NOTICE OF PRIVACY PRACTICES

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1 Creative Community Living Services, Inc. HIPAAf4100 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. In this document, we and us and our refers to Creative Community Living Services, Inc. and shall include (when appropriate) all wholly owned subsidiaries including Creative Living Environments LLC, Creative Nursing & Consulting LLC and Creative Home Health LLC. We are required by federal law to protect the privacy of your individual health information (referred to in this notice as Protected Health Information ). We are also required to provide you with this notice regarding our legal duties and privacy practices with respect to your protected health information, and to abide by the terms of this notice, as it may be updated from time to time. We may receive and maintain Protected Health Information about you during the course of providing services to you. We may also hire business associates to help provide these benefits to you. These business associates may also receive and maintain Protected Health Information about you in the course of assisting us. THE EFFECTIVE DATE OF THIS NOTICE IS January 1, We are required to follow the terms of this notice until it is replaced. We reserve the right to change the terms of this notice at any time. If we make changes to this notice, we will revise it and send a new notice to all clients at that time. We reserve the right to make the new changes apply to all Protected Health Information about you maintained by us before and after the effective date of the new notice. Purposes for which We May Use or Disclose Medical Information About You Without Your Consent or Authorization We may use and disclose Protected Health Information about you for the following purposes: Health Care Providers Treatment Purposes. We may use or disclose your Protected Health Information to facilitate or assist with treatment or services rendered by us or health care providers on your behalf. For example, we may disclose Protected Health Information about you to your doctor, at the doctor s request, for your treatment. Payment. We may use or disclose your Protected Health Information to determine eligibility for health and/or dental benefits, to facilitate payment for the treatment or services you receive from various providers, to determine benefit responsibility under your health benefit plan or to coordinate your plan s coverage. For example, we may use or disclose Protected Health Information about you in order for an insurer to pay claims for covered health care services or to provide eligibility information to your doctor when you receive treatment. Health Care Operations. We may use and disclose your Protected Health Information for other of our operations that may be necessary to maintain or operate our organization. For example, we may use or disclose Protected Health Information about you for quality assessment and improvement activities, evaluating the competence or qualifications of our staff, legal services, audit services, fraud and abuse detection and compliance programs, business planning and development, and administrative activities to advance the mission of our organization.

2 Health Services. We may use and disclose your Protected Health Information in order to promote or improve health care services for your benefit. For example, we may use Protected Health Information about you to contact you to give you information about treatment alternatives or other health-related benefits and services that may be of interest to you. As Required By Law. We will use and disclose your Protected Health Information when required by federal, state or local law. For example, we must allow the U.S. Department of Health and Human Services to audit our records. We may also disclose Protected Health Information about you as authorized by and to the extent necessary to comply with workers compensation or other similar laws. To Business Associates. We may disclose Protected Health Information about you to third parties (called business associates) that we hire for assistance. Each of our Business Associates must agree in writing to ensure the continuing confidentiality and security of Protected Health Information about you in conformance with the Health Insurance and Portability Accountability Act of 1996 ( HIPAA ). We may also use and disclose Protected Health Information as follows: To avert a serious threat to your health or safety or the health or safety of others. To comply with legal proceedings, such as a court or administrative order, subpoena, warrant, summons or request under certain circumstances. To law enforcement officials for certain law enforcement purposes: o to identify or locate a suspect, fugitive, material witness or missing person, provided that the Protected Health Information is limited in nature; o in response to a request about an individual who is or is suspected to be a victim of a crime if we are unable to obtain the individual s agreement under certain circumstances; and o in the event we believe that a crime occurred on our premises. To public health authorities or other appropriate government authorities for public health purposes or activities. To a government authority if we reasonably believe an individual is a victim of abuse, neglect or domestic violence. To a governmental agency authorized to oversee the health care system or government programs. To a coroner, medical examiner, or funeral director about a deceased person. To your personal representatives appointed by you or designated by applicable law. For research purposes, as long as certain privacy-related standards are satisfied in conformance with HIPAA. To an organ procurement organization in limited circumstances. For specialized government functions (e.g., military and veterans activities, national security and intelligence, federal protective services, medical suitability determinations, correctional institutions and other law enforcement custodial situations). We may disclose to one of your family members, to a relative, to a close personal friend, or to any other person identified by you, Protected Health Information that is directly relevant to the person s involvement with your care or payment related to your care. In addition, we may use or disclose the Protected Health Information to notify a member of your family, your personal representative, another person responsible for your care, or certain disaster relief agencies of your location, general condition, or death. If you are incapacitated, there is an emergency, or you otherwise do not have the opportunity to agree to or object to this use or disclosure, we will do what in our judgment is in your

