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MAIN LINE ORTHOPAEDICS SITE PRIVACY POLICY NOTICE

Thank you for visiting our Main Line Orthopaedics (MLO) web site and for reviewing our Privacy Policy. Our policy is clear:

We collect no information about you, other than information automatically collected and stored (see below), when you visit our web site unless you choose to provide that information to us. We provide blank insurance forms as a service to our visitors but encourage you to not email insurance or billing forms that contain private financial information as there is no guarantee that that information cannot be intercepted and viewed by third parties.

(NOTE: For information on the Medical Privacy Rule, please go to www.mainlineorthopaedics/medicalprivacy.html )

Information Automatically Collected and Stored:

When you browse through any web site, certain personal information about you can be collected. We automatically collect and temporarily store the following information about your visit:

The name of the domain you use to access the Internet (for example, aol.com, if you are using an America Online account, or stanford.edu, if you are connecting from Stanford University's domain);
• The date and time of your visit;
• The pages you visited; and
• The address of the web site you came from when you came to visit.

We use this information for statistical purposes and to help us make our site more useful to visitors. Unless it is specifically stated otherwise, no additional information will be collected about you.

Personally Provided Information:

You do not have to give us personal information to visit our web sites.

If you choose to provide us with additional information about yourself through an e-mail message, form, survey, etc., we will only maintain the information as long as needed to respond to your question or to fulfill the stated purpose of the communication.

However, all communications addressed to Main Line Orthopaedics are maintained, as required by law, for historical purposes. These communications are archived on a monthly basis, but are also protected by the Privacy Act which restricts our use of them, yet permits certain disclosures.

Disclosure:

Main Line Orthopaedics does not disclose, give, sell or transfer any personal information about our visitors, unless required for law enforcement or statute.

Intrusion Detection:

For site security purposes and to ensure that this service remains available to all users, we employ software programs to monitor traffic to identify unauthorized attempts to upload or change information, or otherwise cause damage. In the event of authorized law enforcement investigations, and pursuant to any required legal process, information from these sources may be used to help identify an individual.

Systems of Records

Information originally collected in traditional paper systems can be submitted electronically, i.e., electronic commerce transactions and information updates about eligibility benefits. Electronically submitted information is maintained and destroyed pursuant to the Federal Records Act, and in some cases may be subject to the Privacy Act. If information that you submit is to be used in a Privacy Act system of records, there will be a Privacy Act Notice provided.

MAIN LINE ORTHOPAEDICS PATIENT PRIVACY POLICY NOTICE (AS OF 4/26/07)

OUR PLEDGE AND PRIVACY OBLIGATIONS

Main Line Orthopaedics is committed to protecting the confidentiality of your medical information. We create a record of the care and services you receive at our facilities. We need this record to provide you with quality care and to comply with certain legal requirements. This notice will inform you as to the ways we may use and disclose information about you and your health (“medical information”). This notice also describes your rights and certain obligations we have regarding the use and disclosure of your medical information.

This notice applies to all of the records of your care generated or maintained by Main Line Orthopaedics, whether made by Main Line Orthopaedics personnel or your doctor. Your doctor may have different policies or notices regarding the doctor’s use and disclosure of your medical information created in the doctor’s office or clinic.

The Health Insurance Portability and Accountability Act (“HIPAA”) requires that we maintain the privacy of your medical information and provide you this notice as to our legal duties and privacy practices with respect to medical information. When we use or disclose medical information, we are required to abide by the terms of this notice. We reserve the right to change our privacy practices and this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. Our current notice may be accessed on the Main Line Orthopaedics web page at http://www.mainlineorthopaedic.com. Revised notices will also be posted in facility patient waiting areas. You may also receive current copies of our notice by sending a written request to our privacy officer.

If you have any questions about this notice, contact Main Line Orthopaedics at Main Line Orthopaedics, 101 S Bryn Mawr Ave, # 200, Bryn Mawr, PA 19010, (610) 527-9500

USES AND DISCLOSURES OF MEDICAL INFORMATION

The following sections describe different ways that we may use and disclose your medical information. For each category of uses or disclosures we will explain what we mean and attempt to provide an example. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of the categories.

For Treatment. We will use and disclose your medical information to provide you with medical treatment and services. We may disclose medical information about you to doctors, nurses, technicians, students, or other health care personnel who are involved in your care. 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 hospital’s dietitian if you have diabetes so that we can arrange for appropriate meals. We may also share your medical information with other Main Line Orthopaedics personnel or non-Main Line Orthopaedics providers, agencies, or facilities in order to coordinate the different things you need, such as prescriptions, lab work and x-rays. We may also disclose medical information to persons outside Main Line Orthopaedics who may be involved in your continuing medical care after you leave Main Line Orthopaedics, such as other health care providers if you need to be transferred to another hospital, a nursing home, a home health provider, a rehabilitation hospital, community agencies and family members.

