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.

We understand the importance of privacy and are committed to maintaining the confidentiality of your
medical information. We make a record of the medical care we provide and may receive such records from
others. We use these records to provide or enable other health care providers to provide quality medical
care, to obtain payment for services provided to you as allowed by your health plan and to enable us to
meet our professional and legal obligations to operate WSS properly. We are required by law to maintain
the privacy of protected health information and to provide individuals with notice of our legal duties and
privacy practices with respect to protected health information. This notice describes how we may use and
disclose your medical information. It also describes your rights and our legal obligations with respect to
your medical information. If you have any questions about this Notice, please contact our Office Manager.

A. How Systems Medicine (SM)
May Use or Disclose Your Health Information

SM collects health information about you and stores it in a chart and on a computer. The medical record is
the property of SM, but the information in the medical record belongs to you. The law permits us to use or
disclose your health information for the following purposes:

1. Treatment. We use medical information about you to provide your medical care. We disclose medical
information to our employees and others who are involved in providing the care you need. For example, we
may share your medical information with other physicians or other health care providers who will provide
services which we do not provide such as a pharmacist or a laboratory.

2. Payment. We use and disclose medical information about you to obtain payment for the services we
provide. For example, we give your health plan the information it requires before it will pay us. We may also
disclose information to other health care providers to assist them in obtaining payment for services they
have provided to you.

3. Health Care Operations. We may use and disclose medical information about you to operate SM. For
example, we may use and disclose this information to review and improve the quality of care we provide, or
to train our professional staff, or we may use and disclose this information to get your health plan to
authorize services or referrals. We may also use and disclose this information as necessary for medical
reviews, legal services and audits, including fraud and abuse detection and compliance programs and
business planning and management. We may also share your medical information with our business
associates who may perform administrative services for us. We have a written contract with each of these
business associates that contains terms requiring them to protect the confidentiality of your medical
information. Although federal law does not protect health information which is disclosed to someone other
than another healthcare provider, health plan or healthcare clearinghouse, under Ohio law all recipients of
health care information are prohibited from re-disclosing it except as specifically required or permitted by
law. We may also share your information with other health care providers, health care clearinghouses or
health plans that have a relationship with you, when they request this information to help them with their
quality assessment and improvement activities, their efforts to improve health or reduce health care costs,
their review of competence, qualifications and performance of health care professionals, their training
programs, their accreditation, certification or licensing activities, or their health care fraud and abuse
detection and compliance efforts

4. Appointment reminders. We may use and disclose medical information to contact and remind you about
appointments. If you are not home, we may leave this information on your answering machine or in a
message left with the person answering the phone or we may send you a postcard.

5. Sign in sheet. We may use and disclose medical information about you by having you sign in when you
arrive at our office. We may also call out your name when we are ready to see you.

6. Notification and communication with family. We may disclose your health information to notify or assist in
notifying a family member, your personal representative or another person responsible for your care, about
your location, your general condition or in the event of your death. In the event of a disaster, we may
disclose information to a relief organization so that they may coordinate these notification efforts.

7. Marketing. We may contact you to give you information about products or services related to your
treatment, case management or care coordination, or to direct or recommend other treatments or healthrelated
benefits and services that may be of interest to you, or to provide you with small gifts. We may also
encourage you to purchase a product or service when we see you. We will not use or disclose your medical
information without your written authorization.

8. Required by law. As required by law, we will use and disclose your health information, but we will limit
our use or disclosure to the relevant requirements of the law. When the law requires us to report abuse,
neglect or domestic violence, or respond to judicial or administrative proceedings, or to law enforcement
officials, we will further comply with the requirement set forth below concerning those activities.

9. Public health. We may, and are sometimes required by law to disclose your health information to public
health authorities for purposes related to: preventing or controlling disease, injury or disability; reporting
child, elder or dependent adult abuse or neglect; reporting domestic violence; reporting to the Food and
Drug Administration problems with products and reactions to medications; and reporting disease or
infection exposure. When we report suspected elder or dependent adult abuse or domestic violence, we
will inform you or your personal representative promptly unless in our best professional judgment, we
believe the notification would place you at risk of serious harm or would require informing a personal
representative we believe is responsible for the abuse or harm.

10. Health oversight activities. We may, and are sometimes required by law to disclose your health
information to health oversight agencies during the course of audits, investigations, inspections, licensure
and other proceedings, subject to the limitations imposed by federal and Ohio law.

11. Judicial and administrative proceedings. We may, and are sometimes required by law, to disclose your
health information in the course of any administrative or judicial proceeding to the extent expressly
authorized by a court or administrative order. We may also disclose information about you in response to a
subpoena, discovery request or other lawful process if reasonable efforts have been made to notify you of
the request and you have not objected, or if your objections have been resolved by a court or administrative
order.

