AVANTI HEALTH SYSTEMS
JOINT NOTICE OF PRIVACY PRACTICES

Date Effective: September 1, 2013

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.

Avanti Health Systems ("AHS") and each of the following AHS affiliates, together, designate themselves as a single Affiliated Covered Entity ("ACE") for purposes of compliance with the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"): Villa Marina Health and Rehabilitation Center, Inc., Middle River Health and Rehabilitation Center, Inc., Villa Maria Health and Rehabilitation Center, LLC, Avanti Health and Rehabilitation Center, LLC, Sky View Nursing Center, LLC, Bay Area Health LLC, d/b/a Bay Area Home Health Services & Avanti Home Care, Home Medical Products and Services, LLC, and Beacon Ambulance Service, Inc. Each of these entities, sites, locations, and care providers will follow the terms of this Joint Notice. In addition, these entities, sites, locations and care providers may share medical information with each other for treatment, payment or health care operations related to the ACE.

AHS also participates in an Organized Health Care Arrangement ("OHCA") with other covered entities. This Joint Notice is jointly used by and jointly describes the practices of all participants within the OHCA, including, without limitation:

• Any health care professional authorized to enter information into your chart.
• All departments or units of AHS.
• Any member of a volunteer group we allow to help you while you are a resident of, or being treated at, an AHS facility.
• All employees, staff, or other AHS personnel.

Each of the above individuals or entities participating in the OHCA will follow the terms of this Joint Notice. In addition, these individuals or entities may share medical information with each other for treatment, payment or health care operations related to the OHCA.

A list of ACE and OHCA participants using this Joint Notice is available upon request. Provision of the Joint Notice to an individual by any one of the ACE or OHCA participants will satisfy requirements with respect to all other ACE or OHCA participants covered by the Joint Notice.

AHS is required by law to maintain the privacy of your health information, to provide to you (or your representative) this Joint Notice of our duties and privacy practices, and to notify you (or your representative) following a breach of your unsecured health information. AHS is required to abide by the terms of this Joint Notice as may be amended from time to time. AHS may change the terms of our Joint Notice. Any revisions to this Joint Notice will be effective for all health information that AHS created or maintained in the past, and for any records that AHS may create or maintain in the future. AHS will post a copy of our current Joint Notice in a prominent location in our facility, as well as on our website, www.avantihs.com.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND THE PURPOSES FOR WHICH AHS MAY USE OR DISCLOSE YOUR HEALTH INFORMATION.

To Provide Treatment. AHS may use your health information to treat you. For example, your attending physician or members of the AHS interdisciplinary team may use information about your symptoms in order to prescribe appropriate medications. AHS may also disclose your health information to individuals outside of AHS involved in your care, including family members, pharmacies, suppliers of medical equipment or other health care professionals.

To Obtain Payment. AHS may use or disclose your health information in order to bill or collect payment for services or items you receive from AHS. For example, AHS may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or AHS. AHS may also need to obtain prior approval from your insurer and may need to explain to your insurer your need for health care and the services that will be provided to you.

To Conduct Health Care Operations. AHS may use or disclose your health information for our own operations and as necessary to provide quality care to all of AHS’s residents and patients. For example, AHS may use your health information to evaluate our staff performance, combine your health information with other AHS residents or patients to evaluate how to more effectively serve all AHS residents, disclose your health information to AHS staff and contracted personnel for training purposes, or use your health information to contact you or your family as part of general information mailings.

For a Facility Directory. If you are receiving care at an AHS facility, unless you request otherwise, AHS may disclose certain information about you (e.g., your name and room number) that is contained in our facility directory to anyone who asks for you by name.

For Fundraising Activities. In support of our charitable mission, AHS may use certain information about you (e.g., demographic information, dates of health care provided, department of service information, treating physician, outcome information and health insurance status) to contact you or your family to raise money for AHS. You may choose to "opt-out" of receiving these fundraising communications by notifying the AHS Privacy Officer that you do not wish to be contacted at (715) 561-3200.

For Appointment Reminders. AHS may use or disclose your health information to contact you to remind you that you have an appointment.

To Inform You About Health Information That May Be of Interest to You. AHS may use or disclose your health information to tell you about or recommend possible options or alternatives for your care, or to inform you of other information that may be of interest to you.

Release of Information to Family/Friends. Unless you specifically request in writing that AHS not communicate with such person(s), AHS may release your health information to a family member or friend who is involved in your treatment or who is helping to pay for your care.

