PROMEDICA PHYSICIAN GROUP
NOTICE OF PRIVACY PRACTICES

1. THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
   
   The terms of this Notice of Privacy Practices apply to the physicians and staff of ProMedica Physician Group seeing and treating patients at various locations throughout northwest Ohio and southeast Michigan. 
   
   
2. WE HAVE A LEGAL DUTY TO PROTECT YOUR HEALTH INFORMATION
   
   
We are required by law to protect the privacy of your health information. You can request a copy of this notice from the contact person listed in Section VII below at any time.


3. HOW WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION
   
   
1. USE AND DISCLOSURE THAT DOES NOT REQUIRE YOUR AUTHORIZATION
   
   ProMedica Physician Group collects health information from you and stores it in a paper chart and on a computer. The collected information may be used for the following purposes.
   
   
1. For treatment. We may give information about you to physicians, nurses, medical students, and other health care personnel who are involved in your care.
   
   
2. To obtain payment for treatment. We may give portions of your information to our billing department and to your health plan to get paid for the services we provided to you. We may give your information to our business associates, such as billing companies, claims processing companies, law firms, collection agencies, and others that process our health care claims. We may also give your information to another health care provider that has treated you for their payment purposes.
   
   
3. For regular health care operations. We may disclose information about you to operate this business. For example, we may use information about you to look at the quality of health care services that you received or to look at the performance of the professionals who provided health care services to you. We may provide information about you to our accountants, attorneys, consultants, and others in order to make sure we are complying with the laws that affect us. We may also give your information to other health care providers and health plans for their business operations if they have or had a patient relationship with you.
   
   
4. When required by federal, state or local law, judicial or administrative proceedings, or law enforcement. For example, we give out your information when a law requires that we report information to government agencies and law enforcement personnel about victims of abuse, neglect, or domestic violence; when dealing with gunshot and other wounds; either by subpoena or when ordered by the court.
   
   
5. For public health activities. For example, we report information about births, deaths, and various diseases, to government officials in charge of collecting that information, and we give coroners, medical examiners, and funeral directors necessary information relating to a death.
   
   
6. For health oversight activities. For example, we will provide information to assist the government when it conducts an investigation or inspection of a health care provider or organization.
   
   
7. To avoid harm. In order to avoid a serious threat to the health or safety of a person or the public, we may give your information to law enforcement personnel or persons able to prevent or lessen such harm.
   
   
8. For specific government functions. We may give out information on military personnel and veterans in certain situations. We may also give your information for national security purposes, such as protecting the President of the United States or conducting intelligence operations.
   
   
9. For workers' compensation purposes. We may release your information to your employer when we have provided health care to you at the request of your employer to determine workplace-related illness or injury.
   
   
10. Appointments and services. We may contact you to remind you of an appointment or give you a test result. You have the right to request that messages not be left on voice mail or sent to a particular address. We may also contact you to give you information about treatment alternatives, or other health care services and benefits we offer.
    
    
2. YOU HAVE THE OPPORTUNITY TO OBJECT TO THESE DISCLOSURES
   
   
1. Disclosures to family, friends, or others. We may provide your information to a family member, friend, or other person that you indicate is involved in your care or the payment for your health care, unless you object and fill out the appropriate form.
   
   
3. DISCLOSURES THAT REQUIRE AUTHORIZATION
   
   Ohio
   Disclosures related to psychiatric treatment programs, human immunodeficiency virus (HIV) test results or diagnosis of AIDS or an AIDS-related condition, or information about alcohol treatment program, or certain information to the State Long-Term Care Ombudsman, will not be made without your authorization except as required or allowed by law. Before we use or disclose your personal health information for any reason other than those reasons described in Section III.A and III.B, we will need to get your written authorization. If you authorize us to use or disclose your information, you can revoke your authorization by filling out the appropriate form.
   
   Michigan
   Disclosures related to psychiatric programs, acquired immunodeficiency syndrome (AIDS), human immunodeficiency virus (HIV), and alcohol/drug treatment programs will not be made without your consent except as required or allowed by law.
   
   
4. YOUR HEALTH INFORMATION RIGHTS
   
   
1. THE RIGHT TO REQUEST LIMITS ON HOW WE USE AND DISCLOSE YOUR HEALTH INFORMATION
   
   You have the right to ask that we limit how we use and give out your information. We will carefully consider your request, but we are not required to accept it. If we accept your request, we will put it in writing and abide by it except in emergency situations. To request limits, complete the appropriate form at the facility where you are receiving care.
   
   
2. THE RIGHT TO CHOOSE HOW WE SEND YOUR INFORMATION TO YOU
   
   You have the right to ask that we send information to you to an alternate address. For example, you may ask us to send information to your work address rather than your home address. You can also ask that it be sent by alternate means. For example, you can ask that we send information by fax instead of regular mail. We will agree to your request if we can easily provide it in the format you request.
   
   
3. THE RIGHT TO SEE AND GET COPIES OF YOUR HEALTH INFORMATION
   
   Most of the time, you have the right to look at or get copies of your health information that we have. Your request must be on the appropriate form and signed by you or your legally authorized representative. In certain situations, we may deny your request. If we do, we will tell you, in writing, our reasons why and explain how you can have the denial reviewed.
   
   
4. THE RIGHT TO CORRECT OR UPDATE YOUR HEALTH INFORMATION
   
   If you believe that there is a mistake in your information or that a piece of important information is missing, you have the right to request that we correct the existing information or add the missing information. Your request and your reason for the request must be submitted on the appropriate form. Each request will be carefully considered. If we approve your request, we will make the change to your information and tell you that we have done it.
   
   
5. CHANGES TO THE POLICY
   
   If our privacy policy should change at any time in the future, we will promptly change and post the new notice. We reserve the right to apply any changes to our privacy policy or this notice to all of the personal health information that we maintain, including information collected before the date of the change.
   
   
6. COMPLAINTS
   
   If you think that we may have violated your privacy rights, or you disagree with a decision we made about your health information, you may file a complaint with the person listed in Section VII below.
   
   
7. PERSON TO CONTACT FOR INFORMATION ABOUT THIS NOTICE
   
   If you have any questions about this notice or any complaints about our privacy practices, please contact the ProMedica Physician Group Privacy Officer at 5855 Monroe St., Sylvania, Ohio 43560, 419-824-7200, or e-mail ppgprivacy@promedica.org.
   
   
8. EFFECTIVE DATE OF THIS NOTICE
   
   Effective date April 14, 2003.