HIPAA NOTICE OF PRIVACY PRACTICES

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH Act) place important restrictions on the sharing of your medical information and provide you with important privacy rights. This Notice of Privacy Practices (the “Notice”) replaces all prior notices provided by us and is effective on the date noted above. This Notice describes our legal obligations and your legal rights regarding your “protected health information” (“PHI”). This Notice describes how your PHI may be used or disclosed to carry out treatment, payment, or health care operations, or other purposes permitted by law. Generally, PHI includes personal information collected from you or created by us that relates to your past, present, or future physical or mental health or condition; the provision of health care; or the past, present, or future payment for the provision of health care.

We are required by law to maintain the privacy of your PHI, provide you with certain rights with respect to your PHI, provide you with a copy of this Notice, and follow the terms of this Notice. We reserve the right to change the terms of this Notice and its practices regarding your PHI. If there is any material change to this Notice, we will provide you with a
copy of the revised Notice of Privacy Practices. If you have any questions about this Notice or about our privacy practices, please contact our Privacy Officer, identified below.

Uses and Disclosures for Treatment, Payment, and Operations
We may use or disclose your PHI without your express authorization under certain circumstances, which include the following:

• For Treatment, to facilitate the provision of treatment and services to you.

• For Payment, to determine your eligibility for treatment or services and to facilitate payment for the treatment or services you receive.

• For Health Care Operations, uses and disclosures necessary to operate our programs and services.

• Treatment Alternatives or Health-Related Benefits and Services that might be of interest to you.
Other Uses and Disclosures

• To Business Associates to perform various functions on our behalf or to provide certain types of services. A Business Associate will receive, create, maintain, transmit,
use, and/or disclose your PHI, but only after they agree in writing with us to implement appropriate safeguards regarding your PHI.

• As Required by Law when required to do so by federal, state, or local law.

• To Avert a Serious Threat to Health or Safety to you, or the health and safety of the public, or another person, limited to someone able to help prevent the threat.

• Organ and Tissue Donation, after your death to an organization that handles organ procurement or organ, eye, or tissue transplantation or to an organ donation bank,
as necessary to facilitate organ or tissue donation and transplantation.

• Military, if you are a member of the armed forces, as required by military command authorities. The Plan Sponsor may also release PHI about foreign military personnel
to the appropriate foreign military authority.

• Workers' Compensation or similar programs, but only as authorized by, and to the extent necessary to comply with,

• laws relating to workers' compensation and similar programs that provide benefits for work-related injuries or illness.

• Public Health Risks for public health activities. These activities generally include the following:
− to prevent or control disease, injury, or disability.
− to report births and deaths.
− to report child abuse or neglect or domestic violence, as required or permitted by law.
− 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.
− for disaster relief efforts

• Health Oversight Activities for activities authorized by law, for example, audits, investigations, inspections, and licensure.

• Lawsuits and Disputesin response to a court or administrative order, including a response to a lawful subpoena, discovery request, or other process by someone involved in a legal dispute, but only if efforts have been made to tell you about the request or to obtain a court or administrative order protecting the information requested.

• Law Enforcement 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, the Plan Sponsor is unable to obtain the victim's agreement.
− about a death that the Plan Sponsor believes may be the result of criminal conduct; and
− about criminal conduct.

• Coroners, Medical Examiners, and Funeral Directors, for example, to identify a deceased person or determine the cause of death. The Plan Sponsor may also release
medical information about patients to funeral directors, as necessary to carry out their duties.

• National Security and Intelligence Activities, to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

• Inmates of a correctional institution or in the custody of a law-enforcement official, to the correctional institution or law-enforcement official if necessary for the
institution to provide you with health care; to protect your health and safety or the health and safety of others; or for the safety and security of the correctional institution.

• Research, to researchers when the individual identifiers have been removed; or when an institutional review board or privacy board has reviewed the research proposal and established protocols to ensure the privacy of the requested information and approves the research.

Other Disclosures with Your Authorization Only
We may disclose your PHI to:

• Personal Representatives authorized by you, or to an individual designated as your personal representative, or attorney-in-fact. You must provide a written notice/authorization and supporting documents such as a power of attorney. We do not have to disclose information to a personal representative if we have a reasonable belief that you have been, or may be, subjected to domestic violence, abuse, or neglect by such person; or treating such person as your personal representative could
endanger you; or in the exercise of professional judgment, it is not in your best interest to treat the person as your personal representative.
‍
• Comply with your Authorization. Other uses or disclosures of your PHI not described above will only be made with your written authorization, including use or disclosure of psychotherapy notes. Further, we will not use or disclose your PHI for marketing; or sell your PHI, unless you provide written authorization. You may revoke written authorizations at any time, so long as the revocation is in writing. Once we receive your written revocation, it will only be effective for future uses and disclosures. It will not be effective for any information that may have been used or disclosed in reliance upon the written authorization and prior to receiving your written revocation.

