3B ORTHOPAEDICS, P.C. NOTICE OF PRIVACY PRACTICES

As Required by the Privacy regulations Created as a Result of the Health Insurance Portability and Accountability Act of 1996 (HIPAA)
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU (AS A PATIENT OF THIS PRACTICE) MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO YOUR PROTECTED HEALTH INFORMATION. PLEASE REVIEW THIS NOTICE CAREFULLY.

Effective date: April 14, 2003

Our practice is committed to maintaining of the privacy of any medical or other personal information that is provided to us. The Privacy Rule under the Health Insurance Portability and Accountability Act of 1996 ("HIPAA") requires us to: (i) maintain the privacy of medical information provided to us; (ii) provide notice of our legal duties and privacy practices; and (iii) abide by the terms of our Notice of Privacy Practices currently in effect.

This notice describes the practices of our physicians, staff and any volunteers at all of our practice sites. These office sites include Pennsylvania Hospital, Cherry Hill, New Jersey and Havertown. Hospital sites include Pennsylvania Hospital, Main Line Health, and Graduate Hospital.

In the ordinary course of receiving treatment and health care services from us, you will be providing us with personal information such as but not limited to:

• Your name, address, and phone number.

• Information relating to your medical history.

• Your insurance information and coverage.

• Information concerning your doctor, nurse or other medical providers.

In addition, we will gather certain medical information about you and will create a record of the care provided to you. Some information also may be provided to us by other individuals or organizations that are part of your "circle of care" - such as a referring physician, your other doctors, your health plan, and close friends or family members. Therefore, generally speaking, your protected health information is any information that relates to your past, present or future physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. PHI individually identifies you or reasonably can be used to identify you. Your medical and billing records at our practice are examples of information that usually will be regarded as your protected health information.

We may use and disclose personal and identifiable health information about you for a variety of purposes. All of the types of uses and disclosures of information are described below, but not every use or disclosure in a category is listed. We are required to disclose health information about you to the Secretary of Health and Human Services, upon request, to determine our compliance with HIPAA and to you, in accordance with your right to access and right to receive an accounting of disclosures, as described below.

This section describes how we may use and disclose your protected health information for treatment, payment, and health care operations purposes. The descriptions include examples. Not every possible use or disclosure for treatment, payment, and health care operations purposes will be listed.

We may use and disclose your protected health information for our treatment purposes as well as the treatment purposes of other health care providers. Treatment includes the provision, coordination, or management of health care services to you by one or more health care providers. Some examples of treatment uses and disclosures include:

• Reviewing your medical information by practice physicians and other staff involved in your care. Your protected health information may also be discussed with consulting physicians, a pharmacy, diagnostic laboratories, home health agencies, durable health equipment providers, and other hospitals, just to name a few.

• Disclosing your protected health information to others who assist in your care such as your spouse, children or parents.

• Using a sign in sheet in the waiting area which is accessible to others.

• Paging you in the waiting area.

• Sending or receiving faxes in a secure area.

• Contacting you to remind you of your appointment.

We may use and disclose your protected health information to obtain payment for services we provided to you. Some examples of payment uses and disclosures include:

• Sharing information with your health insurer to determine whether you are eligible for coverage and submitting a claim form to your health insurer.

• Providing supplemental information to your health insurer so that your health insurer can obtain reimbursement from another health plan under a coordination of benefits clause in your subscriber agreement.

• Mailing your bills in envelopes with our practice name and return address.

• Providing a bill to a family member or other person designated as responsible for payment for services rendered to you.

• Providing medical records and other documentation to your health insurer to support the medical necessity of a health service or a quality review audit.

• Providing information to a collection agency or our attorney for purposes of securing payment of a delinquent account.

We may use and disclose your protected health information for our health care operation purposes as well as certain health care operations purposes of other health care providers and health plans. Some examples of health care operation purposes include:

• Quality assessment and improvement activities.

• Population based activities relating to improving health or reducing health care costs.

• Reviewing the competence, qualification, or performance of health care professionals.

• Conducting training programs for medical and other students.

• Accreditation, certification, licensing, and credentialing activities.

• Health care fraud, abuse detection and compliance programs.

