HIPAA

Effective Date: November 1, 2008

GRAND HEALTH PARTNERS

NOTICE OF HIPAA PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MIDWEST INSTITUTE OF HEALTH, P.C., DOING BUSINESS AS GRAND HEALTH PARTNERS, MAY USE AND DISCLOSE YOUR HEALTH INFORMATION AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.

USING AND DISCLOSING YOUR HEALTH INFORMATION
Whenever you visit a hospital, physician, or other healthcare provider, a record of your visit and the care provided to you during that visit is made. Typically, this record contains information regarding your symptoms, examinations, tests performed (including the results), diagnoses, treatment, and any current and future treatment purposes. In addition, this record is usually used to obtain payment for treatment provided to you, for administrative purposes, and to evaluate the quality of the care provided to you. This notice tells you the ways in which Grand Health Partners may use and disclose your medical information. This notice also describes your rights and certain obligations Grand Health Partners has regarding the use and disclosure of your medical information.

Specifically, Grand Health Partners may use or disclose certain identifiable health information about you for reasons such as:

• Treatment. A means of communication with other health professionals who contribute to or participate in your care while you are a patient, including doctors, nurses, behaviorists, dieticians, and other clinical personnel involved in your care. For example, Grand Health Partners may need to disclose information about your current health status to another doctor treating you for a broken bone or an infection because of the implications.
• Payment. A means by which you or your insurance company can verify services provided to you so that Grand Health Partners may receive payment for those services provided. For example, Grand Health Partners may need to give your health plan information about treatment you received so your insurance company will pay for the care provided.
• Operations. A source of data in Grand Health Partners' daily operations as a health care provider. For example, Grand Health Partners may need to use your health information and record as a tool in educating and assessing the competency of doctors, nurses, and others who provide care. At times, information may be released from your medical record that is not for the purposes of treatment, payment, or operations. You have the right to restrict or prohibit these disclosures. These situations include the following:
• Grand Health Partners may contact you by phone to provide appointment reminders or to offer you information about treatment alternatives or other health related benefits and services that may be of interest to you.
• The release of information for health professional education or research studies that have been approved by Grand Health Partners.

At times, Grand Health Partners is required by law to release your health information. These situations include the following:

• Release of information to public health officials charged with improving the health of our city, state, and nation or responsible for averting a serious threat to health or safety to you, another person, or the public;
• Release of information required by federal, state, or local law or in response to a court order, subpoena, or other discovery request, as permitted or required by law;
• Release of information requested by members of domestic or foreign armed forces to comply with the requirement of domestic or foreign military command authorities;
• Release of information for purposes of national security;
• Release of information to health oversight agencies in connection with legally authorized activities related to the investigation, inspection, and licensure of health care providers; and
• Any other release of information required by law.

In situations not outlined above, Grand Health Partners will ask you for written authorization before using or disclosing any of your identifiable health information. If you choose to sign an authorization, it can later be revoked to stop future use and disclosure without your consent. Such a revocation will not be effective, however, for any actions that Grand Health Partners takes in reliance on your authorization prior to your revocation.

In addition, Grand Health Partners will make reasonable efforts when using, disclosing, or requesting patient health information to limit information to the minimum necessary to accomplish the intended purpose of the use, disclosure, or request. This applies for all situations outlined above.

YOUR HEALTH INFORMATION RIGHTS
Although your health record is the physical property of Grand Health Partners, the information contained within your health record belongs to you. You have certain rights with respect to that information, such as the right to inspect and copy your medical information (with the exception of any psychotherapy notes); the right to request the restriction of certain uses and disclosures of your information; the right to obtain an accounting of disclosures of your health information when such disclosures are made other than for treatment, payment, related administrative or operating purposes as described above, or to you, your personal representative, or to family members or others involved in your medical care; and the right to amend and request changes in the information contained within your health record. These rights are explained in more detail below.

