Notice of Privacy Practices

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.

Your health information is personal, and we are committed to protecting it. Your health information is also very important to our ability to provide you with quality care, and to comply with certain laws. This Notice applies to all records about your care that we provide. (Your physician may have a different policy and a different notice regarding your health information that is created in the physician's office.)

When this Notice refers to "we" or "us," it is referring to Covenant Retirement Communities and its facility, Covenant Village of Colorado.

1. We Are Legally Required to Safeguard Your Protected Health Information.

   We are required by law to:

   1. Maintain the privacy of your health information, also known as "Protected health information" or "PHI;"
   2. Provide you with this Notice, and
   3. Comply with this Notice.

2. Future Changes to Our Practices and This Notice.

   We reserve the right to change our privacy practices and to make any such change applicable to the PHI we obtained about you before the change. If a change in our practices is material, we will revise this Notice to reflect the change. You may obtain a copy of any revised Notice by contacting the administrative representative at the Facility or our Privacy Officer at the Covenant Retirement Communities Central Office. We will also make any revised Notice available in our main lobbies.

3. How We May Use and Disclose Your Protected Health Information.

   The law requires us to obtain your prior consent for most uses and disclosures of your PHI. In other circumstances, the law allows us to use or disclose PHI without your consent or authorization. This Section III gives examples of these circumstances. However, note that for some types of PHI, there may be stricter restrictions on our uses or disclosures described below. For example, drug and alcohol abuse patient treatment information, HIV test results, mental health information, and genetic testing results may be subject to more stringent disclosure requirements and we may not disclose such records without your consent.

   1. Uses and Disclosures That Do Not Require Your Consent. We may use or disclose your PHI in order for a physician to provide treatment to you. For example, we may disclose your PHI to physicians who are involved in your care.

      We may also use or disclose your PHI pursuant to a law or regulation for claims processing in order to get paid for treatment provided to you. For example, we may use your PHI to create the bills that we submit to the insurance company, Medicare, Medicaid or another third party payor. We may also disclose your PHI pursuant to an appropriate order of the court.

      We may also use or disclose your PHI pursuant to law or regulation for medical audit and quality assurance purposes. For example, we may use your PHI to evaluate the quality of care you received from us, or to evaluate the performance of those involved with your care.

   2. Uses and Disclosures That Require Us To Obtain Your Consent. With your consent, we may also make the following uses and disclosures of your PHI:

      1. We may disclose your PHI to nurses, and other health care personnel who are involved your care. We may also use and disclose your PHI to tell you about or recommend possible treatment options or alternatives, or about health-related benefits or services that may interest you. We may disclose PHI to individuals who will be involved in your care after you leave the facility.
      2. We may disclose your PHI to another health care provider or insurance company for their payment-related activities, such as to get paid for treatment provided to you or to process claims under your health insurance plan.
      3. We may also use or disclose your PHI for our operations related to health care. For example, we may provide your PHI to our attorneys, accountants and other consultants to make sure we are complying with the laws that affect us. We may also provide your contact information (such as name, address and phone number) and the dates you received services from us to a foundation that helps us with our fundraising efforts. In addition, we may also disclose your PHI to another health care provider, health insurance plan or health care clearinghouse for purposes of their operations related to health care. However, we will only do so if they have or have had a relationship with you and if the PHI they request pertains to that relationship. In addition, we will disclose your PHI to these third parties for limited purposes only, such as for them to conduct quality improvement activities, or to review the performance of health care provider, or for training purposes.
      4. Unless you object, we may include your name, location in our facility and general condition in the facility directory that we use when responding to requests by those who ask for you by name. If you do not object, we also disclose information from the directory and your religious affiliation to clergy who visit the facility. We may also provide relevant portions of your PHI to a family member, friend or other person you indicate is involved in your health care or in helping you get payment for your health care. We may use or disclose your PHI to notify your family or personal representative of your location or condition. In an emergency or when you are not capable of agreeing or objecting to these disclosures, we will disclose PHI as we determine is in your best interest, but will tell you about it later, after the emergency and give you the opportunity to object to future disclosures to family and friends. Unless you object, we may also disclose your PHI to persons performing disaster relief activities.

   3. Other Uses and Disclosures That Require Us to Obtain Your Consent. With your consent, we will disclose PHI in the following circumstances:

