HIPAA Notice

Spirit Medical Transport, LLC may use or disclose your PHI without your authorization, or without providing you with an opportunity to object, for the following purposes:

Treatment

This includes verbal and written information that we obtain about you and use pertaining to your medical condition and treatment provided to you by us and other medical personnel, including doctors and nurses who give orders to allow us to provide treatment to you.

It also includes information we give to other healthcare personnel to whom we transfer your care and treatment, and includes transfer of PHI via radio or telephone to the hospital or dispatch center as well as providing the hospital with a copy of the written record we create in the course of providing you with treatment and transport.

Payment

This includes activities we must undertake in order to get reimbursed for the services that we provide to you, including organizing your PHI, submitting bills to insurance companies either directly or through a third-party billing company, managing billed claims for services rendered, performing medical necessity determinations and reviews, performing utilization reviews, and collecting outstanding accounts.

Healthcare Operations

This includes quality assurance activities, licensing and training programs to ensure that our personnel meet our standards of care and follow established policies and procedures, obtaining legal and financial services, conducting business planning, processing grievances and complaints, creating reports that do not individually identify you for data collection purposes, fundraising, and certain marketing activities.

Fundraising

We may contact you when we are in the process of raising funds for Spirit Medical Transport, LLC, or to provide you with information about our annual subscription program.

In addition, we may use your PHI for certain fundraising activities. For example, we may use PHI that we collect about you, such as your name, home address, phone number or other information, in order to contact you to raise funds for our agency.

We may also share this information with another organization that may contact you to raise money on our behalf.

If Spirit Medical Transport, LLC uses your PHI to conduct fundraising activities, you have the right to opt out of receiving such fundraising communications. If you do not want to be contacted for fundraising efforts, contact our HIPAA Compliance Officer, Brian K. Hathaway, in writing, by phone, or by email.

We will also remind you of this right to opt out of receiving future fundraising communications every time that we use your PHI to conduct fundraising and contact you to raise funds. Spirit Medical Transport, LLC will not condition the provision of medical care on your willingness, or non-willingness, to receive fundraising communications.

Reminders for Scheduled Transports and Information on Other Services

We may contact you to provide a reminder of scheduled appointments for non-emergency ambulance and medical transportation, or to provide information about alternative services we offer or other health-related benefits and services that may be of interest to you.

Spirit Medical Transport, LLC is also permitted to use or disclose your PHI without your written authorization in situations including:

• For the treatment activities of another healthcare provider.
• To another healthcare provider or entity for the payment activities of the provider or entity that receives the information, such as your hospital or insurance company.
• To another healthcare provider, such as the hospital to which you are transported, for healthcare operations activities as long as the receiving entity has or has had a relationship with you and the PHI pertains to that relationship.
• For healthcare fraud and abuse detection or activities related to compliance with the law.
• To a family member, other relative, close personal friend or other individual involved in your care when permitted under applicable privacy rules.
• To a public health authority in certain situations, including reporting a birth, death or disease as required by law, public health investigations, reports of child or adult abuse, neglect or domestic violence, adverse events, product defects, or possible exposure to communicable disease.
• For health oversight activities including audits, government investigations, inspections, disciplinary proceedings and other administrative or judicial actions undertaken to oversee the healthcare system.
• For judicial and administrative proceedings as required by court or administrative order, or in certain circumstances in response to a subpoena or other legal process.
• For law enforcement activities in limited situations.
• For military, national defense, security and other special government functions.
• To avert a serious threat to the health and safety of a person or the public at large.
• For workers' compensation purposes and in compliance with workers' compensation laws.
• To coroners, medical examiners and funeral directors for identifying a deceased person, determining cause of death, or carrying out duties authorized by law.
• If you are an organ donor, to organizations involved with organ procurement or organ, eye or tissue transplantation when necessary to facilitate donation and transplantation.
• For research projects subject to strict oversight, approvals and privacy safeguards in accordance with law.

Any other use or disclosure of PHI, other than those listed above, will only be made with your written authorization. The authorization must specifically identify the information we seek to use or disclose, as well as when and how we seek to use or disclose it.

Specifically, we must obtain your written authorization before using or disclosing:

• Psychotherapy notes, other than for the purpose of carrying out our own treatment, payment or healthcare operations purposes.
• PHI for marketing when we receive payment to make a marketing communication.
• PHI when engaging in a sale of your PHI.

