JOINT NOTICE OF PRIVACY PRACTICES

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please read it carefully.

1. Who We Are

   This Notice describes the privacy practices of St. Christopher's Hospital for Children (the "Hospital"), including members of its workforce, the physician members of the medical staff, and allied health professionals who practice at the Hospital. The Hospital and the individual health care providers together are sometimes called "us" or "we" in this Notice. While we engage in many joint activities and provide services in a clinically integrated care setting, we each are separate legal entities. This Notice applies to services furnished to you, the Patient at St. Christopher's Hospital for Children, as a Hospital inpatient or outpatient

2. Our Privacy Obligations

   Each of us is required by law to maintain the privacy of your health information ("Protected Health Information" or "PHI") and to provide you with this Notice of our legal duties and privacy practices with respect to your Protected Health Information. When we use or disclose your Protected Health Information, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).

3. Permissible Uses and Disclosures Without Your Written Authorization

   In certain situations, which we will describe in Section IV below, we must obtain your written authorization in order to use and/or disclose your PHI. However, we do not need any type of authorization from you for the following uses and disclosures:

   1. Uses and Disclosures For Treatment, Payment and Health Care Operations. We may use and disclose PHI, but not your "Highly Confidential Information" (defined in Section IV.C below), in order to treat you, obtain payment for services provided to you and conduct our "health care operations" as detailed below:
   • Treatment: We use and disclose your PHI to provide treatment and other services to you--for example, to diagnose and treat your injury or illness. In addition, we may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you. We may also disclose PHI to other providers involved in your treatment.
   • Payment: We may use and disclose your PHI to obtain payment for services that we provide to you--for example, disclosures to claim and obtain payment from your health insurer, HMO, or other company that arranges or pays the cost of some or all of your health care ("Your Payor") to verify that Your Payor will pay for health care.
   • Health Care Operations: We may use and disclose your PHI for our health care operations, which include internal administration and planning and various activities that improve the quality and cost effectiveness of the care that we deliver to you. For example, we may use PHI to evaluate the quality and competence of our physicians, nurses and other health care workers. We may disclose PHI to our Patient Relations Officer in order to resolve any complaints you may have and ensure that you have a comfortable visit with us.

   We may also disclose PHI to your other health care providers when such PHI is required for them to treat you, receive payment for services they render to you, or conduct certain health care operations, such as quality assessment and improvement activities, reviewing the quality and competence of health care professionals, or for health care fraud and abuse detection or compliance. In addition, we may share PHI with our business associates who perform treatment, payment and health care operations services on our behalf.

   2. Use or Disclosure for Directory of Individuals in the Hospital. We may include your name, location in the Hospital, general health condition and religious affiliation in a patient directory without obtaining your authorization unless you object to inclusion in the directory Information in the directory may be disclosed to anyone who asks for you by name or members of the clergy; provided, however, that your religious affiliation will only be disclosed to members of the clergy.

   3. Disclosure to Relatives, Close Friends and Other Caregivers. We may use or disclose your PHI to a family member, other relative, a close personal friend or any other person identified by you when you are present for, or otherwise available prior to, the disclosure, if we (1) obtain your agreement; (2) provide you with the opportunity to object to the disclosure and you do not object; or (3) reasonably infer that you do not object to the disclosure.

   If you are not present, or the opportunity to agree or object to a use or disclosure cannot practicably be provided because of your incapacity or an emergency circumstance, we may exercise our professional judgment to determine whether a disclosure is in your best interests. If we disclose information to a family member, other relative or a close personal friend, we would disclose only information that we believe is directly relevant to the person's involvement with your health care or payment related to your health care. We may also disclose your PHI in order to notify (or assist in notifying) such persons of your location or general condition.

   4. Public Health Activities. We may disclose your PHI for the following public
      health activities: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to the Pennsylvania Department of Welfare or other public health authorities or other government authorities authorized by law to receive such reports; (3) to report information about products and services under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance.

   5. Victims of Abuse, Neglect or Domestic Violence. If we reasonably believe you are a victim of abuse, neglect or domestic violence, we may disclose your PHI to the Pennsylvania Department of Welfare or other governmental authority, including a social service or protective services agency, authorized by law to receive reports of such abuse, neglect, or domestic violence.

   6. Health Oversight Activities. We may disclose your PHI to a health oversight agency that oversees the health care system and is charged with responsibility for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.

