EFFECTIVE DATE AND REVISIONS

This notice is first in effect on April 14, 2003.

We will promptly revise and distribute this Notice whenever there is a material change to the uses or disclosures, your individual rights, our legal duties, or other privacy practices stated in this Notice. We reserve the right to change our practices and to make the new provisions effective for all protected health information we maintain as well as for all protected health information we receive in the future. We will post a copy of the current Notice in the Community. If revised, the "Notice of Privacy Practices" will be posted in the Community and on our website at www.lcrc.net. In addition, you may obtain a revised copy by contacting the Corporate Privacy Officer.

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 privacy is a high priority for us and medical information about you will be treated by us with the confidentiality required by law. This Notice applies to protected health information and records related to your care that we have received or created. It extends to protected health information received or created by our employees, staff, and volunteers. This notice informs you about the possible uses and disclosures of your protected health information. It also describes your rights and obligations regarding your protected health information.

We are required by law to:

Maintain the privacy of your protected health information.
Provide to you this detailed Notice as to our legal duties and privacy practices with respect to protected health information we collect and maintain about you that explains how, when, and why we use and disclose your protected health information.
Abide by the terms of the Notice currently in effect. We reserve the right to change the terms of this Notice and make the new Notice provisions effective for all protected health information that the Community maintains.

PROTECTED HEALTH INFORMATION

Information regarding your medical history, treatment, and payment for your health care may be originated and/or received by us. State and federal law protect information which can be used to identify you and which relates to your medical care or your payment for medical care. This is your protected health information.

COLLECTING INFORMATION

We collect protected health information about you to help us provide the best service, assistance and care, provide billing services, and to fulfill legal and regulatory requirements. The type of protected health information the Community may receive about you varies according to the assistance and care that you may need.

HOW WE MAY DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU

You will be asked to sign an Acknowledgement Form of your receipt of this Notice of Privacy Practices. However if you choose not to sign the Acknowledgment Form we still can use and disclose your protected health information for purposes of treatment, payment or health care operations unless you make specific restrictions in writing to which we agree. In addition, the use and disclosure of especially sensitive information, such as psychotherapy notes, will require that you sign an Authorization Form to receive treatment and payment.

A. USING AND DISCLOSING YOUR PROTECTED HEALTH INFORMATION FOR CERTAIN PURPOSES THAT DO NOT REQUIRE YOUR WRITTEN CONSENT AND FOR WHICH AUTHORIZATION OR OPPORTUNITY TO AGREE OR OBJECT IS NOT REQUIRED.

Treatment, payment and health care operations where consent, acknowledgment or authorization is not required:

Your consent is not required in connection with our use and disclosure of your protected health information for purposes of treatment, payment and health care operations. For example, a nurse provides care for you and will report any change in your condition to your physician. Your physician may need to know the medications you are taking before prescribing additional medications. It may be necessary for the physician to inform the nurses or staff of the medications you are taking so they can administer the medications and monitor any possible side effects. In addition, we may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.

We also may disclose protected health information to individuals who will be involved in your care after you leave the Community. Employees who have access to protected health information are required to protect it and keep it confidential.

Payment Purposes: We may use and disclose your protected health information so that the treatment and services you receive at the Community may be billed to and payment may be collected from you, an insurance company or another third party. Bills requesting payment will usually include information that identifies you, your diagnosis and any procedures or supplies. For example, we may contact Medicare or your health plan to confirm your coverage or submitted bills may result in a request for additional information prior to payment.

Health Care Operations: We may use and disclose your protected health information for Community operations. These uses and disclosures are necessary to manage the Community and make sure that our residents receive quality care. For example, our Medical Director or members of the quality improvement team may use information in your health record to evaluate our Community's services, including the performance of our staff.

Business Associates: Some services in the Community are provided through contract with business associates. Examples include but are not limited to physician services provided by our Medical Director, certain pharmacy services, radiology and certain laboratory tests. We may disclose protected health information about you to our business associates so that they can perform their jobs and bill you or your third-party payer for services provided. These business associates are required to appropriately safeguard your protected health information.

Appointment Reminders: We may use or disclose your protected health information to remind you about appointments.

Treatment Alternatives: We may use or disclose your protected health information to inform you about possible treatment alternatives that may be of interest to you.

Notification: We may use or disclose protected health information to notify or assist in notifying a family member, personal representative or another person responsible for your care of your location and general condition.

Organ Donation and Transplantation: We may use or disclose to organ procurement, banking or transplantation organizations your protected health information to facilitate organ, eye, or tissue donation and transplantation.