• Conducting other medical review, legal services, and auditing functions.

• Providing information to you of health-related benefits or services that may be of interest to you.

• Business planning and development activities, such as conducting cost management and planning related analyses.

• Other business management and general administrative activities, such as compliance with the federal privacy rule and resolution of patient grievances.

We may use your protected health information to contact you in an effort to raise funds for special programs. If we contact you for fundraising purposes, you will be provided with the opportunity to opt out of receiving any future solicitations.

We may disclose your protected health information to a family member, a relative, a friend, or any other person if we: 1) secure your approval; 2) provide you with the opportunity to object; and 3) reasonably assume that you do not object. If we give information to any individual(s) listed above, only information that we believe is directly relevant to that person’s involvement with your health care or payment related to your health care will be provided. We may also disclose your protected health information in the event of an emergency or to notify or assist in notifying such persons of your location and condition.

We may use and disclose protected health information for public health activities, including:

• Public health reporting, for example, communicable disease reports.

• FDA-related reports and disclosures, for example, adverse event reports.

• Public health warnings to third parties at risk of a communicable disease or condition.

• OSHA requirements for workplace surveillance and injury reports.

We may use and disclose protected health information for purposes of reporting of abuse, neglect, domestic violence or child abuse. For example, we would report elder abuse to the Department of Aging or abuse of a nursing home patient to the Department of Public Welfare.

We may use and disclose protected health information for purposes of health oversight activities authorized by law. These activities could include audits, inspections, investigations, licensure actions, and legal proceedings. For example, we may comply with a Drug Enforcement Agency inspection of patient records.

We may use and disclose protected health information in response to a court order, subpoena or other lawful process.

We may use and disclose protected health information for purpose of providing information to a coroner or medical examiner for the purpose of identifying a deceased patient, determining a cause of death, or facilitating their performance of other duties required by law.

We may use and disclose protected health information for purposes of providing information to funeral directors as necessary to carry out their duties.

For purposes of facilitating organ, eye and tissue donation and transplantation, we may use protected health information and disclose protected health information to entities engaged in the procurement, banking, or transplantation of cadaveric organs, eyes, or tissue.

We may use and disclose protected health information to prevent or lessen a serious and imminent threat to the safety of a person or the public.

We may use and disclose protected health information for purposes involving specialized government functions including:

• Military and veterans activities.

• National security and intelligence.

• Protective services for the President and others.

• Medical suitability determinations for the Department of State.

• Correctional institutions and other law enforcement custodial situations.

We may use and disclose protected health information as authorized by and to the extent necessary to comply with laws relating to workers' compensation or similar programs, established by law, that provide benefits for work-related injuries or illness without regard to fault.

We may use and disclose certain health information about your condition and treatment for research purposes in certain limited circumstances. We will obtain your written authorization to use your Protected Health Information for research purposes except when an Institutional Review Board or Privacy Board has determined that the waiver your authorization satisfies the following: (i) the use or disclosure involves no more than a minimal risk to your privacy based on the following: (A) an adequate plan to protect the identifiers from improper use and disclosure; (B) an adequate plan to destroy the identifiers at the earliest opportunity consistent with the research (unless there is a health research justification for retaining the identifiers or such retention is otherwise required law); and (C) adequate written assurances that the Protected Health Information be re-used or disclosed to any other person or entity (except as required by law) authorized oversight of the research study, or for other research for which the use disclosure would otherwise be permitted; (ii) the research could not practicably be conducted without the waiver; and (iii) the research could not practicably be conducted without access to and use of the Protected Health Information.

We may use and disclose your protected health information in order to tell you about or recommend possible treatment options, alternatives or health related services that may be of interest to you.

Certain functions of the practice are performed by a business associate such as an accounting firm, law firm, record storage firm, etc. We may disclose your protected health information to these business associates so that they may perform the tasks that we hire them to do. Our business associates are bound to respect the confidentiality of your personal and identifiable health information.

We may use protected health information about you in the process of de-identifying the information. For example, we may use your protected health information in the process of removing those aspects which could identify you so that the information can be disclosed to a researcher without your authorization.