Privacy Rights

• Right to Inspect and Copy. You have the right to inspect and copy certain PHI that may be used to make decisions about you. If the information you request is maintained electronically, and you request an electronic copy, we will provide a copy in the electronic form and format you request, if the information can be readily produced in that form and format; if the information cannot be readily produced in that form and format, we will work with you to come to an agreement on form and format or
provide you with a paper copy. To inspect and copy your PHI, you must submit your request in writing to the Privacy Officer identified below. We may charge a reasonable fee for the costs of copying, mailing, or other supplies associated with your request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to your medical information, you may request that the denial be reviewed by submitting a written request to the Privacy Officer identified below.
‍
• Right to Amend. If you feel that your PHI 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 us. To request an amendment, your request must be made in writing and submitted to the Privacy Officer identified below. In addition, 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 it:
− is not part of the medical information kept by or for us.
− 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 information that you would be permitted to inspect and copy; or
− is already accurate and complete.
− If your request is denied, you have the right to file a statement of disagreement with us and any future disclosures of the disputed information will include your statement.

• Right to an Accounting of Disclosures. You have the right to request an "accounting" of certain disclosures of your PHI. The accounting will not include (1) disclosures for purposes of treatment, payment, or health care operations. (2) disclosures made to you; (3) disclosures made pursuant to your authorization; (4) disclosures made to friends or family in your presence or because of an emergency; (5) disclosures for national security purposes; and (6) disclosures incidental to otherwise permissible disclosures. To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer identified below. Your request must state the time period you want the accounting to cover, which may not be longer than six years before the date of the request. Your request should indicate in what form you want the list (for example, paper or electronic). The first list you request within a 12-month period will be provided free of charge. 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 modify your request at that time before any costs are incurred.
‍
• Right to Request Restrictions or limitation on your PHI that we use or disclose for treatment, payment, or health care operations. You also have the right to request a limit on your PHI that is disclosed to someone who is involved in your care or the payment for your care, such as a family member or friend. Except as provided in the next paragraph, we are not required to agree to your request. However, we will comply with any restriction request if (1) except as otherwise required by law, the
disclosure is to a health plan for purposes of carrying out payment or health care operations (and is not for purposes of carrying out treatment); and (2) the PHI pertains solely to a health care item or service for which the health care provider involved has been paid in full by you or another person. To request restrictions, you must make your request in writing to the Privacy Officer identified below. In your request, you must state (1) what information you want to limit; (2) whether you want to limit our use, disclosure, or both; and (3) to whom you want the limits to apply - for example, disclosures to your spouse. If we honor the request, it will stay in place until you revoke it or we notify you.
‍
• Right to Request Confidential Communications about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. Your request must be made in writing to the Privacy Officer identified below and specify how or where you wish to be contacted. We will accommodate all reasonable requests.
‍
• Right to Be Notified of a Breach in the event that we (or a Business Associate) discover a breach of unsecured PHI.
‍
• Right to a Paper Copy of This Notice You may request a paper copy of this notice at any time from the Privacy Officer identified below, even if you have agreed to receive this notice electronically.

SMS Terms and Conditions

• How We Share Your Information (Mobile Phone Numbers). Your phone number will not be shared with third parties/affiliates for marketing/promotional purposes. Hamaspik of Rockland County may share your phone number with certain third-parties for the limited purpose of assisting us with providing the automated communications to you. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
‍
• Opt-In Consent to Mobile Messaging: By submitting your phone number, you are authorizing Hamaspik of Rockland County to send informational text messages, multimedia messages, and/or telephone calls using an automatic telephone dialing system or an artificial or prerecorded voice to the phone number you have provided. Standard message and data rates may apply, depending on your carrier’s pricing plan. These fees may vary if the message is sent domestically or internationally.
‍
• Opt-out of Text Message Communications: You may unsubscribe or opt-out from receiving future automated communications from Hamaspik of Rockland County at any time. If you wish to stop receiving text messages from us, reply STOP, QUIT, CANCEL, OPT-OUT, or UNSUBSCRIBE to any automatic text message sent from us.