notice in written or electronic form. You may contact Sacramento Ear, Nose and Throat for a copy, and one will be provided to you at no charge.

Right to Request Restriction on Disclosure of Personal Information
State and federal law permits you to request restrictions on the use and disclosure of your personal information by Sacramento Ear, Nose and Throat. Sacramento Ear, Nose and Throat reserves the right to accept or reject your request for restriction. All requests must be made in writing. Upon receipt, Sacramento Ear, Nose and Throat will review the request and notify you of its decision to either accept or reject the request. Even is Sacramento Ear, Nose and Throat agrees to honor your request to restrict Sacramento Ear, Nose and Throat’s uses and disclosures of your personal information, Sacramento Ear, Nose and Throat may cease to honor that restriction without your consent, upon notice to you. In that event, Sacramento Ear, Nose and throat will continue to honor the request for a restriction in connection with all personal information which Sacramento Ear, Nose and Throat physicians received or created prior to termination of the restriction. However, Sacramento Ear, Nose and Throat will not be obligated to honor the restriction after it provides you notice that it will cease to do so. If you agree to terminate, then Sacramento Ear, Nose and Throat may use and disclose all of your personal information in its possession in accordance with applicable law. All requests for restrictions for restrictions which are agreed to by Sacramento Ear, Nose and Throat will be made part of your personal information and made available for your review upon proper request.

Right to Confidential Communications
You have the right to request that Sacramento Ear, Nose and Throat provide your personal information to you in a confidential manner. For example, you may request that Sacramento Ear, Nose and Throat send your personal information by alternate means or to an alternate address, such as by telephone to a different telephone number or to an office address rather than your home address. Also, you may, for example, request that your personal information be sent in a sealed envelope rather than on a postcard.

Right to Complain
Sacramento Ear, Nose and Throat is obligated to comply with the privacy practices set forth in this Notice. If you believe that Sacramento Ear, Nose and Throat has violated this privacy policy, you have the right to file a complaint with Sacramento Ear, Nose and Throat Surgical and Medical Group, Inc., your Health Plan, and the California Department of Managed Care or the United States Department of Health and Human Services, Office of Civil Rights.

Contacting Sacramento Ear, Nose and Throat Surgical and Medical Group, Inc. Regarding Your Rights If you should have any questions regarding your rights or wish to make any of the above requests or complaints, you should direct your inquiries to:

Sacramento Ear, Nose and Throat Surgical and Medical Group, Inc.
1111 Exposition Blvd, Bldg. 700
Sacramento, CA 95815
(916) 736-3399

Rights Reserved by Sacramento Ear, Nose and Throat Surgical and Medical Group, Inc. Sacramento Ear, Nose and Throat Surgical and Medical Group, Inc. reserves all of the rights expressed above. Sacramento Ear, Nose and Throat further reserves the right to amend or change the terms of this Notice at any time and to make the provisions of the new Notice effective for all personal information we maintain. You may request updates to this Notice, and such updates can also be found on our website at www.sacent.com.

Effective Date
The effective date of this Notice is April 14, 2003.