Effective April 14, 2003

DOUGLAS COUNTY HOSPITAL'S
HIPAA & MINNESOTA LAW NOTICE OF PRIVACY PRACTICES
_____________________________________________________________________________________________________________________________________
THIS NOTICE DESCRIBES HOW CERTAIN MEDICAL INFORMATION
ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN
GET ACCESS TO THIS INFORMATION.

PLEASE REVIEW IT CAREFULLY AND RETAIN WITH YOUR IMPORTANT PAPERS.

_______________________________________________________________________________________________________
PURPOSE OF THIS NOTICE
This notice describes the ways in which Douglas County Hospital (DCH) may use and disclose Protected Health Information (PHI)* about you. This notice describes your rights and certain obligations we have regarding the use and disclosure of PHI.

* Specifically under the Health Insurance Portability and Accountability Act (HIPAA), Protected Health Information
(PHI) is defined as: information about (1) your physical/mental health or condition, any healthcare provided to you,
or payment of health care provided to you whether past, present or future; (2) that is created by us; and (3) that
identifies you or could be used to identify you.

OUR PLEDGE REGARDING PROTECTED HEALTH INFORMATION
DCH understands that PHI about you and your health is personal. We have a legal duty and are committed to protecting the privacy of your PHI. We create a record of the care and services you receive at the hospital. We need this record to provide you with quality care and to comply with certain legal requirements. This Notice of Privacy Practices (Notice) applies to all of your PHI generated by the hospital, whether made by hospital personnel or your personal doctor. Your personal doctor may have different policies or notices regarding the use and disclosure of your PHI created in the doctor's office or clinic.

This Notice will tell you about the ways in which DCH may use and disclose your PHI. We will describe your rights and certain obligations that we have regarding the use and disclosure of PHI.

We are required by law to:

• Make sure that PHI that identifies you is kept private;
• Give you this notice of our legal duties and privacy practices with respect to PHI about you;
• Make good faith efforts to obtain written acknowledgment of receipt of this Notice from you, maintain records of the signed receipts, and document the failure to obtain a receipt;
• Follow the terms of the Notice that is currently in effect;
• Change the Notice in accordance with federal and state regulations and to suit our facility's administrative needs;
• Provide our internal complaint process for privacy issues to you; and
• Make the Notice or any revised Notice available in hard copy, by posting it in our facility, and displaying it on the DCH Web site. You can request a Notice in person or by mail.

WHO WILL FOLLOW THIS NOTICE
This Notice describes DCH's practices and that of:

• Any health care professional authorized to enter information into your medical and billing records;
• All medical students and other trainees affiliated with the hospital;
• Any member of the Volunteers/Auxiliary that may help you while you are in the hospital;
• All departments, units, employees, staff and other hospital personnel.
• All physicians and other allied health professionals that the hospital has a contractual agreements with as well as Regional
  Anesthesiology, King's Medical and other entities that provide a service to the hospital. In addition, these entities, sites
  and locations may share PHI with each other for treatment, payment or hospital operations purposes described in this
  Notice.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU
You have the following rights regarding the PHI we maintain about you:

• Right to Inspect and Copy. You have the right to inspect and copy PHI that may be used to make decisions about your care including medical and billing records.
  
  To inspect and copy PHI that may be used to make decisions about you, you must submit your request in writing to "Douglas County Hospital/Release of Information". 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 PHI, you may request that the denial be reviewed. Another licensed health care professional chosen by the hospital 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 Amend. If you feel that PHI 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 the hospital.
  
  To request an amendment, your request must be made in writing and submitted to the DCH Privacy Officer. 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 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 PHI kept by or for the hospital;
  • Is not part of the information which you would be permitted to inspect and copy; or
  • Is accurate and complete.

  
  If we accept your requested amendment, we may append such amendment to your current record (rather than redact, delete or change the prior record). If we deny your requested amendment, you will be notified of your right to file a statement of disagreement with this decision which will be retained in your record.

• Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." This is a list of the disclosures we made of your PHI except for uses and disclosures made for treatment, payment, health care operations (TPO).
  
  To request this list or accounting of disclosures, you must submit your request in writing to the DCH 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. The first list you request within a 12 month period will be free. For additional lists, we may charge you for the costs of copying, mailing or other supplies associated with your request.
  
  
• Right to Request Restrictions. You have the right to request a restriction or limitation on the PHI we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the PHI we disclose 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 a surgery you had to a specific family member. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment.
  
