What is this notice?

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 also describe your rights and certain obligations we have regarding the use and disclosure of medical information.

This notice applies to all of the records received, used, or disclosed by Solera Health. Non-Solera health providers may have different policies or notices regarding their uses and disclosures of your medical information.

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. The notice will contain the effective date on the first page, in the top right-hand corner. In addition, each time you use our services, we will offer you a copy of the current notice in effect.

Solera’s pledge regarding medical information

We understand that confidential medical information about you (“you” or “your” used throughout refers to the patient) and your health is personal. We are committed to protecting medical information about you.

We are required by law to:

• Make sure that medical information that identifies you is kept private (with certain exceptions)
• Give you this notice of our legal duties and privacy practices with respect to medical information about you’ and
• Follow the terms of the notice that is currently in effect

Why does Solera collect your medical information?

We create a record of the care and services you receive. We need this record to provide you with quality care and to comply with certain legal requirements.

How does Solera use and disclose your medical information?

The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures we will explain what we mean and try to give some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

For treatment

We may use medical information about you to provide you with health care coordination and health management services. Our communications to you may be by telephone, cell phone, email, or mail. For example, we may use your information to facilitate appointment scheduling with your provider. We may disclose medical information about you to healthcare providers who are involved in taking care of you. We may also disclose medical information about you to people outside Solera Health who may be involved in your continued care, such as a disease management or prevention program.

For payment

We may use and disclose medical information about you so that the services you receive may be billed and payment collected from you, an insurance company or a third party, if applicable. For example, we may need information about your treatment history to facilitate benefits claims.

For health care operations

We may use or disclose your health care information for health care operations. For example, we may use your information to determine the quality of care you received from one of our partners. If the activities require disclosure outside of our organization we will request your authorization before disclosing that information.

As required by law

We will disclose medical information about you when required to do so by federal, state or local law.

To avert a serious threat to health or safety

We may use and disclose medical information about you when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. Any disclosure, however, would only be to someone able to help prevent the threat.

Appointment reminders

We may use and disclose medical information to contact you as a reminder that you have an appointment for care.

Attendance reminders

We may use and disclose medical information to contact you to remind you about your attendance obligations.

Preventive health and health-related benefits and services

We may use and disclose medical information to tell you about changes or lifestyle options or alternatives that may be of interest to you. We may also use and disclose medical information to tell you about health-related benefits or services that may be of interest to you.

Public health activities

We may disclose medical information about you for public health activities. These activities generally include:

• To prevent or control disease, injury or disability
• To report births and deaths
• To report regarding the abuse or neglect of children, elders and dependent adults
• To report reactions to medications or problems with products
• To notify people of recalls of products they may be using
• To notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition
• To notify the appropriate government authority if we believe a patient has been the victim of abuse, neglect, or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
• To notify emergency response employees regarding possible exposure to HIV/AIDS, to the extent necessary to comply with state and federal laws

Workers’ compensation

We may release medical information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.

Lawsuits and disputes

If you are involved in a lawsuit or a dispute, we may share medical information about you in response to a court or administrative order. We may also share medical information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute, but only if efforts have been made to tell you about the request (which may include written notice to you) or to obtain an order protecting the information requested.

Fundraising activities

You may want to make contributions to support the services we provide. You have the right to opt out of (stop) receiving fundraising messages. If you receive a fundraising message, it will tell you how to opt out.

Marketing and sales

Most uses and sharing of medical information for marketing purposes, and sharing that constitute a sale of medical information, require your authorization. Solera health will not share your health information for marketing or sales purposes without getting your authorization.

Who else can Solera give my medical information to?

We may share your medical information with the following people or organizations, for reasons other than those described in the section above.

People involved in your care or payment for your care

We may release medical information about you to a friend or family member who is involved in your medical care. We may also give information to someone who helps pay for your care.

If you’re caught in a disaster such as a hurricane, we may also share medical information about you to an organization assisting in a disaster relief effort so that your family can be notified about your condition, status, and location.

Government authorities who receive reports of abuse, neglect, or violence

We may disclose your information to a government authority authorized by law to receive reports of abuse, neglect, or violence relating to children or the elderly.

Military command authorities

If you are a member of the armed forces, we may release medical information about you as required by military command authorities. We may also release medical information about foreign military personnel to the appropriate foreign military authority.

Health oversight agencies

We may disclose medical information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs and compliance with civil rights laws. We will only make this disclosure if you agree or when required or authorized by law.

Law enforcement

We may release medical information if asked to do so by a law enforcement official:

• In response to a court order, subpoena, warrant, summons or similar process
• To identify or locate a suspect, fugitive, material witness, or missing person
• About the victim of a crime if, under certain limited circumstances, we are unable to get the person’s agreement
• About a death we believe may be the result of criminal conduct
• About criminal conduct at the hospital, and
• In emergency circumstances to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime

Coroners, medical examiners and funeral directors

We may release medical information to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death.

Authorized federal officials

We may release medical information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law. We may disclose medical information about you to authorized federal officials so they may provide protection to the president, other authorized persons, or foreign heads of state, or may conduct special investigations.

Correctional institutions or law enforcement officials

If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may disclose medical information about you to the correctional institution or law enforcement official.

