This Notice describes how medical information about you may be used and disclosed and how you can get access to this information. It is divided into seven sections. Please review it carefully.

USE AND DISCLOSURE OF HEALTH INFORMATION

Vetted International, Ltd. protects the confidentiality of and security of your personal information by using industry recognized security safeguards such as firewalls, coupled with carefully developed security procedures to protect your information from loss, misuse or unauthorized alteration. Whenever we ask for sensitive information, we encrypt it as it is transmitted to us. Our employees are trained and required to safeguard your information, and, using physical, electronic and procedural safeguards, we restrict access to personal information to those employees and agents for business purposes only. Additionally, we use internal and external resources to review the adequacy of our security procedures.

1. THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:

To Provide Treatment. Vetted International Ltd. may use your health information to coordinate care within Vetted International, Ltd. and with others involved in your care, such as your attending physician, members of Vetted International, Ltd. interdisciplinary team and other health care professionals who have agreed to assist Vetted International, Ltd. in coordinating care. For example, physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. Vetted International, Ltd. also may disclose your health care information to individuals outside of Vetted International, Ltd. involved in your care, including family members, clergy who you have designated, pharmacists, suppliers of medical equipment or other health care professionals.

To Obtain Payment. Upon your written request on the release of information, Vetted International, Ltd. may include your health information in invoices to collect payment from third parties for the care you receive from Vetted International, Ltd. For example, Vetted International, Ltd. may be required by your health insurer to provide information regarding your health care status so that the insurer will reimburse you or Vetted International, Ltd. Vetted International, Ltd. also may need to obtain prior approval from your insurer and may need to explain to the insurer your need for care and the services that will be provided to you.

To Conduct Health Care Operations. Vetted International, Ltd. may use and disclose health information for its own operations in order to facilitate the function of Vetted International, Ltd. and as necessary to provide quality care to all of Vetted International, Ltd. patients. Health care operations include such activities as:

• Quality assessment and improvement activities.
• Activities designed to improve health or reduce health care costs.
• Protocol development, case management and care coordination.
• Contacting health care providers and patients with information about treatment alternatives and other related functions that do not include treatment.
• Professional review and performance evaluation.
• Training programs including those in which students, trainees or practitioners in health care learn under supervision.
• Accreditation, certification, licensing or credentialing activities.
• Review and auditing, including compliance reviews, medical reviews, legal services and compliance programs.
• Business planning and development, including cost management and planning related analyses and formulary development.
• Business management and general administrative activities of Vetted International, Ltd.

2. OTHER PERMITTED USES AND DISCLOSURES OF HEALTH INFORMATION RELATING TO PUBLIC POLICY OR LEGAL CIRCUMSTANCES FOR WHICH YOUR HEALTH INFORMATION MAY ALSO BE USED OR DISCLOSED:

When Legally Required. Vetted International, Ltd. will disclose your health information when it is required to do so by any Federal, State or Local law.

When There Are Risks to Public Health. Vetted International, Ltd. will disclose your health information for public activities and purposes in order to:

• Prevent or control disease, injury or disability, report disease, injury, vital events—such as birth or death—and the conduct of public health surveillance, investigations and interventions.
• Report adverse events, product defects, to track products or enable product recalls, repairs and replacements and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
• Notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
• Notify an employer as legally required.

To Report Abuse, Neglect or Domestic Violence. Vetted International, Ltd is allowed to notify government authorities if Vetted International, Ltd. believes a patient is the victim of abuse, neglect, or domestic violence. Vetted International, Ltd. will make this disclosure only when specifically required or authorized by law or when the patient agrees to the disclosure.

To Conduct Health Oversight Activities. Vetted International, Ltd. may disclose your health information to a health oversight hospice for activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. Vetted International, Ltd., however, may not disclose your health information if you are the subject of an investigation and your health information is not directly related to your receipt of health care or public benefits.

In Connection With Judicial and Administrative Proceedings. Vetted International, Ltd. may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only when Vetted International, Ltd. makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information.

For Law Enforcement Purposes. As permitted or required by State law, Vetted International, Ltd. may disclose your health information to a law enforcement official for certain law enforcement purposes as follows:

• As required by law for reporting types of wounds or other physical injuries pursuant to a court order, warrant, subpoena or summons or similar process.
• For the purpose of identifying or locating a suspect, fugitive, material witness or missing person.
• To a law enforcement official if Vetted International, Ltd. has a suspicion that your death was the result of criminal conduct including criminal conduct at the Hospice.
• In an emergency in order to report a crime.

3. AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION

Other than for the reasons previously, Vetted International, Ltd. will not disclose your health information without your written authorization. If you or your representative authorizes Vetted International, Ltd. to use or disclose your health information, you may revoke that authorization in writing at any time.

4. YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your health information that Vetted International, Ltd. maintains:

Right to Request Restrictions. You may request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on Vetted International, Ltd.’s disclosure of your health information to someone who is involved in your care or the payment of your care. However, Vetted International, Ltd. is not required to agree with your request. If you wish to make a request for restrictions, please contact the Privacy Officer at (919) 518-9200 or by email at privacy.officer@vetted-intl.com.

Right to Receive Confidential Communications. You have the right to request that Vetted International, Ltd. communicate with you in a certain way. For example, you may ask that Vetted International, Ltd. only conduct communications pertaining to your health information with you privately with no other family members present. If you wish to receive confidential communications, please contact the Privacy Officer at (919) 518-9200 or by email at privacy.officer@vetted-intl.com. Vetted International, Ltd. will not request that you provide any reasons for your request and will attempt to honor your reasonable requests for confidential communications.

Right to Inspect and Copy Your Health Information. You have the right to inspect and copy your health information, including billing records. A request to inspect and copy records containing your health information may be made to the Privacy Officer at (919) 518-9200 or by email at privacy.officer@vetted-intl.com. Vetted International, Ltd. may charge a reasonable fee for copying and assembling costs associated with your request.

Right to Amend Health Care Information. You or your representative has the right to request that Vetted International, Ltd. amend your records, if you believe that your health information is incorrect or incomplete. That request may be made as long as the information is maintained by Vetted International, Ltd. A request for an amendment of records must be made in writing to the Privacy Officer, 3301 Benson Drive, Ste. 545, Raleigh, NC, 27609. Vetted International, Ltd. may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by Vetted International, Ltd., if your records you are requesting are not part of the health information you or your representative are permitted to inspect and copy, or if, in the opinion of Vetted International, Ltd. the records containing your health information are accurate and complete.

Right to an Accounting. You or your representative has the right to request an accounting of disclosures of your health information made by Vetted International, Ltd. for certain reasons, including reasons related to public purposes authorized by law and certain research. The request for an accounting must be made in writing to the Privacy Officer, 3301 Benson Drive, Ste. 545, Raleigh, NC, 27609. The request should specify the time period for the accounting. Accounting requests may not be made for periods of time in excess of six (6) years. Vetted International, Ltd. will provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee.

Right to Paper Copy of this Notice. You or your representative has the right to a separate paper copy of this Notice at any time, even if you or your representative has received this Notice previously. To obtain a separate paper copy, please contact the Privacy Officer at (919) 518-9200 or by e-mail at privacy.officer@vetted-intl.com.

Right to Lodge a Complaint. You or your representative has the right to lodge a complaint to Vetted International, Ltd. and to the Office of Civil Rights in the Department of Health and Human Services (DHHS) if you or your representative believes that your privacy rights have been violated. Complaints, in writing, to Vetted International, Ltd. should be made to:

Privacy Officer
Vetted International, Ltd.
3301 Benson Drive Ste. 545
Raleigh, NC, 27609
privacy.officer@vetted-intl.com

Vetted International, Ltd. encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.

5. DUTIES OF VETTED INTERNATIONAL, LTD.

Vetted International, Ltd. is required by law to maintain the privacy of your health information and to provide to you and your representative this Notice of its duties and privacy practices. Vetted International, Ltd. is required to abide by the terms of this Notice as may be amended from time to time. Vetted International, Ltd. reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all health information that it maintains. If Vetted International, Ltd. changes its Notice, Vetted International, Ltd. will provide a copy of the revised Notice to you or your appointed representative.

6. CONTACT PERSON

Vetted International, Ltd. has designated the Privacy Officer as its contact person for all issues and questions regarding patient privacy and your rights under Federal privacy standards. You may contact this person at (919) 518-9200 or by writing to the Privacy Officer, 3301 Benson Drive Ste. 545, Raleigh, NC, 27609 or via e-mail at privacy.officer@vetted-intl.com.

7. EFFECTIVE DATE. This Notice is effective June 1, 2005.