We may disclose protected health information as by-product of an otherwise permitted use or disclosure. For example, other patients may overhear your name being paged in the waiting room.

We may use and disclose your protected health information when required by other laws not already specified above.

III. OTHER USES AND DISCLOSURE OF PERSONAL INFORMATION WITH AUTHORIZATION

We are required to obtain written authorization from you for any other uses and disclosures of medical information other than those described above in Section II. If you provide us with such permission, you may revoke that permission in writing at any time. If you revoke your permission, we will no longer use your disclosed personal information about you for the reasons covered by your written authorization, except to the extent we have already relied on your original permission.

You have the right to ask for restriction on the ways we use and disclose your health information for treatment, payment and health care operation purposes. You may also request that we limit our disclosures to persons assisting with your care or payment of your care. We will consider your request but we are not required to accept it. To request further restriction, you must submit a written request to our Privacy Officer. The request must tell us: (a) what information you want restricted; (b) how you want the information restricted; and (c) to whom you want the restriction to apply.

You have a right to request that we communicate your protected health information to you by a certain means or at a certain location. For example, you might request that we only contact you by mail or at work. We are not required to agree to request for confidential communications that are unreasonable but are committed to accommodate a reasonable request.

To make a request for confidential communications, you must submit a written request to our Privacy Officer. The request must tell us how or where you want to be contacted. In addition, if another individual or entity is responsible for payment, the request must explain how payment will be handled.

You have a right to receive an "accounting of disclosures". The list would not include allowable disclosures such as uses and disclosure for your treatment, payment for services furnished to you, our health care operations, disclosures to you, disclosures you gave us authorization to make, and uses and disclosures before April 14, 2003, among others. To request an accounting, you must submit a written request to the Privacy Officer. All requests for an "accounting of disclosures" must state a time period, which may not be longer than six (6) years from the date of disclosure and may not include dates before April 14, 2003. If you ask for this information more than once every 12 months, we may charge you a fee.

You have a right to inspect and obtain a copy of your protected health information including your medical records and billing records, but not any psychotherapy notes. This right is subject to limitations and we may impose a charge for the labor and supplies involved in providing copies. To exercise your right of access, you must submit a written request to our Privacy Officer. The request must: (a) describe the health information to which access is requested, (b) state how you want to access the information, such as inspection, pick-up of copy, mailing of copy, (c) specify any requested form or format, such as a paper copy or by electronic means, and (d) include the mailing address, if applicable. Our practice may deny your request to inspect and/or copy in certain limited situations, however, you may request a review of our denial.

You may revoke your authorization, except to the extent that we have already used or disclosed your protected health information. A revocation form must be completed and returned to the Privacy Officer.

You have a right to request that we amend protected health information that we maintain about you in a designated record set if the information is incorrect or incomplete. This right is subject to limitations. To request an amendment, you must submit a written request to our Privacy Officer. The request must specify each change that you want and provide a reason to support each requested change. Our practice will deny your request if you fail to submit your request (and the reason supporting your request) in writing. Also, we may deny your request if you ask us to amend information that is in our opinion: (a) accurate and complete; (b) not part of the Protected Health Information kept by or for the practice; (c) not part of the Protected Health Information which you would be permitted to inspect and copy; or (d) not created by our practice, unless the individual or entity that created the information is not available to amend the information.

If you have any complaints concerning our privacy practices, you may contact the secretary of the Department of Health and Human Services, 200 Independence Avenue, S. W., Room 509 F, HHH Bldg B, Washington, D.C. 20201 (e-mail; ocrmail@HHS.gov)

You may also contact our Privacy Officer at Booth Bartolozzi Baldertston, 800 Spruce Street, Philadelphia, PA 19107 Phone: 1-888-678-4632

YOU WILL NOT BE RETALIATED AGAINST OR PENALIZED BY US FOR FILING A COMPLAINT.

We reserve the right to change this notice at any time. We further reserve the right to make any change effective for all protected health information that we maintain at the time of the change - including information that we created or received prior to the effective date of the change.

We will post a copy of our current notice in the waiting room of the practice. At any time, patients may review the current notice.

This notice is effective as of April 14, 2003.