Patient Privacy

Sodexo Operations, LLC

NOTICE OF HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) PRIVACY PRACTICES

Effective Date: April 14, 2003 Revision Date:

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 respect patient confidentiality and only release personal health information about you in accordance with the State and federal law. This notice describes our policies related to the use of the records of your care generated by Sodexo. We are required by law to keep your medical information private, give you this Notice of our legal duties, our privacy practices and your rights, and to follow the terms of our most current Notice.

Privacy Contact. If you have any questions about this policy or your rights contact:

Susan Ramsey MS RD CDE LDN

Senior Manager, MNT

Sodexo Health Care Services

PO Box 602

Washington Crossing, PA 18977

Office 215-493-4025 fax 215-493-8039

USE AND DISCLOSURE OF PROTECTED HEALTH INFORMATION:

In order to effectively provide you care, there are times when we may need to share your personal health information with others beyond Sodexo. This includes for:

Treatment. We may use or disclose personal health information about you to provide, coordinate, or manage your care or any related services, including sharing information with others outside Sodexo that we are consulting with or referring you to.

Payment. Information may be used or disclosed to obtain payment for the treatment and services provided. This will include contacting your health insurance company for prior approval of planned treatment or for billing purposes.

Healthcare Operations. We may use information about you to coordinate our business activities. This may include setting up your appointments, reviewing your care, training staff, evaluating and improving the quality of care we provide, or evaluating what additional types of services we should offer. We may also use health information for business planning or disclose it to attorneys, accountants, consultants and others in order to make sure we are complying with the law. We may remove information that identifies you so that others may use the de-identified information to study health care and the health care delivery without learning who you are.

Information Disclosed Without Your Consent.

Under State and federal law, information about you may be disclosed without your consent in the following circumstances:

Emergencies. Sufficient information may be shared to address the immediate emergency you are facing.

Follow Up Appointments/Care. We will be contacting you to remind you of future appointments or information about treatment alternatives or other health-related benefits and services that may be of interest to you.

As Required by Law. This would include situations where we have a subpoena, court order, or are mandated to provide public health information, such as communicable diseases or suspected abuse and neglect such as child abuse, elder abuse, or institutional abuse.

Governmental Requirements. We may disclose information to a health oversight agency for activities authorized by law, such as audits, investigations inspections and licensure. There also might be a need to share information with the Food and Drug Administration related to adverse events or product defects. We are also required to share information, if requested with the Department of Health and Human Services to determine our compliance with federal laws related to health care.

Criminal Activity or Danger to Others. If a crime is committed on our premises, against our personnel or we if we become aware of or reasonably suspect that a crime has occurred we may share information with law enforcement agencies. We also have the right to involve law enforcement and to warn any potential victims when we believe an immediate danger may exist to someone, or if we believe you present a danger to yourself.

PATIENT RIGHTS:

You have the following rights under State and federal law:

Copy of Record. You are entitled to inspect the personal health record Sodexo has generated about you. We may charge you a reasonable fee for copying and mailing your record.

Release of Records. You may consent in writing to release of your records to others, for any purpose you choose. This could include your attorney, employer, or others who you wish to have knowledge of your care. You may revoke this consent at any time, but only to the extent no action has been taken in reliance on your prior authorization.

Restriction on Record. You may ask us not to use or disclose part of the personal health information. This request must be in writing. Sodexo is not required to agree to your request if we believe it is in your best interest to permit use and disclosure of the information. The request should be given to the Program Director who will consult with the staff involved in your care to determine if the request can be granted.

Contacting You. You may request that we send information to another address or by alternative means. We will honor such request as long as it is reasonable and we are assured it is correct. We have a right to verify that the payment information you are providing is correct. Due to agency policy, we are not able to provide information by email.

Amending Record. If you believe that something in your record is incorrect or incomplete, you may request we amend it. To do this contact the Program Director and ask for the Request to Amend Health Information form. In certain cases, we may deny your request. If we deny your request for an amendment you have a right to file a statement you disagree with us. We will then file our response and your statement and our response will be added to your record.

Accounting for Disclosures. You may request a listing of any disclosures we have made related to your personal health information, except for information we used for treatment, payment, or health care operations purposes or that we shared with you or your family, or information that you gave us specific consent to release. It also excludes information we were required to release. To receive information regarding disclosure made for a specific time period no longer than six years and after April 14, 2003, please submit your request in writing to our Privacy Officer. We will notify you of the cost involved in preparing this list.

Questions and Complaints. If you have any questions, or wish to have a copy of or further information regarding this Policy or have any complaints you may contact us in writing at our office listed above. You also may complain to the Secretary of Health and Human Services if you believe Sodexo has violated your privacy rights. We will not retaliate against you for filing a complaint.

Changes in Policy. Sodexo reserves the right to change its Privacy Policy based on the needs of Sodexo and changes in state and federal law.

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