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.

Effective Date: March, 2009

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 our facilities. We need this record to provide you with quality care and to comply with certain legal requirements.

This notice will tell you about the ways in which we may use or disclose medical information about you. We also describe your rights and certain obligations we have regarding the use or disclosure of medical information. Franciscan Health System, including St. Joseph Medical Center, St. Francis Hospital, St. Clare Hospital, Enumclaw Regional Hospital, St. Anthony Hospital, Franciscan Medical Group, and our medical staff members, follow the terms of this notice.

This notice applies to the medical information generated by our facilities, whether made by facility personnel or your personal physician while at one of our facilities.

We are required by law to:

• make sure that medical information that identifies you is kept private;
• give you this notice of our legal duties andprivacy practices with respect to medical information about you; and
• follow the terms of the notice that is currently in effect.

HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU

The following categories describe different ways that we use or disclose medical information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use or disclose information will fall within one of the categories.

For Treatment. We will 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, or other health care providers who are involved in taking care of you. 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 organization 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 also disclose medical information about you to people outside the facility who may be involved in your health care, such as other physicians involved in your care, family members, significant others or other health care related entities such as specialty hospitals, skilled nursing care facilities and other healthcare services.

For Payment. We will use or disclose medical information about you so that the treatment and services you receive at Franciscan Health System 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 insurance company or surgeon information about surgery you received at the hospital so your health insurance company will pay us or reimburse you for the surgery. We may also tell your health insurance company about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment. We may disclose your medical information to other healthcare providers so that they can bill for health care services that they provided to you, such as ambulance services. We may also give information to other third parties who are responsible for payment for your health care.

For Health Care Operations. We may use or disclose medical information about you for routine facility operations, including quality review of the services provided, internal auditing, accreditation, certification, licensing or credentialing activities of the facility, medical research and education for facility staff and students, and patient satisfaction surveys. We may disclose your medical information to other healthcare providers that also have a relationship with you and need the medical information for operational purposes. These uses and disclosures are necessary to run our facilities 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.

Facility Directory. We may include certain limited information about you in the facility directory while you are a patient in one of our facilities. This information may include your name, location in the facility and your general condition (e.g., fair, stable, etc.). The directory information may only be released to people who ask for you by name. This is so your family and friends can visit you in the hospital, or so that flowers sent to you by family and friends can be delivered. You have the right to "opt out" and not have your name published in our facility directory. This right however, cannot be protected if you elect to notify others of your presence in our facility. To "opt out," please see the Privacy Notice Acknowledgement.

Health-Related Benefits and Services. We may use and disclose medical information to tell you about health-related benefits or services. We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at a Franciscan Health System facility. We may use and disclose medical information to tell you about or recommend possible health treatment options or alternatives.

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 to funeral directors as necessary to carry out their duties.

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.

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.

Special Protections. Certain federal and state laws that provide special protections for certain kinds of medical information call for specific authorizations from you to use or disclose that information. When your medical information falls under these special protections, we will contact you to secure the required authorizations to comply with federal and state laws.

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

Lawsuits and Disputes. If you are involved in a lawsuit or dispute, we may disclose information about you in response to a court or administrative order or other lawful process.

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 as governed by the Federal Register. We may also release medical information about foreign military personnel to the appropriate foreign military authority.

To Avert a Serious Threat to Health or Safety. We may use or 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. We may also release your medical information to federal officials for National Security activities and for protection of the President and National Heads of State. Any disclosure, however, would only be to someone able to help prevent the threat.

Public Health Risks. We may disclose medical information about you for public health activities such as to prevent or control disease, injury or disability; report births and deaths; report reactions to medications or problems with medical products.

Disaster Relief Efforts. We may disclose your medical information to an organization assisting in a disaster relief effort so that your family can be notified about your condition and location.

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 laws.

Law Enforcement. We may release medical information to a law enforcement official as permitted or required by federal, state or local law. An example of this would be reporting suspected child abuse.

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 for the institution to provide you with health care; to protect your health and safety or the health and safety of others; or for the safety and security of the correctional institution.

Fundraising Activities. We may use medical information about you to contact you in an effort to raise funds for Franciscan Health System. We may disclose medical information to a foundation related to the organization so that the foundation may contact you in raising funds for Franciscan Health System. We would only release contact information, such as your name, address and phone number and the dates you received treatment or services at our facilities.

Business Associates. We may share medical information with companies that work with us. All companies that act on our behalf are contractually obligated to keep the information we provide to them confidential, and to use the medical information we share only to provide the services we ask them to perform for you and us.

Research. Under certain circumstances, we may use and disclose medical information about you for 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. This process evaluates a proposed research project and its use of medical information, balancing research needs with patient needs for privacy of their medical information.

YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU

    You have the following rights regarding medical information we maintain about you:

Right to Inspect and Copy. You have the right to inspect and obtain a copy of medical records and billing information that may be used to make decisions about your care and payment for care. To inspect or obtain a copy of the medical information that may be used to make decisions about you, please see the Privacy Notice Acknowledgement. If you request a copy of the information, we may charge a reasonable fee for costs of copying, mailing or other supplies associated with your request.

We may deny your request to inspect and obtain a copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. You may choose another licensed health care professional to review your request and the denial. 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 organization. To request an amendment, please see the Privacy Notice Acknowledgement. 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 organization;
• Is not part of the information which you would be permitted to inspect and copy; or
• Is accurate and complete.

Right to an Accounting of Disclosures. You have the right to receive a list of instances where we have disclosed information for reasons other than treatment, payment or operations or with your authorization. To request this list or accounting of disclosures, please see the Privacy Notice Acknowledgement. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a 12-month period will be free. For additional lists, we may charge you for the cost 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. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.

Although we will consider your requests, you should be aware that, under the law, we do not have to agree to change the privacy practices that we have described in this Notice. Further, it is not our normal practice to agree to such changes. If we do agree, we will comply with your request unless you are in need of emergency treatment and the restricted medical information is needed to provide the emergency treatment. If the information is disclosed for emergency treatment, we will request that the health care provider not further use or disclose information.

To request restrictions, please see the Privacy Notice Acknowledgement. In your written request, you must tell us what information you want to limit; whether you want to limit our use, disclosure or both; and to whom you want the limits to apply. If we decide to agree to a restriction that you want, we will provide you with a letter describing the special procedures that we will apply to your information.

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 an alternative location from your home address, such as work, or only contact you by mail instead of by phone. We might also communicate with you via e-mail with your expressed written consent.

To request confidential communications, please see the Privacy Notice Acknowledgement. Your request must specify how or where you wish to be contacted. We will not ask you the reason for your request. We will accommodate all reasonable requests. We reserve the right to reverse this accommodation if our efforts to reach you at your alternate address for payment purposes fail. In addition, be sure and contact other entities such as physicians who are treating you, as well as your insurance company, if you wish any communications from them to be sent to an alternate address.

Right to a Paper Copy of This Notice. You may ask us to give you a paper copy of this notice at any time. You may also obtain a copy of this notice at our website, www.FHShealth.org.

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 our facilities and on the Franciscan Health System web site. The notice will include the effective date.

COMPLAINTS / GRIEVANCES

If you believe your privacy rights have been violated, you may file a complaint with our administrative office or with the United States Secretary of Department of Health and Human Services. To file a complaint with our facility, please see the Privacy Notice Acknowledgement. You will not be penalized for filing a complaint.

OTHER USES OF MEDICAL INFORMATION

Other uses or disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose medical information about you, you may revoke that permission in writing, at any time. Upon receipt of your written revocation, 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 permission, and that we are required to retain our records of the care that we provided to you.