Business Associates. AHS may disclose your health information to our business associates that perform functions on our behalf or provide us with services if the information is necessary for them to provide such functions or services. AHS requires our business associates to agree in writing to protect the privacy of your health information and to use and disclose your health information only as specified in that written agreement.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND THE PURPOSES FOR WHICH AHS MAY USE OR DISCLOSE YOUR HEALTH INFORMATION WITHOUT YOUR WRITTEN CONSENT OF AUTHORIZATION.

When Legally Required. AHS will disclose your health information to the extent that we are required to do so by any federal, state, or local law.

When There are Risks to Public Health. AHS may disclose your health information for the following public activities and purposes:

• To prevent or control disease, injury, or disability, to report disease, injury, or vital events such as death, and to conduct public health surveillance investigations.
• To report adverse events, product defects, to tract products or enable product recalls, repairs and replacements and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
• To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
• To an employer about an individual who is a member of the workforce as legally required.

To Report Abuse, Neglect or Domestic Violence. AHS is allowed to notify government authorities if AHS reasonably believes a resident is the victim of abuse, neglect or domestic violence. AHS will make this disclosure only when specifically required or authorized by law or when you authorize such disclosure.

To Conduct Health Oversight Activities. AHS may disclose your health information to a health oversight agency or other organization for activities including: audits; civil, administrative or criminal investigations; inspections; licensure; or disciplinary action. If you are the subject of a health oversight agency investigation, AHS may disclose your health information only if it is directly related to your receipt of health care of public benefits.

In Connection with Judicial and Administrative Proceedings. As permitted or required by state law, AHS may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order. Under certain conditions, AHS may also disclose your health information in response to a subpoena, discovery request or other lawful process.

For Law Enforcement Purposes. As permitted or required by state law, AHS may disclose your health information to a law enforcement official for certain law enforcement purposes, including, under certain limited circumstances, if you are a victim of a crime or in order to report a crime.

To Coroners and Medical Examiners. AHS may disclose your health information to coroners and medical examiners for purposes of determining your cause of death or for other duties, as authorized by law.

To Funeral Directors. If necessary to carry out their duties, AHS may disclose your health information to funeral directors consistent with applicable law and, if necessary, to carry out their duties with respect to your funeral arrangements prior to, and in reasonable anticipation of, your death.

For Organ, Eye or Tissue Donation. AHS may use or disclose your health information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue for the purpose of facilitating the donation and transplantation.

For Research Purposes. AHS may, under very select circumstances, use your health information for research. Before AHS discloses any of your health information for such research purposes, the project will be subject to an extensive approval process.

In the Event of a Serious Threat to Health or Safety. AHS may, consistent with applicable law and ethical standards of conduct, disclose your health information if AHS, in good faith, believes that such a disclosure is necessary to prevent or lessen a serious and imminent threat to your health and safety or to the health and safety of the public.

For Specified Government Functions. In certain circumstances, the federal regulations authorize AHS to use or disclose your health information to facilitate specific government functions relating to the military or veterans, national security, intelligence activities, protective services for the President and others, medical suitability determinations, and law enforcement custody.

For Worker’s Compensation. AHS may release your health information for worker’s compensation or similar programs.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION.

Other than what is stated above, AHS will not use or disclose your health information other than with your written authorization (or the authorization of your representative). Your authorization (or the authorization of your representative) is specifically required before AHS: (i) uses or discloses your psychotherapy notes; (ii) uses your health information to make a marketing communication to you for which it received financial remuneration from a third party, unless such communication is face-to-face or in other limited circumstances; or (iii) discloses your health information in any manner that constitutes the sale of such information under HIPAA. Also, some types of health information are particularly sensitive and the law, with limited exceptions, may require that AHS obtain your authorization to use or disclose that information. Sensitive information may include information dealing with genetics, HIV/AIDS, mental health, developmental disabilities, and alcohol and substance abuse. If required by law, AHS will ask that you (or your representative) sign an authorization before we use or disclose such information. If you (or your representative) authorize AHS to use or disclose your health information, you (or your representative) may revoke that authorization in writing at any time, except to the extent that it has already been acted upon.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION.

You have the following rights regarding your health information that AHS maintains.

Right to Receive Confidential Communications. You (or your representative) have the right to request that AHS communicate with you about your health and related issues in a certain way. Such requests shall specify the requested method of contact or the location where you wish to be contacted. For instance, you may ask that AHS contact you on a cellular phone rather than your home phone. All requests for confidential communications must be made in writing using the appropriate AHS form. The form can be requested by contacting the AHS Privacy Officer at (715) 561-3200, or the Administrator or Social Worker. AHS will accommodate reasonable requests. You (or your representative) do not need to give a reason for your request.