3 best interest regarding such disclosure and will disclose only the information that is directly relevant to the person s involvement with your health care. Authorizations: Uses and Disclosures with Your Permission We will not use or disclose Protected Health Information about you for any other purposes unless you give us your written authorization to do so. If you give us written authorization to use or disclose Protected Health Information about you for a purpose that is not described in this notice, then, in most cases, you may revoke it in writing at any time. Your revocation will be effective for all Protected Health Information about you that we maintain, except for information we have already released based on your authorization. Your Rights You may make a written request to us to do one or more of the following concerning Protected Health Information about you that we maintain: To put additional restrictions on our use and disclosure of Protected Health Information about you. We do not have to agree to your request except in certain limited circumstances (see New Rights Effective February 17, 2010, below). To receive communications from us by alternative means or at a location different from what we are currently using. We do not have to agree to your request unless such alternative means are reasonable. Your request must be in writing and must specify the alternative means or location. To see and get copies of Protected Health Information about you. In limited cases, we do not have to agree to your request. In particular, we may not comply with your request if the information was not created by us (unless the creator of the information is no longer available to make the requested amendment), not available to you for inspection or copying or if is already accurate and complete. To amend Protected Health Information about you that is retained in a designated record set. In some cases, we do not have to agree to your request for amendment. To receive a list of disclosures of Protected Health Information about you that we and our Business Associates made for certain purposes for the last 6 years (but not for disclosures before January 1, 2013). Please note, however, that certain disclosures may not be included in such an accounting, such as disclosures made for treatment, payment or health care operation purposes or disclosures that are incidental. To send you a paper copy of this notice if you received this notice by or on the Internet. In some cases, we may charge you a nominal, cost-based fee to carry out your request. New Rights Effective February 17, 2010 You have the right to opt-out of receiving any communications from us or our affiliates regarding fundraising for our activities relating to improving the quality of health care or improving community health. If you choose to opt-out of receiving such communications, we ask that you fill out our Fundraising Opt-Out Form and give or send the form to:

4 Creative Community Living Services, Inc. Attn: Privacy Official We will keep your request on file. You may choose to change your decision at any time. You have the right to access certain health information from your Electronic Health Record, to the extent that we maintain such a record. You also have a right to receive a copy of that information in an electronic format and to tell us to send a copy of that information directly to a person or organization that you designate. However, this information will not include psychotherapy notes, information related to a legal proceeding and information related to the Clinical Laboratory Improvements Amendments of If you wish to access and receive a copy of your health information from your Electronic Health Record, you must provide us with clear and specific directions on our Electronic Health Record Request Form. We may impose a fee to cover our labor costs in responding to your request for electronic copies of your health information. You have the right to request a restriction on disclosing your health information to a health plan or insurer when you pay for a health care item or service out-of-pocket in full, provided there are no other legal requirements for such disclosure. We must abide by this request. If you wish to request such a restriction, please fill out our Restriction on Disclosures Form and give or send it to: Creative Community Living Services, Inc. Attn: Privacy Official If you want to exercise any of these rights described in this notice, please contact the Privacy Official at the location indicated below. We will give you the necessary information and forms for you to complete and return to us. Complaints If you believe your privacy rights have been violated, you may file a complaint in writing by contacting the Privacy Official at the location indicated below under Contacting Us or to the Secretary of the Department of Health and Human Services. We will not retaliate against you for filing a complaint. Contacting Us To request additional copies of this notice or to receive more information about our privacy practices or your rights, please contact our Privacy Official at: Creative Community Living Services, Inc. Attn: Privacy Official Conclusion Use and disclosure of Protected Health Information by us is regulated, in part, by a federal law known as HIPAA. You may find these rules at 45 Code of Federal Regulations Parts 160 and 164. This Notice attempts to summarize the Privacy Standards. The Privacy Standards will supersede any discrepancy between the information in this Notice and the Privacy Standards.