  To request restrictions, you must make your request in writing to the DCH Privacy Officer. In your request, you must tell us (1) what information you want to limit, and (2) to whom you want the limits to apply; for example, disclosures to your spouse, relatives, or friends.
  
  
• Right to Request Confidential/Alternative 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
  work or by mail. To request confidential communications, you must make your request in writing to the DCH 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 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. You may obtain a copy of this Notice at our website, www.dchospital.com. To obtain a paper copy of this Notice, go
  to any of the hospital's registration areas or contact the DCH Privacy Officer.

HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU
The following categories describe different ways that we use and disclose PHI. For each category of uses or disclosures, we will explain what we mean and try to give some examples. However, not every possible use or disclosure in a category will be listed. We will not use or disclosure PHI except as described in this Notice or allowed by law without your written authorization for such use or disclosure of your PHI.

• For Treatment. We will use PHI about you to provide you with medical treatment or services. We may disclose PHI about
  you to doctors, nurses, technicians, medical students, or other hospital personnel who are involved in taking care of you at
  the hospital. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes
  may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can
  arrange for appropriate meals. Different departments of the hospital also may share PHI about you in order to coordinate
  the different things you need, such as prescriptions, lab work and x-rays. We also may disclose PHI about you to people
  outside the hospital who may be involved in or have information necessary for your medical care.
  
  
• For Payment. We may use and disclose PHI about you so that the treatment and services you receive at the hospital may be billed to and payment may be collected from you, an insurance company or a third party. For example, we may need to give your health plan information about surgery you received at the hospital so your health plan will pay us or reimburse you for the surgery. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.
  
  
• For Health Care Operations. We may use and disclose PHI about you for hospital operations. These uses and disclosures are necessary to run the hospital and make sure that all of our patients receive quality care. For example, we may use PHI to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine PHI about many hospital patients to decide what additional services the hospital should offer, what services are not needed, and whether certain new treatments are effective. We may also disclose information to doctors, nurses, technicians, medical students, and other hospital personnel for review and learning purposes. We may also combine the PHI we have with PHI from other hospitals to compare how we are doing and see where we can make improvements in the care and services we offer. We may remove information that identifies you from this set of PHI so others may use it to study health care and health care delivery without learning who the specific patients are.
  
  
• Business Associates. Some health care administration and operation activities are performed for us by our business associates. Examples of our business associates include our claims administrator, transcription service or shredding service. We may disclose your PHI to our business associates so that they can perform the job we have asked them to do. We require our business associates to appropriately safeguard PHI to follow our privacy practices.
  
  
• Medical Emergencies. We may use or disclose PHI to help you in a medical emergency.
  
  
• Appointment Reminders. We may use and disclose PHI to contact you as a reminder that you have an appointment for treatment or medical care at the hospital.
  
  
• Treatment Alternatives. We may use and disclose PHI to tell you about or recommend possible treatment options or alternatives that may be of interest to you.
  
  
• Health-Related Benefits and Services. We may use and disclose PHI to tell you about health-related benefits or services that may be of interest to you.
  
  
• Hospital Directory. We may include certain limited information about you in the hospital directory while you are a patient at the hospital. This information may include your name, location in the hospital, your general condition (e.g., fair, stable, etc.) and your religious affiliation. The directory information, except for your religious affiliation, may also be released to people who ask for you by name. Your religious affiliation may be given to a member of the clergy, such as a priest or rabbi, even if they don't ask for you by name. This is so your family, friends and clergy can visit you in the hospital and generally know how you are doing. If there is specific information that you do not want included in the directory, you must notify DCH's Privacy Officer in writing.
  
  
• Individuals Involved in Your Care or Payment for Your Care. We may release PHI 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. We may tell your family or friends your condition and that you are in the hospital. In addition, we may disclose PHI about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.
  
  
• As Required By Law. We will disclose PHI about you when required to do so by federal, state or local law. When the disclosure of PHI is prohibited or restricted by applicable law, the hospital's disclosure will reflect the more stringent law.
  
  
• To Avert a Serious Threat to Health or Safety. We may use and disclose PHI 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.
  
