NOTICE OF PRIVACY PRACTICES
Effective Date: April 14, 2003

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.

We understand the importance of privacy and are committed to maintaining the confidentiality of your medical information. We make a record of the medical care we provide and may receive such records from others. We use these records to provide or enable other health care providers to provide quality medical care, to obtain payment for services provided to you and to enable us to meet our professional and legal obligations to operate this medical practice properly. We are required by law to maintain the privacy of protected health information and to provide individuals with notice of our legal duties and privacy practices with respect to protected health information. This notice describes how we may use and disclose your medical information. It also describes your rights and our legal obligations with respect to your medical information. If you have any questions about this Notice, please contact our Privacy Officer listed above.

Changes to this notice: We reserve the right to amend this Notice of Privacy Practices at any time in the future. Until such amendment is made, we are required by law to comply with this Notice. After an amendment is made, the revised Notice of Privacy Protections will apply to all protected health information that we maintain, regardless of when it was created or received. We will keep a copy of the current notice posted in our reception area, and copies will be available at the reception desk. We will also post the current notice on our website.

How We May Use or Disclose Your Health Information
We collect health information about you and store it in a chart and on a computer. This is your medical record. The medical record is the property of this medical practice, but the information in the medical record belongs to you. The following categories describe different ways that we use your health information within our office and disclose your health information to persons and entities outside of our office. We have not listed every use or disclosure within the categories below, but all permitted uses and disclosures will fall within one of the following categories. In addition, there are some uses and disclosures that require your specific authorization. The law permits us to use or disclose your health information for the following purposes:

Treatment: We use medical information about you to provide your medical care. We disclose medical information to our employees and others who are involved in providing the care you need. For example, we may share your medical information with other physicians or other health care providers who will provide services which we do not provide. Or we may share this information with a pharmacist who needs it to dispense a prescription to you, or a laboratory that performs a test. We may also disclose medical information to members of your family or others who can help you when you are sick or injured.

Payment: We use and disclose medical information about you to obtain payment for the services we provide. For example, we give your health plan the information it requires before it will pay us. We may also disclose information to other health care providers to assist them in obtaining payment for services they have provided to you.

Health Care Operations: We may use and disclose medical information about you to operate this medical practice. For example, we may use and disclose this information to review and improve the quality of care we provide; to obtain authorization from your health plan; for medical reviews, legal services and audits; for compliance programs and business planning and management. We may also share your medical information with our "business associates", such as our billing service, that perform administrative services for us. We have a written contract with each of these business associates that contains terms requiring them to protect the confidentiality of your medical information. Although federal law does not protect health information which is disclosed to someone other than another healthcare provider, health plan or healthcare clearinghouse, under California law all recipients of health care information are prohibited from re-disclosing it except as specifically required or permitted by law. We may also share your information with other health care providers, health care clearinghouses or health plans that have a relationship with you, when they request this information to help them with their quality assessment and improvement activities, their efforts to improve health or reduce health care costs, their review of competence, qualifications and performance of health care professionals, their training programs, their accreditation, certification or licensing activities, or their health care fraud and abuse detection and compliance efforts. We may also share medical information about you to all the other health care providers who participate in Scripps Health’s Organized Health Care Arrangement for any health care operations activities of Scripps Health.

Appointment Reminders: We may use and disclose medical information to contact and remind you about appointments. If you are not home, we may leave this information on your answering machine or in a message left with the person answering the phone.

Sign in sheet: We may use and disclose medical information about you by having you sign in when you arrive at our office. We may also call out your name when we are ready to see you.

Marketing: We may contact you to give you information about products or services related to your treatment, case management or care coordination, or to direct or recommend other treatments or health-related benefits and services that may be of interest to you, or to provide you with small gifts. We may also encourage you to purchase a product or service when we see you. We will not use or disclose your medical information without your written authorization.

Special Situations That Do Not Require Your Authorization
State or federal law permits the following disclosures of your health information without verbal or written permission from you.

Required by law: We will use and disclose your health information as required by law, but we will limit our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse, neglect or domestic violence, or respond to judicial or administrative proceedings, or to law enforcement officials, we will further comply with the requirements set forth below concerning those activities.

Public health: We may disclose health information about you for public health activities such as: preventing or controlling disease, injury or disability; reporting child, elder or dependent adult abuse or neglect; reporting domestic violence; reporting to the FDA problems with products and reactions to medications; and reporting disease or infection exposure, as permitted by law. When we report suspected elder or dependent adult abuse or domestic violence, we will inform you or your personal representative promptly unless in our best professional judgment, we believe the notification would place you at risk of serious harm or would require informing a personal representative we believe is responsible for the abuse or harm.

Health oversight activities: We may disclose health information to a health oversight agency for activities authorized by law. These activities include audits, investigations, inspections, licensure and other proceedings, subject to the limitations imposed by federal and California law.

Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose health information about you in response to a court or administrative order. We may also disclose information about you in response to a subpoena, discovery request or other lawful process by someone else involved in the dispute.

Law enforcement: We may disclose your health information to a law enforcement official for purposes such as identifying or locating a suspect, fugitive, material witness or missing person, complying with a court order, warrant, grand jury subpoena and other law enforcement purposes.

Coroners: We may disclose your health information to coroners in connection with their investigations of deaths.

Public safety: We may disclose your health information to appropriate persons in order to prevent or lessen a serious and imminent threat to the health or safety of a particular person or the general public.