As Required by Law: We will disclose protected health information about you when required to do so by federal, state or local law.

Law Enforcement: We may disclose protected health information about you for law enforcement purposes as required by law or in response to a valid subpoena.

To Avert a Serious Threat to Health or Safety: We may use and disclose protected health information about you when necessary to prevent a serious threat to your health or safety or the health or safety of the public or another person.

Public Health: As required by law, we may disclose your protected health information for public health activities. These activities may include, for example:

Reporting to a public health or other government authority for preventing or controlling disease, injury or disability, or reporting child abuse or neglect;
To notify a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition.
Persons subject to the jurisdiction of the Food and Drug Administration (FDA): We may disclose your protected health information to persons subject to the jurisdiction of the FDA concerning adverse events or problems with products, for tracking products in certain circumstances, to enable product recalls, repairs or replacements or to comply with other FDA regulated activities.

Reporting Victims of Abuse, Neglect or Domestic Violence: If we believe that you have been a victim of abuse, neglect, or domestic violence, we may use and disclose your protected health information to notify a government authority if required or authorized by law or if you agree to the report.

Health Oversight Activities: We may disclose your protected health information to a health oversight agency for activities authorized by law. These may include, for example, audits, investigations, inspections, surveys, licensure and disciplinary actions; civil, administrative, or criminal proceedings; or other legal proceedings. These activities are necessary for government oversight of the government payment or regulatory programs, compliance with civil rights laws and for government oversight of the health care system. The Community does not control or define what information is needed by the health oversight organizations.

Coroner, Medical Examiners, Funeral Directors: Protected health information regarding a decedent may be released to a coroner or medical examiner for the purpose of identifying a deceased person, determining cause of death or other purposes as authorized by law. Protected health information regarding a decedent may also be disclosed to funeral directors if necessary to carry out their duties.

Judicial and Administrative Proceedings: We may disclose your protected health information for law enforcement purposes as required by law or in response to a valid court order, a subpoena or administrative request authorized by law. We may also disclose your protected health information to a limited extent and in limited circumstances in response to a law enforcement officer's request for information for identification and location purposes.

Military and Veterans: If you are or have been a member of the armed forces, we may release your protected health information as required by military command authorities.

Research: We may disclose your protected health information to researchers in certain limited circumstances. We will use your protected health information for research purposes only with your written authorization except in the following circumstances: (a) our use or disclosure was approved by a duly constituted Institutional Review Board or Privacy Board; (b) we obtain the oral or written agreement of a researcher that (i) the information being sought is necessary for the research study; (ii) the use or disclosure of your protected health information is solely to prepare a research protocol or for similar preparatory research; and (iii) the researcher will not remove any of your protected health information from our premises; or (c) the protected health information sought by the researcher only relates to decedents and the researcher agrees either orally or in writing that the use or disclosure is necessary for the research and, if we request it, to provide us with proof of death prior to access to the protected health information of the decedents.

Lawsuits and Disputes: If you are involved in a lawsuit or dispute, we may disclose protected health information about you in response to a court or administrative order. We may also disclose your protected health information in response to suspected criminal activity, a subpoena, discovery request or other lawful process by someone else involved in the dispute, but only if we receive satisfactory assurance from the party seeking the information that efforts have been made to tell you about the request or to obtain an order protecting the information requested.

National Security and Intelligence Activities: We may release protected health information about you to authorized federal officials for intelligence, counterintelligence and other national security activities authorized by law and to federal officials to protect the President, other officials or foreign heads of state or to conduct investigations.

Fundraising Activities: We may use your protected health information for the purpose of contacting you as part of a fundraising effort. Only demographic information and the dates healthcare was provided to you will be disclosed in connection with fundraising efforts. If you do not wish to be contacted for fundraising activities, you may contact your Executive Director at 561-454-2000 to have your name removed from our fundraising list.

Inmates: We may disclose your protected health information to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official if such disclosures are necessary for health, safety, law enforcement or security purposes.

Other Uses and Disclosures: Other uses and disclosures will be made only with your written authorization which generally may be revoked in writing at any time and will be effective except to the extent that we have taken action in reliance on such written authorization.