You may revoke your authorization at any time, in writing, except to the extent that we have already used or disclosed medical information in reliance on that authorization.

As a patient, you have a number of rights with respect to your protected health information.

Right to Access, Copy or Inspect Your PHI

You have the right to inspect and copy most of the medical information that we collect and maintain about you. Requests for access to your PHI should be made in writing to our HIPAA Compliance Officer.

In limited circumstances, we may deny you access to your medical information, and you may appeal certain types of denials. We have forms available to request access to your PHI and will provide a written response if access is denied and advise you of applicable appeal rights.

We will normally provide access to this information within 30 days of your written request. If we maintain your medical information electronically, you have the right to obtain a copy in electronic format.

If you request that we transmit a copy of your PHI directly to another person, we will do so provided the request is in writing, signed by you or your representative, and clearly identifies the designated person and where the copy should be sent.

We may charge a reasonable cost-based fee for providing access to your PHI, subject to applicable state law.

Right to Request an Amendment of Your PHI

You have the right to ask us to amend protected health information that we maintain about you. Requests should be made in writing to Brian K. Hathaway, our HIPAA Compliance Officer.

When required by law, we will amend your information within 60 days of your request and notify you when the information has been amended. We may deny a request in certain circumstances, including when we believe the information you have asked us to amend is correct.

Right to Request an Accounting of Disclosures

You may request an accounting of certain disclosures of your medical information by contacting our HIPAA Compliance Officer and making the request in writing.

You have the right to receive an accounting of certain disclosures made within six years immediately preceding your request.

We are not required to provide an accounting for certain disclosures, including those for treatment, payment or healthcare operations; disclosures you expressly authorized; disclosures made to you, your family or friends; or certain disclosures for law enforcement or governmental purposes.

Right to Request Restrictions

You have the right to request restrictions on how we use and disclose your medical information for treatment, payment or healthcare operations, or on information provided to family, friends and other individuals involved in your healthcare.

We are only required to abide by a requested restriction under limited circumstances, and it is generally our policy that we will not agree to restrictions unless required by law.

Spirit Medical Transport, LLC is required to abide by a requested restriction when you ask that we not release PHI to your health plan about a service for which you, or someone on your behalf, have paid Spirit Medical Transport, LLC in full.

We are also required to abide by restrictions that we agree to. If restricted information is needed to provide emergency treatment, however, the PHI may be disclosed to a healthcare provider for that emergency treatment.

A restriction may be terminated if you agree to or request its termination. Most current restrictions may also be terminated by Spirit Medical Transport, LLC as long as you are notified. PHI created or received after termination will no longer be subject to the restriction, while previously restricted PHI must continue to be treated as restricted.

Right to Notice of a Breach

If we discover that there has been a breach of your unsecured PHI, we will notify you by first-class mail sent to the most recent address we have on file.

If you prefer notification by email, contact Brian K. Hathaway, our HIPAA Compliance Officer, and provide a valid email address. You may withdraw your agreement to receive notice by email at any time.

Right to Request Confidential Communications

You have the right to request that we send your PHI to an alternate location, such as somewhere other than your home address, or in a specific manner, such as email rather than regular mail.

We will comply with reasonable requests when required by law. Requests should be made in writing to our HIPAA Compliance Officer.

Internet, Email and the Right to Obtain a Paper Copy

If we maintain a website, we will prominently post a copy of this Notice on our website and make the Notice available electronically through the website.

If you allow us, we will forward this Notice by electronic mail instead of on paper. You may always request a paper copy of the Notice.

Revisions to the Notice

Spirit Medical Transport, LLC is required to abide by the terms of the version of this Notice currently in effect.

Spirit Medical Transport, LLC reserves the right to change the terms of this Notice at any time. Changes will be effective immediately and will apply to all PHI that we maintain.

Material changes to the Notice will be promptly posted in our facilities and on our website, if we maintain one. You may obtain a copy of the latest version by contacting Brian K. Hathaway, our HIPAA Compliance Officer.

You have the right to complain to us, or to the Secretary of the United States Department of Health and Human Services, if you believe that your privacy rights have been violated.

Questions, comments or complaints may be directed to Brian K. Hathaway, our HIPAA Compliance Officer.