Specialized government functions: We may disclose your health information for military or national security purposes or to correctional institutions or law enforcement officers that have you in their lawful custody.

Worker’s compensation: We may release health information about you for worker’s compensation or similar programs if you have a work-related injury. These programs provide benefits to you for your work-related injuries.

Change of Ownership: In the event that this practice is sold or merged with another organization, your health information will become the property of the new owner, although you will maintain the right to request that copies of your health information be transferred to another physician or medical group.

Research: We may disclose your health information to researchers conducting research with respect to which your written authorization is not required as approved by an Institutional Review Board or privacy board, in compliance with governing law, or when preparing research protocols when data is not removed from our office.

Situations Requiring Your Verbal Agreement
Individuals Involved in Your Care or Payment for Your Care: We may disclose health information about you to a family member or friend who is involved in your medical care, unless you tell us in advance not to do so. In addition, we may disclose health information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, location or in the event of your death. If you are unable or unavailable to agree or object, our health professionals will use their best judgment in communication with your family and others.

Situations Requiring Your Written Authorization
Except as described in this Notice of Privacy Practices, our office will not use or disclose health information which identifies you without your written authorization. If you authorize us to use or disclose health information about you, you may revoke that authorization in writing at any time. Please understand that we cannot take back any disclosures that have already been made pursuant to your original authorization. Listed below are some typical disclosures that require your authorization.

Special Categories of Treatment Information: In most cases, federal or state law requires your written authorization or the written authorization of your representative for each disclosure of drug and alcohol abuse treatment, HIV and AIDS test results and mental health treatment.

Disability and Return to Work/School Forms: Your written authorization is required for us to complete and submit your application for Disability Benefits, FMLA leave paperwork and Return to Work or School release forms sent to your school or employer.

Marketing: Except as previously noted, most marketing activities require your written authorization. This office does not use or sell your information to third parties for marketing purposes. We may however, ask you to participate in marketing activities to promote our practice. Should we do so, your authorization is required.

Research: When a research study involves your treatment, or in certain circumstances records research, we may disclose your health information to researchers only after you have signed a specific written authorization. In addition, an Institutional Review Board (IRB) will already have reviewed the research proposal, established appropriate protocols to ensure the privacy of your health information and approved the research. You do not have to sign the authorization, but if you refuse you cannot be part of the research study and may be denied research-related treatment.

Your Health Information Rights
You have a right to a paper copy of this Notice of Privacy Practices, even if you have previously requested its receipt by e-mail or on our website.

Right To Request Special Privacy Protections: You have the right to request restrictions on certain uses and disclosures of your health information, by a written request specifying what information you want to limit and what limitations on our use or disclosure of that information you wish to have imposed. We reserve the right to accept or reject your request, and will notify you of our decision.

Right To Request Confidential Communications: You have the right to request that we communicate with you about medical matters in a specific way or at a specific location. For example, you may ask that we only contact you at work or by mail. We will comply with all reasonable requests submitted in writing which specify how or where you wish to receive these communications.

Right to Inspect and Copy: You have the right to inspect and copy your health information, with limited exceptions. To access your medical information, you must submit a written request detailing what information you want access to and whether you want to inspect it or get a copy of it. We will charge a reasonable fee, as allowed by California law. We may deny your request under limited circumstances. If we deny your request to access your child's records because we believe allowing access would be reasonably likely to cause substantial harm to your child, you will have a right to appeal our decision. If we deny your request to access your psychotherapy notes, you will have the right to have them transferred to another mental health professional.

Right to Amend or Supplement: You have a right to request that we amend your health information that you believe is incorrect or incomplete. You must make a request to amend in writing, and include the reasons you believe the information is inaccurate or incomplete. We are not required to change your health information, and will provide you with information about our denial and how you can disagree with the denial. We may deny your request if we do not have the information, if we did not create the information (unless the person or entity that created the information is no longer available to make the amendment), if you would not be permitted to inspect or copy the information at issue, or if the information is accurate and complete as is. You also have the right to request that we add to your record a statement of up to 250 words concerning any statement or item you believe to be incomplete or incorrect.

Right to an Accounting of Disclosures: You have a right to receive an accounting of disclosures of your health information made by this medical practice, except that we do not have to account for the disclosures provided to you or pursuant to your written authorization, or as described above in paragraphs related to treatment, payment, health care operations, notification and communication with family and specialized government functions or disclosures for purposes of research or public health which exclude direct patient identifiers, or which are incident to a use or disclosure otherwise permitted or authorized by law, or the disclosures to a health oversight agency or law enforcement official to the extent this medical practice has received notice from that agency or official that providing this accounting would be reasonably likely to impede their activities.

Right To Complain about any aspect of our privacy practices to us or to the United States Department of Health and Human Services. Complaints about this notice or how we handle your health information should be directed to our Privacy Officer listed at the top of this notice. There will be no retaliation against you if you file a complaint with us. If you are not satisfied with the manner in which this office handles your complaint, you may submit a formal complaint to the Secretary of the United States Department of Health and Human Services, Office of Civil Rights, Hubert H. Humphrey Bldg Room 509F, 200 Independence Avenue, S.W., Washington, DC 20201.

If you have any questions about this notice or would like to have a more detailed explanation of these rights or if you would like to exercise one or more of these rights, contact our Privacy Officer listed at the top of this Notice of Privacy Practices.