12. Law enforcement. We may, and are sometimes required by law, to disclose your health information to a
law enforcement official for purposes such as identifying or locating a suspect, fugitive, material witness or
missing person, complying with a court order, warrant, grand jury subpoena and other law enforcement
purposes.

13. Coroners. We may, and are often required by law, to disclose your health information to coroners in
connection with their investigations of deaths.

14. Organ or tissue donation. We may disclose your health information to organizations involved in
procuring, banking or transplanting organs and tissues.

15. Public safety. We may, and are sometimes required by law, to disclose your health information to
appropriate persons in order to prevent or lessen a serious and imminent threat to the health or safety of a
particular person or the general public.

16. Specialized government functions. We may disclose your health information for military or national
security purposes or to correctional institutions or law enforcement officers that have you in their lawful
custody.

17. Worker’s compensation. We may disclose your health information as necessary to comply with worker’s
compensation laws. For example, to the extent your care is covered by workers’ compensation, we will
make periodic reports to your employer about your condition. We are also required by law to report
cases of occupational injury or occupational illness to the employer or workers’ compensation insurer.

18. Change of Ownership. In the event that SM is sold or merged with another organization, your health
information/record will become the property of the new owner, although you will maintain the right to
request that copies of your health information be transferred to another physician or medical group.

19. Research. We may disclose your health information to researchers conducting research with respect to
which your written authorization is not required as approved by an Institutional Review Board or privacy
board, in compliance with governing law.

B. When SM May Not Use or Disclose Your Health Information
Except as described in this Notice of Privacy Practices, SM will not use or disclose
health information which identifies you without your written authorization. If you
do authorize SM to use or disclose your health information for another purpose,
you may revoke your authorization in writing at any time.

C. Your Health Information Rights
1. Right to Request Special Privacy Protections. You have the right to request restrictions on certain uses
and disclosures of your health information, by a written request specifying what information you want to
limit and what limitations on our use or disclosure of that information you wish to have imposed. We
reserve the right to accept or reject your request, and will notify you of our decision.
2. Right to Request Confidential Communications. You have the right to request that you receive your
health information in a specific way or at a specific location. For example, you may ask that we send
information to a particular email account or to your work address. We will comply with all reasonable
requests submitted in writing which specify how or where you wish to receive these communications.
3. Right to Inspect and Copy. You have the right to inspect and copy your health information, with limited
exceptions. To access your medical information, you must submit a written request detailing what
information you want access to and whether you want to inspect it or get a copy of it. We will charge a
reasonable fee, as allowed by Ohio law. We may deny your request under limited circumstances. If we
deny your request to access your child’s records because we believe allowing access would be reasonably
likely to cause substantial harm to your child, you will have a right to appeal our decision.
4. Right to Amend or Supplement. You have a right to request that we amend your health information that
you believe is incorrect or incomplete. You must make a request to amend in writing, and include the
reasons you believe the information is inaccurate or incomplete. We are not required to change your health
information, and will provide you with information about SM’s denial and how you can disagree with the
denial. We may deny your request if we do not have the information, if we did not create the information
(unless the person or entity that created the information is no longer available to make the amendment), if
you would not be permitted to inspect or copy the information at issue, or if the information is accurate and
complete as is. You also have the right to request that we add to your record a statement of up to 250
words concerning any statement or item you believe to be incomplete or incorrect.
5. Right to an Accounting of Disclosures. You have a right to receive an accounting of disclosures of your
health information made by SM, except that SM does not have to account for the disclosures provided to
you or pursuant to your written authorization, or as described in paragraphs 1 (treatment), 2 (payment), 3
(health care operations), 6 (notification and communication with family) and 16 (specialized government
functions) of Section A of this Notice of Privacy Practices or disclosures for purposes of research or public
health which exclude direct patient identifiers, or which are incident to a use or disclosure otherwise
permitted or authorized by law, or the disclosures to a health oversight agency or law enforcement official
to the extent SM has received notice from that agency or official that providing this accounting would be
reasonably likely to impede their activities.
6. You have a right to a paper copy of this Notice of Privacy Practices If you would like to have a more
detailed explanation of these rights or if you would like to exercise one or more of these rights, contact the
Office Manager.

D. Changes to this Notice of Privacy Practices
We reserve the right to amend this Notice of Privacy Practices at any time in the future. Until such
amendment is made, we are required by law to comply with this Notice. After an amendment is made, the
revised Notice of Privacy Protections will apply to all protected health information that we maintain,
regardless of when it was created or received. We will keep a copy of the current notice posted in our
reception area, and will offer you a copy at each appointment.

E. Complaints
Complaints about this Notice of Privacy Practices or how SM handles your health information should be
directed to the Office Manager. If you are not satisfied with the manner in which this office handles a
complaint, you may submit a formal complaint to:

Department of Health and Human Services
Office of Civil Rights
Hubert H. Humphrey Bldg.
200 Independence Avenue, S.W.
Room 509F HHH Building
Washington, DC 20201

You will not be penalized for filing a complaint.