For Payment. Your medical information will be used, as necessary, to obtain payment for your health care services. We may use your medical information so that the treatment and services you receive at Main Line Orthopaedics or from other entities, such as an ambulance company, may be billed and payment collected from you, an insurance company or a third party. For example, we may share your medical information with your health insurance company to obtain reimbursement after we have treated you, or to determine whether your health insurance plan will cover your treatment.

For Health Care Operations. We may use and disclose your medical information to conduct our health care operations. These uses and disclosures are necessary to the business activities of Main Line Orthopaedics and to ensure all our patients receive quality care. These activities include, but are not limited to, quality improvement activities, business management and planning functions, licensure and accreditation activities, and to obtain audit, accounting or legal services. For example, we may use your medical information to review our treatment and services and to evaluate the performance of our staff in caring for you. We may also combine medical information 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, or to compare how we are doing with others and where improvements can be made. We may remove information that identifies you from this set of medical information so others may use it to study health care and health care delivery without learning the identity of specific patients. We may disclose medical information to doctors, nurses, technicians, medical students, and other facility personnel for performance improvement and educational purposes.

Appointment Reminders. We may use and disclose medical information to contact you as a reminder that you have an appointment for treatment or medical care at one of our facilities.

Treatment Alternatives. We may use and disclose medical information 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 medical information to tell you about health-related benefits or services that may be of interest to you.

Fundraising Activities. We may use your medical information to contact you to provide information about Main Line Orthopaedics sponsored activities, including fundraising programs and events. We may disclose medical information to a foundation related to Main Line Orthopaedics Medical Center so that the foundation may contact you about fundraising programs and events. We only would release contact information, such as your name, address and phone number and the dates you received treatment or services at our facilities. If you do not want us to contact you about our fundraising efforts, you must notify us in writing by forwarding your request to: Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010 (610) 527-9500.

Directories. We may include certain limited information about you in a hospital directory if you are an inpatient at a Main Line Orthopaedics affiliated Medical Center, unless you object. This information will include your name and location in the facility and may be released to people who ask for you by name. Unless you object, we will also maintain your religious affiliation on a list that may be given to a member of the clergy of your religious affiliation even if they don’t ask for you by name.

Individuals Involved in Your Care or Payment for Your Care. We may release medical information about you to a friend, family member, or personal representative who is involved in your medical care. We may also give information to someone who helps pay for your care. We may also tell your family or friends your condition and that you are in the hospital. In addition, we may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location.

Research. Under certain circumstances, we may use and disclose medical information 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 medical information, trying to balance the research needs with patients' need for privacy of their medical information. Before we use or disclose medical information for research, the project will have been approved through this research approval process, but we may, however, disclose medical information 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 medical information they review does not leave the facility. We will almost always ask for your specific permission (authorization) 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 at the hospital.

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

To Avert a Serious Threat to Health or Safety. We may use and disclose medical information 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. Any disclosure would be limited to someone able to help prevent the threat.

SPECIAL SITUATIONS

Organ and Tissue Donation. If you are an organ donor, we may release your medical information 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, Veterans, National Security, and Other Government Purposes. If you are or were a member of the armed forces, we may release your medical information to military command authorities as authorized or required by law. We may also release medical information about foreign military personnel to the appropriate foreign military authority. We may also disclose medical information to authorized federal officials for purposes of national security, intelligence and counter-intelligence activities as authorized or required by law and to authorized federal officials charged with protecting the President, authorized officials, foreign heads of state, and conducting special federal investigations.

Workers' Compensation. We may disclose your medical information as authorized to comply with workers' compensation laws and other similar programs established by law.

Public Health Disclosures. We may disclose your medical information for public health activities and purposes to a public health authority authorized by law to collect or receive information. These activities generally include: • Preventing or controlling disease, injury or disability;
• Reporting vital events such as births and deaths;
• Reporting suspected instances of child abuse, endangerment, or neglect;
• Reporting reactions to medications or problems with products;
• Notifying people of recalls of products they may be using;
• Notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition, where authorized by law;
• Notifying the appropriate government authority if we believe a patient has been the victim of abuse, neglect or domestic violence and this disclosure is made as authorized or required by law.