      1. When Required by Law. We disclose PHI when we are required to do so by federal, state or local law.
      2. For Public Health Activities. For example, we disclose PHI when we report the occurrence of certain diseases, or adverse reactions to a drug or medical device.
      3. For Reports About Victims of Abuse, Neglect or Domestic Violence. We will disclose your PHI in these reports only if we are required or authorized by law to do so, or if you otherwise agree.
      4. To Health Oversight Agencies. We will provide PHI as requested to government agencies who have authority to audit or investigate our operations.
      5. For Judicial or Administrative Proceedings. We may disclose your PHI in response to an administrative order. We may disclose your PHI in response to a subpoena, discovery request, or other lawful request, but only if efforts have been made to tell you about the request or to obtain a court order that will protect the PHI requested.
      6. To Law Enforcement. We may release PHI to a law enforcement official, as required by law.
      7. To Coroners, Medical Examiners and Funeral Directors. We may disclose PHI to facilitate the duties of these individuals.
      8. To Organ Procurement Organizations. We may disclose PHI to facilitate organ donation and transplantation.
      9. For Medical Research. We may disclose your PHI to medical researchers who request it for approved medical research projects; however, with very limited exceptions such disclosures must be cleared through a special approval process before any PHI is disclosed to the researchers, who will be required to safeguard the PHI they receive.
      10. To Avert a Serious Threat to Health or Safety. We may disclose your PHI to someone who can help prevent a serious threat to your health and safety or the health and safety of another person or the public.
      11. For Specialized Government Functions. For example, we may disclose your PHI to authorized federal officials for intelligence and national security activities that are authorized by law, or so that they may provide protective services to the President or foreign heads of state or conduct special investigations authorized by law.
      12. To Workers' Compensation or Similar Programs. We may use or disclose your PHI to comply with laws relating to worker's compensation or similar programs.

4. Other Uses and Disclosures of Your Protected Health Information.

   Other uses and disclosures of your PHI that are not covered by this Notice or the laws that apply to us will be made only with your written authorization. If you give us written authorization for a use or disclosure of your PHI, you may revoke that authorization, in writing, at any time. If you revoke your authorization we will no longer use or disclose your PHI for the purposes specified in the written authorization, except that we are unable to take back any disclosures we have already made with your permission. In addition, we can use or disclose your PHI after you have revoked your authorization for actions we have already taken in reliance on your authorization.

5. Your Rights Related to Your Protected Health Information.

   You have the following rights:

   1. The Right to Request Limits on Uses and Disclosures of Your PHI. You have the right to ask us to limit how we use and disclose your PHI, with certain exceptions. For residents in our skilled nursing facility, we are required to agree to your requested restrictions unless you are being transferred to another health care institution, the release of records is required by law, or the release of information is needed to provide you emergency treatment.

   2. The Right to Choose How We Communicate With You. You have the right to ask that we send information to you at a specific address (for example, at work rather than at home) or in a specific manner (for example, by e-mail rather than by regular mail, or never by telephone). We must agree to your request as long as it would not be disruptive to our operations to do so. You must make any such request in writing, addressed to the administrative representative.

   3. The Right to See and Copy Your PHI. You have the right to request, either orally or in writing, to inspect or obtain a copy of your records containing PHI, including medical or billing records or other written information that may be used to make decisions about your care. For residents of our skilled nursing facility, we must allow you to inspect such records within 24 hours of your request and if you request copies of those records, we must provide you with copies within 2 days of that request.

   4. If you are a discharged patient and ask us to copy your PHI, we will charge you $14 for the first ten or fewer pages, $0.50 per page for pages 11-40, and $0.33 per page for every additional page.

   5. The Right to Correct or Update Your PHI. If you believe that the PHI we have about you is incomplete or incorrect, you may ask us to amend it. Any such request must be made in writing and must be addressed to the administrative representative, and must tell us why you think the amendment is appropriate. We will not process your request if it is not in writing or does not tell us why you think the amendment is appropriate. We will inform you in writing as to whether the amendment will be made or denied. If we agree to make the amendment, we will ask you who else you would like us to notify of the amendment.

      We may deny your request if you ask us to amend information that:

      1. Was not created by us, unless the person who created the information is no longer available to make the amendment;
      2. Is not part of the PHI we keep about you;
      3. Is not part of the PHI that you would be allowed to see or copy; or
      4. Is determined by us to be accurate and complete.

      If we deny the requested amendment, we will tell you in writing how to submit a statement of disagreement or complaint, or to request inclusion of your original amendment request in your PHI.

   6. The Right to Get a List of the Disclosures We Have Made. You have the right to get a list of instances in which we have disclosed your PHI. The list will not include certain disclosures, such as disclosures we have made for our treatment, payment and health care operations purposes, those that are a byproduct of another use or disclosure permitted under our privacy policies or by law, those made under an authorization provided by you, those made directly to you or your family or friends or through our facility directory, or for disaster relief purposes. Neither will the list include disclosures we have made for national security or intelligence purposes or disclosures made before April 14, 2003.

      Your request for a list of disclosures must be made in writing and be addressed to the administrative representative. We will respond to your request within 60 days (or 90 days if the extra time is needed). The list we provide will include disclosures made within the last six years unless you specify a shorter period. The first list you request within a 12-month period will be free. You will be charged our costs for providing any additional lists within the 12-month period.

   7. The Right to Get a Paper Copy of This Notice. Even if you have agreed to receive the Notice by e-mail, you have the right to request a paper copy as well. You may obtain a paper copy of this Notice by contacting the administrative representative at the Facility or our Privacy Office at the Covenant Retirement Communities Central Offices. The Notice is also available in our main lobbies.

6. Complaints.

   If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the federal Department of Health and Human Services. To file a complaint with us, put your complaint in writing and address it to our Privacy Officer at P.O. Box 59233, Chicago, IL 60659. We will not retaliate against you for filing a complaint. You may also contact our Privacy Officer if you have questions or comments about our privacy practices.