This disclosure would be necessary:

• For the institution to provide you with health care
• To protect your health and safety or the health and safety of others
• For the safety and security of the correctional institution

Multidisciplinary personnel teams

We may disclose health information about a child or elderly person and their caregivers (such as a child’s parents) to a multidisciplinary personnel team relevant to preventing, identifying, managing, or treating abuse or neglect.

Special categories of information

In some circumstances, your health information may be subject to restrictions that may limit or preclude some uses or disclosures described in this notice. For example, there are special restrictions on the use or disclosure of certain categories of information — such as tests for HIV or treatment for mental health conditions or alcohol and drug abuse. Government health benefit programs, such as Medi-Cal, may also limit the disclosure of beneficiary information for purposes unrelated to the program.

What control do I have about sharing of my medical information?

You can ask for restrictions on the use and sharing of your medical information

You have the right to request a restriction or limitation on:

• The medical information we use or share about you for services, payments, or health care operations
• The medical information we share about you to someone who is involved in your care or the payment for your care, like a family member or friend. For example, you could ask that we not use or disclose information about an evaluation you had.

We are not required to agree to your request, except if you ask us not to share information with a health plan or insurer for payment or health care operations purposes, when you (or someone else on your behalf other than the health plan or insurer) has paid for the item or service out of pocket in full. Even if you request this special restriction, we can disclose the information to a health plan or insurer for purposes of treating you.

If we agree to another special restriction, we will comply with your request unless the information is needed to provide you emergency treatment.

To request restrictions:

1. You must make your request in writing to myprivacy@soleranetwork.com
2. In your request, you must tell us:
• What information you want to limit
• If you want to limit our use, disclosure or both, and
• To whom you want the limits to apply, for example, disclosures to your spouse

Requesting confidential communications

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at home or by telephone.

To request confidential communications:

1. You must make your request in writing to myprivacy@soleranetwork.com
2. Your request must specify how or where you wish to be contacted

We will not ask you the reason for your request. We will accommodate all reasonable requests.

Disclosure at your request

We may disclose information when requested by you. This disclosure at your request may require a written authorization from you.

To request information disclosure:

3. You must make your request in writing to myprivacy@soleranetwork.com
4. In your request, you must tell us:
• What information you want to disclose
• If you want to limit our use, disclosure or both, and
• To whom you want the disclosure(s) to apply, for example, disclosures to your spouse

Can I see the medical information Solera has collected?

Yes, you have the right to inspect and obtain a copy of medical information that may be used to make decisions about your care. Usually, this includes medical and billing records, but may not include some mental health information.

To inspect and obtain a copy of medical information that may be used to make decisions about you:

1. You must submit your request in writing to myprivacy@soleranetwork.com
2. You have the right to request that the copy be provided in an electronic form or format (such as a PDF saved on a compact disk) if the information is readily producible in an electronic form or format

We may charge a fee for the costs of copying, mailing, or other supplies associated with your request.

We may deny your request to inspect and obtain a copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed. A licensed health care professional chosen by us will review your request and the denial. The person conducting the review will not be the person who denied your request. We will comply with the outcome of the review.

Can I see whom Solera has shared my medical information with?

You have the right to request an “accounting of disclosures.” This is a list of the disclosures we made of medical information about you other than our own uses for treatment, payment, health care operations (as those functions are described above), and with other exceptions pursuant to the law.

To request an accounting (list) of disclosures:

1. You must submit your request in writing to myprivacy@soleranetwork.com
2. In your request, you must tell us:
• A time period which may not be longer than 6 years and may not include dates before April 14, 2003.
• What format you want the list in (for example, on paper or electronically).

The first list you request within a 12-month period will be free. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or change your request at that time before we create any costs.

Can I change my medical information?

If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for Solera Health.

To request an amendment to your medical information:

1. You must make a written request to myprivacy@soleranetwork.com
2. You must provide a reason that supports your request

We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

• Was not created by us, unless the person or entity that created the information is no longer available to make the amendment
• Is not part of the medical information kept by or for Solera Health
• Is not part of the information which you would be allowed to inspect and copy, or
• Is accurate and complete

What if I think my privacy has been violated?

If you believe your privacy rights have been violated, you may file a complaint with Solera Health or the Secretary of the Federal Department of Health and Human Services. All complaints must be submitted in writing. You will not be punished for filing a complaint.

To file a complaint with Solera Health, contact: Privacy Officer at Privacy Officer, Solera Health, 2425 East Camelback Road, Suite 150; Phoenix, AZ 85016, (602) 904-6108; myprivacy@soleranetwork.com.

To file a complaint with the Department of Health and Human Services, contact: Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Ave., S.W., Washington, D.C. 20201, or visit the Office for Civil Rights website to file a complaint electronically: http://www.hhs.gov/ocr/filing-with-ocr/index.html.

Notification of a breach

Solera Health will notify you as required by law following a breach of your unsecured protected health information.

You have a right to a paper copy of this notice

You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice.

To obtain a paper copy of this notice, please contact: Solera Privacy Officer at Privacy Officer, Solera Health, 2425 East Camelback Road, Suite 150; Phoenix, AZ 85016, (602) 904-6108; myprivacy@soleranetwork.com.

You may obtain an electronic copy of this notice at our website: www.soleranetwork.com