Grand Health Partners may deny your request to amend or change your medical record if:

• The request is not in writing;
• The request does not include a reason to support the request;
• The information was created by another health care provider;
• The information is not part of the health information kept by or for Grand Health Partners;
• The information is not part of the health information you would be permitted to inspect or copy; or
• Your health information is already accurate and complete.

If Grand Health Partners exercises this right to deny your request, you will receive a written explanation of the reasons for the denial. You have the right to complain about this denial as outlined in the"Your Complaints" section of this notice.

Any request for an accounting of disclosures of your information from Grand Health Partners must be in writing at Grand Health Partners' address, can be for a time no longer than six years, and may not include a period before April 14, 2003. The first disclosure list you request within a 12-month period is free. For any additional request, Grand Health Partners may charge you for the cost of providing the list. Grand Health Partners will notify you of that charge in advance and provide you with the opportunity to withdraw or modify your request after such notification.

You may request that Grand Health Partners not use or disclose your medical information except as specifically authorized by you, when required by law, or in emergency circumstances. Grand Health Partners will consider your request, but you should be aware that Grand Health Partners is not legally required to accept it and may, if Grand Health Partners deems your request too restrictive, elect not to treat you or to disregard your request in an emergency. If Grand Health Partners agrees to your request, it will comply with it unless the information is needed to provide you with emergency treatment. To request restrictions, you must make your request in writing at Grand Health Partners' address.

You have the right to inspect and obtain a copy of your health record. Usually, this includes medical and billing records but does not include records such as certain psychotherapy notes.

If you request copies of your health records, the request must be in writing and there will be a charge for such copies. This cost is directly related to the administrative and copying charges associated with your request, as permitted by law. If your request for copies is, in your opinion, an emergency, please let us know and we will work with you to meet these emergency needs.

Grand Health Partners may deny your request to inspect and copy your medical information in certain very limited circumstances. If you are denied access to your medical information, you may request that the denial be reviewed. For information regarding such a review, contact Grand Health Partners' office as stated below.

You also have the right to request that Grand Health Partners communicate with you about medical matters in certain ways (home phone/cell phone) or at certain locations. Again, this request must be in writing and should be specific as to how and where you wish to be contacted. Grand Health Partners does not need to know the reasons for your request. Grand Health Partners will comply with all reasonable requests for us to communicate with you in a certain way.

YOUR COMPLAINTS
Grand Health Partners must provide a process to address any complaints that you have regarding privacy issues. If you are concerned that Grand Health Partners has violated your privacy rights, its own policies as summarized in this notice, or if you disagree with a decision Grand Health Partners has made about access to your records, you may contact the person listed below. You may also send a written complaint to the United States Department of Health & Human Services. The person and office listed below can provide you with the appropriate address upon request. You will not suffer any retaliation for filing a complaint. All complains must be submitted in writing.

Complaints may be filed by contacting Kim McCorriston in writing at 2060 East Paris Avenue, Suite 100, Grand Rapids, Michigan 49546.

RESPONSIBILITIES OF GRAND HEALTH PARTNERS
Grand Health Partners is required by law to protect the privacy of your information and to provide you with this notice about its privacy practices. Grand Health Partners is also required to abide by the terms of this notice and to notify you if it is unable to agree to a requested restriction you have made relative to the use or disclosure of your information. In addition, Grand Health Partners is required to accommodate reasonable requests you make regarding the communication of your health information by alternate means or at alternative locations.

Grand Health Partners may change its policies or practices regarding the use of your health information from time to time as explained in this notice. If Grand Health Partners makes any changes, it will post the new notice in its waiting area and on its website at www.grandhealthpartners.com. You have the right to a written copy of this notice and can always request a copy of the current notice at any time. In particular, you have the right to a paper copy of this notice if you received this notice electronically.

If you have any questions regarding this notice or the use or disclosure of your health information or if you wish to file a complaint regarding Grand Health Partners' use or disclosure of your health information, please contact Kim McCorriston of Grand Health Partners at (616) 956-6100.