5 The following affiliates and subsidiaries also adhere to CCLS, Inc. s privacy policies and procedures: Creative Nursing & Consulting, LLC Creative Living Environments, LLC Creative Home Health, LLC New: 2/19/13

6 Creative Community Living Services, Inc. 314 E. Main Street HIPAAf4101 AMENDMENT TO NOTICE OF PRIVACY PRACTICES On February 17, 2009, President Obama signed into law additional health information privacy and security protections. This document amends CCLS, Inc.'s Notice of Privacy Practices by adding new rights to the Notice. The rights listed in the Notice are still in effect. This amendment merely adds to them. Unless specified otherwise below, these new rights take effect on February 17, Please contact the CCLS, Inc. Privacy Official if you have any questions or concerns about these new rights. NEW RIGHT WITH REGARD TO FUNDRAISING COMMUNICATIONS 1 You have the right to opt-out of receiving any communications from CCLS, Inc. or its affiliates regarding fundraising for CCLS, Inc.'s activities relating to improving the quality of health care or improving community health. If you choose to opt-out of receiving such communications, we ask that you fill out the Fundraising Opt-Out form and give or send the form to the CCLS, Inc. Privacy Official. We will keep your request on file. You may choose to change your decision at any time. RIGHT OF ACCESS TO ELECTRONIC HEALTH RECORD 2 You have the right to access certain health information from your Electronic Health Record, to the extent that CCLS, Inc. maintains such a record. You also have a right to receive a copy of that information in an electronic format and to tell us to send a copy of that information directly to a person or organization that you designate. However, this information will not include psychotherapy notes, information related to a legal proceeding and information related to the Clinical Laboratory Improvements Amendments of If you wish to access and receive a copy of your health information from your Electronic Health Record, you must provide us with clear and specific directions on the Electronic Health Record Request form. We may impose a fee to cover our labor costs in responding to your request for electronic copies of your health information. RESTRICTIONS ON DISCLOSURES 3 You have the right to request a restriction on disclosing your health information to a health plan or insurer when you pay for a health care item or service out-of-pocket in full, provided there are no other legal requirements for such disclosure. We must abide by this request. If you wish to request such a restriction, please contact the CCLS, Inc. Privacy Official for the appropriate form. 1 HITECH 13406(b). 2 HITECH 13405(e). This requirement may not apply to health plans, as HITECH defines electronic health record as an electronic record of health-related information on an individual that is created, gathered, managed and consulted by authorized health care clinicians and staff. HITECH (emphasis added). Regardless of whether this section applies to health plans, health plans must still comply with the HIPAA rule that concerns the individual s right to inspect and obtain a copy of the individual s PHI in a designated record set. See 45 CFR (a)(1). 3 HITECH 13405(a).

7 ACCOUNTING OF DISCLOSURES 4 Beginning as early as January 1, 2011 and as late as January 1, 2016, you will have the right to request an accounting of disclosures of your protected health information that CCLS, Inc. makes relating to your treatment, payment for services rendered to you and health care operations of CCLS, Inc., as long as those disclosures were made through an Electronic Health Record. The accounting of such disclosures will be for the three years prior to the date of your request. Once CCLS, Inc. knows the exact date of when this new right takes effect, it will send an additional notice to you alerting you to the effective date. Once this right takes effect, you may make such requests for accounting of disclosures by requesting and filling out the Request for Accounting of Disclosures form and give or send it to CCLS, Inc. Privacy Official. NOTICE OF BREACH You have the right to be notified if your unsecured protected health information is breached. Protected health information is secured if it is rendered unreadable, unusable or indecipherable to unauthorized persons through the use of a technology or methodology specified by the federal Department of Health and Human Services. CCLS, Inc. will do everything it can to secure your protected health information. However, should a breach of your unsecured protected health information occur, CCLS, Inc. will notify you as soon as it is able, but no later than 60 calendar days after discovery of the breach. CONTACT INFO FOR INQUIRIES RELATING TO THIS AMENDMENT CCLS, Inc. Privacy Official. Watertown WI Reference: Fundraising Opt-Out form f6300 Electronic Health Record Request form f6400 Request for Accounting of Disclosures form f5500 New: 2/19/13 4 HITECH 13405(c). It should be noted that this requirement may not apply to health plans, as HITECH defines electronic health record as an electronic record of health-related information on an individual that is created, gathered, managed and consulted by authorized health care clinicians and staff. HITECH (emphasis added). WHD/

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