Right to Request Restrictions. You (or your representative) may request restrictions on certain uses and disclosures of your health information. You (or your representative) have the right to request a limit on AHS’s disclosure of your health information to someone who is involved in your care or in the payment of your care. All requests for restrictions must be made in writing using the appropriate AHS form. The form can be requested by contacting the AHS Privacy Officer at (715) 561-3200, or the Administrator or Social Worker. AHS is not required to agree to your request; however, if we do agree, we are bound by that agreement except when otherwise required by law or in emergencies. AHS must agree to a restriction request if: (i) the disclosure is to a health plan for purposes of carrying out payment or health care operations (and not for purposes of carrying out treatment); and (ii) the health information pertains solely to a health care item or service for which AHS has been paid out-of-pocket in full by you or someone else on your behalf (not the health plan). If you self-pay and request a restriction, it will apply only to those health records created on the date that you received the item or service for which you, or another person (other than the health plan) on your behalf, paid in full, and which document the item or service provided on such date.

Right to Inspect and Copy your Health Information. You (or your representative) have the right to inspect and copy your health information, including billing records. All requests to inspect and copy records containing your health information must be made in writing using the appropriate AHS form. The form can be requested by contacting the AHS Privacy Officer at (715) 561-3200, or the Administrator or Social Worker. If you (or your representative) request a copy of your health information, AHS will provide you (or your representative) with a copy of your health information in the format you request unless we cannot practicably do so. AHS may charge a reasonable fee for the copying and assembling costs associated with your request. AHS may deny your request to inspect and/or copy your health information in certain limited circumstances. If AHS denies your request, you (or your representative) may request that we provide you with a review of our denial. Reviews will be conducted by a licensed health care professional who we have designated as a reviewing official and who did not participate in the original decision to deny the request.

Right to Amend your Health Information. If you (or your representative) believe that your health information is incorrect or incomplete, you (or your representative) have the right to request that AHS amend your records. That request may be made as long as AHS still maintains your records and it must include a reason for the amendment. All requests for amendment of records must be made in writing using the appropriate AHS form. The form can be requested by contacting the AHS Privacy Officer at (715) 561-3200, or the Administrator or Social Worker. AHS may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if the requested amendment pertains to health information that was not created by AHS, if the records you are requesting to amend are not part of AHS’s records, if the health information you wish to amend is not part of the health information you (or your representative) are permitted to inspect or copy, or if, in the opinion of AHS, the records containing your health information are accurate and complete.

Right to an Accounting. You (or your representative) have the right to request an accounting of disclosures of your health information made by AHS for any reason other than for treatment, payment or health operations. All requests for an accounting must be made in writing using the appropriate AHS form. The form can be requested by contacting the AHS Privacy Officer at (715) 561-3200, or the Administrator or Social Worker. The request should specify the time period for the accounting, which may not exceed six years. AHS will provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.

Right to a Paper Copy of This Joint Notice. You (or your representative) have a right to a separate paper copy of this Joint Notice at any time, even if you (or your representative) have received this Joint Notice previously (either in paper or electronic format). To obtain a separate paper copy, please contact the AHS Privacy Officer at 715-561-3200. A copy of the current version of our Joint Notice may also be obtained on our website, www.avantihs.com.

Right to Breach Notification. You (or your representative) have a right to be notified of any breach of your unsecured health information. Notification of a breach may be delayed or not provided if so required by a law enforcement official. If you are deceased and there is a breach of your health information, the notice will be provided to your next of kin or personal representative if AHS knows the identity and address of such individual.

CONTACT PERSON FOR QUESTIONS AND COMPLAINTS

Contact Person. AHS has designated Joseph Simonich as its contact person for all issues regarding resident privacy and your rights under federal privacy standards. If you have any questions regarding this Joint Notice or feel that your privacy rights as stated in this Joint Notice have been violated, please contact Joseph Simonich at (906) 362-5715.

Complaints. AHS encourages you to express any concern you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint. You (or your representative) have the right to express concerns or complaints to AHS or to the Secretary of Health and Human Services if you (or your representative) believe that your privacy rights have been violated. Please direct any concerns or complaints to Joseph Simonich at (906) 362-5715 or the AHS Privacy Officer, 300 Villa Drive, Hurley, Wisconsin 54534.