   7. Judicial and Administrative Proceedings. We may disclose your PHI in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

   8. Law Enforcement Officials. We may disclose your PHI to the police or other law enforcement officials as required or permitted by law or in compliance with a court order or a grand jury or administrative subpoena.

   9. Decedents. We may disclose your PHI to a coroner or medical examiner as authorized by law.

   10. Organ and Tissue Procurement. We may disclose your PHI to organizations that facilitate organ, eye or tissue procurement, banking or transplantation.

   11. Research. We may use or disclose your PHI without your consent or authorization as permitted by Pennsylvania law if our Institutional Review Board approves a waiver of authorization for disclosure.

   12. Health or Safety. We may use or disclose your PHI to prevent or lessen a serious and imminent threat to a person's or the public's health or safety as permitted or required by Pennsylvania law.

   13. Specialized Government Functions. We may use and disclose your PHI to units of the government with special functions, such as the U.S. military or the U.S. Department of State under certain circumstances.

   14. Workers' Compensation. We may disclose your PHI as authorized by and to the extent necessary to comply with Pennsylvania law relating to workers' compensation or other similar programs.

   15. As Required by Law. We may use and disclose your PHI when required to do so by any other law not already referred to in the preceding categories.

4. Uses and Disclosures Requiring Your Written Authorization

   1. Use or Disclosure with Your Authorization. For any purpose other than the ones described above in Section III, we only may use or disclose your PHI when you grant us your written authorization on our authorization form (Your Authorization"). For instance, you will need to execute an authorization form before we can send your PHI to your life insurance company or to the attorney representing the other party in litigation in which you are involved.

   2. Marketing. We must also obtain your written authorization ("Your Marketing Authorization") prior to using your PHI to send you any marketing materials. (We can, however, provide you with marketing materials in a face-to-face encounter without obtaining Your Marketing Authorization. We are also permitted to give you a promotional gift of nominal value, if we so choose, without obtaining Your Marketing Authorization.) In addition, we may communicate with you about products or services relating to your treatment, case management or care coordination, or alternative treatments, therapies, providers or care settings without Your Marketing Authorization.

   3. Uses and Disclosures of Your Highly Confidential Information. In addition, federal and state law require special privacy protections for certain highly confidential information about you ("Highly Confidential Information"), including the subset of your PHI that: (1) is maintained in psychotherapy notes~ (2) is about mental illness, mental health and developmental disabilities services; (3) is about alcohol and drug abuse prevention, treatment, and referral; (4) is about HIV/AIDS testing, diagnosis or treatment; (5) is about child abuse and neglect. In order for us to disclose your Highly Confidential Information for a purpose other than those permitted by law, we must obtain your written authorization.

      1. For disclosures of alcohol or drug abuse treatment, such authorization must include at least the following information: (a) name and person, agency or organization to whom disclosure is to be made; (b) specific information to be disclosed; (c) purpose of intended disclosure; (d) dated signature of patient or personal representative (under applicable Pennsylvania law); (e) dated signature of a witness; and (f) expiration date of the authorization.

      2. For disclosures of HIV/AIDS testing, diagnosis or treatment, such authorization must include: (a) specific name or general designation of the person permitted to make the disclosure; (b) name or title of the individual, or the name of the organization to which the disclosure is to made~ (c) name of the subject of the information~ (d) purpose of the disclosure; (e) specific information to be disclosed; (f) signature of the subject; (g) date on which the authorization is signed; (h) a statement that the authorization may be revoked at any time except to the extent that the person making the disclosure already acted in reliance on it; (i) date, event or condition upon which the consent will expire, if not earlier revoked; and G) the following statement, "This information has been disclosed to you from records protected by Pennsylvania law. Pennsylvania law prohibits you from making any further disclosure of this information unless further disclosure is expressly permitted by the written consent of the person to whom it pertains or is authorized by the Confidentiality of HIV-Related Information Act. A general authorization for the release of medical or other information is not sufficient for this purpose."

