Associated Pathology Medical Group, Inc. (APMG) is committed to protecting the privacy of your personal health information. APMG protects the confidentiality of individuals’ laboratory test results and other patient protected health information (PHI) that we collect and create as part of our diagnostic testing activities.

We encourage you to read this Notice thoroughly so that you will understand our commitment to protect your PHI. Should you have any questions about this Notice or any of our practices please call:

Executive Director
Associated Pathology Medical Group, Inc.
105A Cooper Court
Los Gatos, CA 95032
(800) 848-2764, ext. 2723

This Notice takes effect January 1, 2005

APMG’s Privacy Policy

APMG and its employees are committed to obtaining, maintaining, using and disclosing patient protected health information (PHI) in a manner that protects patient privacy. We will only disclose the minimum amount of PHI we consider necessary to perform diagnostic testing and receive reimbursement for our services. Your doctor(s) may have different Notices regarding their use and disclosure of your PHI created in their offices.

APMG is required by law to provide this Notice of Privacy Practices with respect to PHI, to maintain the privacy of PHI, to state the potential uses and disclosures of PHI, and to list the rights of individuals with respect to their PHI. Your PHI at APMG includes personal and medical information such as your name, address, date of birth, testing ordered that we obtain from you, your physician, health plan, or other sources. Your PHI also includes the laboratory testing results that we create.

Changes to this Notice of Privacy Practices

APMG is obliged to abide by this Notice as currently in effect. APMG reserves the right to change the terms of this Notice of Privacy Practices. The current Notice will be available on our website: www.apmglab.com and a printed copy is available by contacting our Executive Director at the phone number listed above.

How APMG may use and disclose your Protected Health Information (PHI)

Your PHI will be used or disclosed for treatment, payment, or healthcare operations purposes and for other purposes permitted or required by law. The ways APMG may use or disclose PHI fit into one of the categories listed below.

For Treatment
As a health care provider that provides laboratory testing for ordering physicians, APMG will disclose your PHI to physicians and other authorized health care professionals who need access to your laboratory results to treat you. In addition to your treating physician, we may provide a specialist consulting physician with information about your results to further validate the results before release to your physician.

For Payment
APMG may use and disclose your PHI so claims for our diagnostic services may be paid. These disclosures would be made to insurance companies, hospitals, physicians and health plans. Any third party disclosure would be to parties that assist us in creating bills and claim forms. In some cases we may have to contact you to obtain complete billing information or for other billing purposes. When required, we may use an outside collection agency to obtain payment.

For Healthcare Operations
We may use or disclose your PHI to enable us to support our operations. These include quality control, quality assurance and reference range creation. These operations would disclose only your demographic data such as age and sex, not unique identifiers such as name and social security number.

Disclosures to Business Associates
APMG may disclose your PHI to other companies or individuals who perform services for our company. These other entities, known as “business associates,” must sign a written agreement with APMG to appropriately safeguard your PHI.

As Required by Law
We may use or disclose your PHI for various public policy purposes that are authorized or required by federal or state law. We are required to disclose your PHI to the Secretary of the U.S. Department of Health and Human Services upon request. We must provide you with copies of your PHI at your request, except where restricted or prohibited by state law.

Public Safety
When appropriate we may use or disclose PHI to prevent or lessen a serious and imminent threat to health or safety of a person or the public.

Public Health
We may disclose your PHI when reporting communicable disease results to public health departments as required by law. This includes gonorrhea results. We may disclose your PHI for FDA reporting purposes.

Health Oversight
Various governmental agencies periodically review our records to ensure that APMG is complying with the rules and regulations of licensing agencies. These include CMS (Centers for Medicare and Medicaid), HHS, State of California Department of Laboratory Field Services and others.

Judicial and Administrative Proceedings
We may disclose your PHI to comply with court orders, discovery requests or other legal process in the case of judicial or administrative proceedings.

Law Enforcement
We may also disclose your PHI for law enforcement purposes. For example, we may be required to release PHI to comply with a court order, judicial subpoena, court-ordered warrant, grand jury subpoena, administrative request or other investigative process. This happens only if efforts have been made to inform you of the request. We may also obtain an order of protection of the requested PHI.

National Security, Military and Protective Services
APMG may release your PHI to authorized federal officials. This is to enable them to conduct intelligence, counterintelligence, or other national security activities. Also to provide protection to the members of the U.S. government or foreign state, or to conduct special investigations.

Your Rights Regarding Your PHI

Access
You or your authorized personal representative have the right to inspect and copy your PHI. To inspect and copy health information maintained by APMG, submit your request in writing to our Executive Director.

Amendments
You have the right to request amendments. While APMG will consider such a request, we are not required to make requested amendments. Please contact our Executive Director, in writing, should you wish to make such a request.

Right to an Accounting of Disclosures
You have the right to request an “Accounting of Disclosures.” This is a list of the disclosures made by APMG in the preceding six (6) years from the date of your request. To complete a request please contact our Executive Director in writing.

Right to Request Restrictions
You have the right to request a restriction on the use and disclosure of your PHI. While APMG will consider such a request, we are not required to comply with the requested restrictions. Please contact our Executive Director, in writing, should you wish to make such a request.

Right to Request Confidential Communications
You have the right to request APMG communicate with your regarding your PHI using alternative means or at alternative locations. For example, you can ask we send your Explanation of Benefits (EOB) to a specified address. While APMG will attempt to accommodate all reasonable requests, we are not required to guarantee compliance with all requests.

Right to a Paper Copy of this Notice
You have the right to a paper copy of this Notice upon request. Please direct your requests, in writing, to our Executive Director.

Complaints
If you believe your PHI, as described under this Notice, has been violated, you can mail a written complaint to the attention of our Executive Director whose address is listed below. You may also contact the regional office of the U.S. Department of Health and Human Services. The complaint should generally be filed within 180 days of when the act or omission in your complaint occurred. Please Note: You cannot, and will not, be penalized or retaliated against for filing a complaint.

How to Exercise these Rights
All requests must be made in writing to the following address:

Associated Pathology Medical Group, Inc.
Attn: Executive Director
105A Cooper Court
Los Gatos, CA 95032