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.

Total Health Care, Inc. provides your health care benefits. We are required by law to maintain the privacy of your health information and to give you this notice of our legal duty and how we protect the privacy of your written, spoken and electronic health information. We are generally required to notify you if your health information is not secured and is used or released in a way that is not permitted by this notice or privacy laws. We will follow the requirements of this notice while it is in effect. This notice is effective September 23, 2013, and will remain in effect until we change it.

HOW WE MAY USE AND RELEASE YOUR HEALTH INFORMATION WITHOUT YOUR PERMISSION

Only people who have both a need and a legal right may see your health information. Unless you give us written permission, we will only use and release your health information for the following purposes:

• To You or Your Personal Representative: We may release your health information to you or your personal representative (someone who has the legal right to act for you).
• For Treatment: We may use and release your health information to help you get health care. For example, we may notify your doctor about care you get in an emergency room.
• For Payment: We may use and release your health information so that your health care is correctly paid. For example, we may ask an emergency room for details about your health care before we pay the bill.
• For Healthcare Operations:We may use and release your health information for our business operations. For example, we may use your information to review the quality of care you get or to talk to you about your health benefits.
• To Others Involved in Your Care: Unless you tell us not to, we may release your health information to a member of your family, a close friend, or any other person you request, if they are involved in your health care or payment for your health care.
• To Business Associates:We may release your health information to the companies we hire to help us in our business. Before these companies can get your information, they must agree in writing that they will follow our privacy rules.
• To Group Health Plans and Plan Sponsors: If you participate in an employee benefit plan that we insure, we may share certain health information with the employer that sponsors the plan under certain conditions required by law.
• Other Permitted Uses and Releases of Your Information:Although certain rules apply, we may use or release your health information as required by law; for public health activities; to a health oversight agency for activities authorized by law, such as inspections of our offices by the government; to a governmental authority if we reasonably believe that you have been avictim of abuse, neglect or domestic violence; as required by the Food and Drug Administration; in the course of judicial or administrative proceedings (for example, in response to an order of a court); in response to certain law enforcementrequests; to coroners, medical examiners, and funeral directors; for organ, eye or tissue donation purposes; for workers’ compensation purposes; for special government functions, including national security and intelligence activities; and to avert a serious and immediate threat to the health or safety of a person or the public. We may disclose your health information to researchers in limited circumstances, if the researchers use privacy protections required by law. We must also release your information when required by the Department of Health and Human Services to investigate our compliance with the privacy laws.
• Health related benefits: We may use or release your health information to send you our newsletters or to tell you more about the benefits we offer.
• Written Permission: We may use your information for other purposes not described in this notice if you give us permission in writing. We generally need your permission to use or release your health information if it relates to psychotherapy notes, relates to marketing, or relates to the sale of your health information. You have the right to change your mind and revoke your written permission. You must revoke your written permission in writing. We cannot take back any uses or releases made before you revoke your permission.

If we use or release your health information for underwriting purposes, we are prohibited from using or releasing your health information that is genetic information for underwriting purposes.

Generally, federal privacy laws regulate how we may use and release your health information. In some circumstances state law also regulates how we may use and release your health information. In such situations, we will comply with the law that is most protective of your health information and/or gives you additional rights.

Your Rights

You have the following rights regarding your health information:

• Right to Inspect and Copy: In most cases, you have the right to look at or get copies of your records upon written request. You may be charged a fee for the cost of copying your records. If we deny your request, you may ask to have our decision reviewed.
• Right to Amend: Upon written request, you may ask us to change your records if you feel that the record is incorrect or incomplete. We may deny your request for certain reasons, but we must give you a written reason for our denial.
• Right to a List of Releases: Upon written request, you have the right to receive a list of releases of your health information made by us during the six year period before the request. This list will not include information that was released for treatment, payment or health care operations , or as permitted as described above. This list will not include information provided directly to you or your family, or information that was released based upon your written permission.
• Right to Request Restrictions on Our Use or Release of Your Information: Upon written request, you have the right to ask for limits on how your health information is used or released. We are not required to agree to such requests.
• Right to Request Confidential Communications: You have the right to ask that we share information with you in a certain way or in a certain place. Your request must be in writing. For example, you may ask us to send information to your work address instead of your home address.
• How to Use Your Rights Under This Notice: If you want to use your rights under this notice, you may write to us at the address listed below. We will help you prepare your written request, if you wish.

Changes To This Notice

We reserve the right to change this notice. A revised notice will be effective for health information we already have about you as well as any information we may receive in the future. We are required by law to comply with whatever notice is currently in effect. If the changes are important, the new notice will be mailed to you before it takes effect.

Complaints

If you believe that your privacy rights have been violated, you have the right to file a complaint with the federal government. You may write to: Office of Civil Rights Dept. of Health and Human Services 200 Independence Avenue, S.W. Washington, D.C. 20201 Phone: 877-696-6775 TTY: 886-788-4989, or visit www.hhs.gov/ocr/privacy/hipaa/complaints

You will not be penalized for filing a complaint with the federal government.

Complaints and Communications to Us: If you want to exercise your rights under this notice, communicate with us about privacy issues, or if you wish to file a complaint about us, you can call or write to us at the following address or number:

27777 Franklin Rd., Suite 1300
Southfield, MI 48034
(313) 871-2000 or (800) 826-2862

You will not be penalized for filing a complaint.

Copies Of This Notice

You have the right to receive an additional 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 of this notice upon request. Please call or write to us to request a copy.

September 2013