      3. For disclosures of information that is maintained in psychotherapy notes or is about mental illness, mental health and developmental disabilities, such authorization must include: (a) start and end dates for the authorization; (b) identification of the third party authorized to receive the record; (c) the specific purpose for which the records are to be used; (d) the specific information to be released; (e) a statement that the authorization is revocable at the written request of the person authorizing the disclosure (or at the oral request if the person is physically unable to write); (f) a statement that the person authorizing the release of information to third parties understands the nature of the release and gives his authorization freely; (g) a place for the signature of the patient or personal representative (under applicable Pennsylvania law) providing the authorization and the date of the authorization (immediately below the statement that the authorization was freely given); (h) a place for the signature of the Hospital staff person obtaining authorization and the date authorization was obtained; (i) a place to provide a verbal authorization if the patient or personal representative (under applicable Pennsylvania law) is physically unable to provide a signature and a place for the signatures of two witnesses; and (j) the following statement, "This information has been disclosed to you from records whose confidentiality is protected by State statute. State regulations limit your right to make any further disclosure of this information without prior written consent of the person to whom it pertains."

5. Your Rights Regarding Your Protected Health Information

   1. For Further Information: Complaints. If you desire further information about your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to your PHI, you may contact the Hospital Privacy Office. You may also file written complaints with the Director, Office for Civil Rights of the U.S. Department of Health and Human Services. Upon request, the Hospital Privacy Office will provide you with the correct address for the Director. We will not retaliate against you if you file a complaint with us or the Director.

   2. Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of your PHI (1) for treatment, payment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction. If you wish to request additional restrictions, please obtain a request form from the Hospital Privacy Office and submit the completed form to the Hospital Privacy Office. We will send you a written response.

   3. Right to Receive Confidential Communications. You may request, and we will accommodate, any reasonable written request for you to receive your PHI by alternative means of communication or at alternative locations.

   4. Right to Revoke Your Authorization. You may revoke Your Authorization, Your Marketing Authorization or any written authorization obtained in connection with your Highly Confidential Information, except to the extent that we have taken action in reliance upon it, by delivering a written revocation statement to the Hospital Privacy Office identified below. A form of written revocation is available upon request from the Hospital Privacy Office.

   5. Right to Inspect and Copy Your Health Information. You may request access to your medical record file and billing records maintained by us in order to inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. You should take note that, if you are a parent or legal guardian of a minor, certain portions of the minor's medical record will not be accessible to you (for example, records relating to abortion, treatment or testing for venereal diseases or other reportable diseases, alcohol and drug abuse prevention, treatment, and referral). If you desire access to your records, please obtain a record request form from the Hospital Privacy Office and submit the completed form to the Hospital Privacy Office. If you request copies, we will charge you or your next of kin up to $1 dollar per page for the first 20 pages, up to $0.75 per page for the 21st through the 60th page; and up to $0.25 for any remaining pages of the provided copies. For Microfilm, charges for producing records under a subpoena can be up to $1.50 per page. We will also charge you for our actual postage, shipping or delivery costs, if you request that we mail the copies to you.

   6. Right to Amend Your Records. You have the right to request that we amend Protected Health Information maintained in your medical record file or billing records. If you desire to amend your records, please obtain an amendment request form from the Hospital Privacy Office and submit the completed form to the Hospital Privacy Office. We will comply with your request unless we believe that the information that would be amended is accurate and complete or other special circumstances apply.

   7. Right to Receive An Accounting of Disclosures. Upon request, you may obtain an accounting of certain disclosures of your PHI made by us during any period of time prior to the date of your request provided such period does not exceed six years and does not apply to disclosures that occurred prior to April 14, 2003. If you request an accounting more than once during a twelve (12) month period, we will charge you $1.00 per page of the accounting statement.

   8. Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice, even if you have agreed to receive such notice electronically.

6. Effective Date and Duration of This Notice

   1. Effective Date. This Notice is effective on April 14, 2003.

   2. Right to Change Terms of this Notice. We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all Protected Health Information that we maintain, including any information created or received prior to issuing the new notice. If we change this Notice, we will post the new notice in waiting areas around the Hospital and on our Internet site at www.stchristophershospital.com. You also may obtain any new notice by contacting the Hospital Privacy Office.

7. Hospital Privacy Office

   You may contact the Hospital Privacy Office at:
   Hospital Privacy Office
   St. Christopher's Hospital for Children
   3601 A Street
   Philadelphia, PA 19134
   Telephone Number: (215) 427-5340
   E-mail: SCHC-PrivacyOffice@tenethealth.com
   

   Corporate Privacy Office
   Ethics & Compliance Department
   Tenet Healthcare Corporation
   1445 Ross Avenue.Suite 1400
   Dallas, TX 75202
   E-mail: PrivacySecurityOffice@tenethealth.com
   Ethics Action Line (EAL): 1-800-8-ETHICS