Health Oversight Activities. We may disclose your medical information to health oversight agencies for activities authorized by law such as audits, investigations, inspections, and licensure activities.

Lawsuits and Disputes. In connection with lawsuits or other legal proceedings, we may disclose your medical information in response to a court or administrative order, or in response to a subpoena, discovery request, warrant, or other lawful process.

Law Enforcement. Where requested by law enforcement, and as authorized or required by law, we may disclose medical information:
In response to a court order, subpoena, warrant, summons or similar process;
In response to limited requests for information necessary to identify or locate a suspect, fugitive, material witness, or missing person;
About a suspected victim of a crime if the individual agrees to the disclosure and, under certain circumstances, where we are unable to obtain the person's agreement;
About a death we suspect may be the result of criminal conduct;
About criminal conduct that occurs at Main Line Orthopaedics facilities; 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 disclose your medical information to a coroner or medical examiner for identification purposes, determining cause of death, or to permit their performance of other duties required by law. Your medical information may also be disclosed to a funeral director, as authorized by law, to permit the director to perform their lawful duties.

Inmates. If you are an inmate of a correctional facility or under the custody of law enforcement officials, we may disclose your medical information to the correctional institution or officials as authorized or required by law.

YOUR RIGHTS REGARDING YOUR MEDICAL INFORMATION

Your medical information is the property of Main Line Orthopaedics. You have the following rights, however, regarding medical information we maintain about you:

Right to Inspect and Copy. With certain exceptions, you have the right to inspect and copy your medical information for as long as we maintain that information.

To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to the appropriate Medical Record Department of the Main Line Orthopaedics entity that maintains your medical information. A list of all Main Line Orthopaedics record departments and their addresses is set forth at the end of this Notice. 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 limited circumstances. If you are denied access to your medical information, in most cases, you may request that the denial be reviewed. Another licensed health care professional chosen by Main Line Orthopaedics 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 an Amendment or Addendum. If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information or add an addendum (addition to the record). You have the right to request an amendment or addendum for as long as the information is kept by or for Main Line Orthopaedics.

To request an amendment, your request must be made in writing and submitted to the medical record department of the Main Line Orthopaedics entity that maintains your information at the appropriate address set forth at the end of this Notice. 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 medical information kept by or for Main Line Orthopaedics;
• 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 disclosures”. This is a list of the disclosures we made of your medical information. This right does not apply to disclosures made for purposes of treatment, payment, and health care operations or disclosures that are subject to certain restrictions, exceptions, and limitations imposed by law.

To request an accounting of disclosures, you must submit your request in writing to Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010. Your request must state a time period that may not be longer than six years and may not include dates before April 14, 2003. Your request should indicate in what form you want the list (for example, on paper, electronically). The first list you request within a 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.

We will ordinarily respond to your request for an accounting within 60 days. If we require additional time to prepare the accounting you have requested, we will notify you in writing about the reason for the delay and the date you can expect to receive the accounting.

Right to Request Restrictions. You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information 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.

We are not required to agree to your request. If we do agree, our agreement must be in writing and we will comply with your request unless the information is needed to provide you emergency treatment.

To request a restriction, you must make your request in writing to the Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010. 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, for example, disclosures to your spouse.

Right to Request Confidential Communications. You have the right to request that we communicate with you about medical matters in a more confidential way by requesting that we communicate with you by alternative means or at alternative locations. For example, you can ask that we only contact you at home or by mail.

To request more confidential communications, please make your request in writing to Main Line Orthopaedics, contact Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010 (610) 527-9500. We will not ask you the reason for your request, and we will try to accommodate reasonable requests. Please specify in your request how or where you wish to be contacted, and how payment for your health care will be handled if we communicate with you through the requested alternative method or location.

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 of this Notice.

You may obtain a downloadable copy of this notice at our website, http://www.mainlineorthopaedic.com/patientresources.html or by writing Privacy Officer, Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010

COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with Main Line Orthopaedics or with the Secretary of the Department of Health and Human Services. To file a written complaint with Main Line Orthopaedics, contact Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010 (610) 527-9500.

You will not be penalized for filing a complaint.

OTHER USES OF MEDICAL INFORMATION

Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written authorization, giving us permission for such uses or disclosures. If you provide us permission to use or disclose medical information about you, you may revoke that permission, in writing, at any time, by contacting Privacy Officer, Main Line Orthopaedics, contact Main Line Orthopaedics 101 S Bryn Mawr Ave # 200 Bryn Mawr, PA 19010 (610) 527-9500. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. We are unable to take back any disclosures we have already made with your permission, and we will retain our records of the care that we provided to you as required by law.