B. USING AND DISCLOSING YOUR PROTECTED HEALTH INFORMATION WITHOUT YOUR CONSENT UNLESS YOU OBJECT.

Certain uses and disclosures do not require your prior written consent unless you object. If you are informed in advance of the use or disclosure and have the opportunity to object, we may use and disclose your protected health information for the following reasons without your consent unless you object:

Community Directory: Unless you object, we will include certain limited information about you in our Community Directory. This information may include your name, location in the Community, general condition and religious affiliation. Our directory does not include specific medical information about you. This information may be provided to members of the clergy and, except for religious affiliation, to other people who ask for you by name. In addition, your name will be on the door, your name will be on the dining room table and may include dietary information, your name may be in the Community newsletter, such as on the monthly birthday list, you may be in pictures/videos, such as during participation in an activity, your name will be on the monthly birthday board, clothing will be marked with your name to prevent loss, your name may be on beauty shop appointment list, and paperwork, computer work, and transmissions.

Communication with Family: Unless you object, we may disclose to a family member or any other person you identify, your protected health information relevant to the involvement of a family member, personal representative, close personal friend, including clergy, involved in your care or payment for your care.

Disaster Relief: We may disclose your protected health information to an organization assisting in a disaster relief effort.

YOUR RIGHTS

Right to Request Confidential Communications: You have the right to request that we communicate with you concerning personal health matters in a certain manner or at a certain location. For example, you can request that we contact you only at a certain phone number. To request confidential communications, you must make your request in writing to the Privacy Officer. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to Request Restrictions: You have the right to request restrictions on our use or disclosure of your protected health information that is used to carry out treatment, payment or health care operations. You also have the right to request a limit on the protected health information we disclose about you to someone who is involved in your care or the payment of your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you had. We are not required to agree to your request, but even if we do agree to your request, any limitation on disclosure will not apply if you are being transferred to another health care institution since law requires the release of records, or the release of information as needed to provide emergency care. To request restrictions, you must make your request in writing to the Privacy Officer. In your request, you must tell us (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.

Right of Access to Protected Health Information: You have the right to inspect and copy your protected health information. Usually, this includes medical and billing records, but does not include psychotherapy notes. To inspect and copy protected health information that may be used to make decisions about you, you must submit your request in writing to the Privacy Officer. If you request a copy of the information, 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 copy in certain very limited circumstances. If you are denied access to protected health information, you may request that the denial be reviewed. We will choose another licensed health care professional who 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.

Right to Request Amendment: If you feel that protected health 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 us. You must make your request in writing and must state the reason for the requested amendment. The request must be submitted to the Privacy Officer. 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 not longer available to make the amendment;
Is not part of the protected health information kept by or for us;
Is not part of the information which you would be permitted to inspect and copy; or
Is accurate and complete.
Right to an Accounting of Disclosures: You have the right to request an "accounting" of our disclosures of your protected health information. This is a list of the disclosures of protected health information about you made by the Community or by others on our behalf, but does not include disclosures made for treatment, payments, and health care operations, or for certain other limited purposes. To request this list or accounting of disclosures, you must submit your request in writing to the Privacy Officer. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in which form you want the list (for example, on paper or electronically). The first list you request within a twelve (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 modify your request at that time before any costs are incurred.

Right to a Paper Copy of This Notice: You have the right receive a paper copy of this Notice from us at any time upon request. Even if you have agreed to receive this Notice electronically, you are still entitled to a paper copy of this notice. You may obtain a copy of this Notice at our website, www.lcrc.net. You may obtain a paper copy of this Notice by contacting the Community Privacy Coordinator or by inquiring at the office of the Executive Director of the Community.

AUTHORIZATION

Other uses and disclosures of your protected health information not allowed by law will only be made with your Authorization. If you revoke your Authorization, we will no longer use or disclose your protected health information for the purposes covered by the Authorization, except where we already relied on the Authorization.

FOR MORE INFORMATION OR TO REPORT A PROBLEM

If you have questions and would like additional information, please contact Lifespace Community's Corporate Privacy Officer at 515-288-5805. If you believe your privacy rights have been violated, you may file a complaint with Lifespace Community's Corporate Privacy Officer or the Office of Civil Rights in the U.S. Department of Health and Human Services. All complaints must be submitted in writing.

Contact:
Deb E. Goss
Director of Health Services
Lifespace Communities, Inc.
100 East Grand Ave. Suite 200
Des Moines, IA 50309

Or you may contact:
Region IV-Attn: Roosevelt Freeman, Regional Manager
Office for Civil Rights
U.S. Department of Health and Human Services
Atlanta Federal Center
61 Forsyth Street, SW, Suite 3B70
Atlanta, GA 30323-8909

You will not be penalized for filing a complaint.