  
• Research. Under certain circumstances, we may use and disclose PHI about you for research purposes. For example, a research project may involve comparing the health and recovery of all patients who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of PHI, trying to balance the research needs with patients' need for privacy of their PHI. Before we use or disclose PHI for research, the project will have been approved through this research approval process; but we may however, disclose PHI about you to people preparing to conduct a research project, for example, to help them look for patients with specific medical needs, so long as the PHI they review does not leave the premises. We will almost always ask for your specific permission if the researcher will have access to your name, address or other information that reveals who you are, or will be involved in your care.
  
  
• Pursuant to Your Written Authorization. We may use and disclose your PHI pursuant to your written authorization. DCH has authorization forms available and a completed form must state the parties to whom the information is to be disclosed to, which PHI is to be disclosed, the duration of the authorization, and the purpose.

SPECIAL SITUATIONS - USES AND DISCLOSURES

• Organ and Tissue Donation. If you are an organ donor, we may release PHI to organizations that handle 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 and Veterans. If you are a member of the armed forces, we may release PHI about you as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.
  
  
• Workers' Compensation. We may release PHI about you for workers' compensation or similar programs. These programs provide benefits for work-related injuries or illnesses.
  
  
• Public Health Risks. We may disclose PHI about you for public health activities. These activities may include:
  • To prevent or control disease (such as cancer or tuberculosis) , injury or disability;
  • To make other reports as requested or authorized by applicable law;
  • To report vital events such as births and deaths;
  • 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;
    
    
• Abuse, Neglect or Threat. We may give PHI to the proper government authorities if we believe a patient has been the victim of abuse, neglect or domestic violence.
  
  
• Health Oversight Activities. We may disclose PHI 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.
  
  
• Legal Process. If you are involved in a lawsuit or a dispute, we may disclose PHI about you in response to a court or administrative order. We may also disclose PHI about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute.
  
  
• Law Enforcement. We may release PHI to law enforcement. This could be:
  • 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 obtain the person's agreement;
  • About a death we believe may be the result of criminal conduct;
  • About criminal conduct occurring on our premises; 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 PHI to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person or determine the cause of death. We may also release PHI about patients of the hospital to funeral directors as necessary to carry out their duties.
  
  
• National Security and Intelligence Activities. We may release PHI about you to authorized federal officials or foreign heads of state for intelligence, counterintelligence, special investigations, or other national security activities authorized by law.
  
  
• Correctional Facility. If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release PHI about you to the correctional institution or law enforcement official. This release would be necessary (1) for the institution to provide you with health care; (2) to protect your health and safety or the health and safety of others; or (3) for the safety and security of the correctional institution.

CHANGES AND REVISIONS
We reserve the right to change the Notice and make the revised Notice effective for PHI we already have about you as well as any information we receive in the future. We will post a copy of the current Notice in the hospital and on the DCH website:
www.dchospital.com and will promptly make any revision available upon request. The Notice will contain the effective date on the
first page, in the top right-hand corner. Douglas County Hospital also reserves the right to change its policies, procedures and
practices in response to changes in the law or regulations and to suit its administrative needs.

SPECIAL RULES FOR PSYCHOTHERAPY NOTES
Psychotherapy notes as collected only by a psychotherapist during a counseling session are considered PHI and are entitled to a higher standard of protection than other PHI and are to be maintained separately from the patient's medical record.

QUESTIONS AND COMPLAINTS
If you have questions or concerns regarding our privacy practices, please contact the DCH Privacy Officer at the address provided below.

If you believe your privacy rights have been violated, you may file a written complaint with the hospital. To file a complaint with the
hospital, contact DCH's Privacy Officer. All complaints must be submitted in writing. If we cannot resolve your concern, you also
have the right to file a written complaint with the Secretary of the Department of Health and Human Services (DHHS). We will
provide you with the DHHS contact information upon request. We support your right to the privacy of your PHI and will not
retaliate in any way if you choose to file a complaint with us or with the DHHS.

OTHER USES OF PROTECTED HEALTH INFORMATION
Other uses and disclosures of PHI not covered by this Notice or the laws that apply to us will be made only with your written
permission. If you provide us permission to use or disclose PHI about you, you may revoke that permission, in writing, at any time. If you revoke your permission, we will no longer use or disclose PHI about you for the reasons covered by your written authorization except to the extent we have already taken action in reliance on your written permission. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the care that we provided to you.

Please address all written correspondence to:
Douglas County Hospital
Attention: Privacy Officer
111-17th Avenue East
Alexandria Minnesota 56308
Phone: (320) 762-6177
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