Patient Privacy ("HIPAA")
NOTICE OF HOLLISTER-STIER PHARMACY PRIVACY PRACTICES

This notice describes how medical information about patients may be used and disclosed and how patients can get access to this information.

Please read the information provided carefully. These procedures are in compliance with the Health Insurance Portability and Accountability Act ("HIPAA").

Hollister-Stier Pharmacy is required by law to maintain the privacy of Protected Health Information ("PHI") and to provide you with notice of our legal duties and privacy practices with respect to PHI. PHI is information that may identify you and that relates to your past, present or future physical or mental health or condition and related health care services.

Your Doctor will ask you to sign an Acknowledgment that you have received this Notice of Privacy Practices ("Notice"). This Notice describes how Hollister-Stier may use and disclose your protected health information (PHI), in accordance with the HIPAA Privacy Regulation, to carry out prescribed treatment, payment or health care operations, and for other specific purposes that are permitted or required by law. Some of the uses and disclosures described in this Notice may be limited in certain cases by applicable state laws that place further restrictions on the disclosure of your health information than the federal standards. The Notice also describes your rights with respect to your PHI. We are required to provide this notice to you by the Health Insurance Portability and Accountability Act ("HIPAA").

Your Health Information - Electronic Storage
To provide you with safe and convenient pharmacy services, we need to obtain and use your health information. Without your health information, we would be unable to fill your prescriptions. Hollister-Stier will store information provided by you in our computer system. That information will include your name, address, phone number, date of birth, and other identifying information particular to you. In addition, any information that you provide concerning drugs that you are taking, medical conditions you may have, allergies, and other matters affecting your health will be stored in our computer.

Protection of Personal Information
The protection of your personal information is important to us. For example, we authorize individuals to access your personal information only to the extent necessary to conduct routine business functions such as claims payment. We have secure building access and electronic systems that are only used by employees who have authorized access. We train our employees on our written confidentiality policy and procedures. Should an employee violate our policy and procedures, he or she is subject to immediate disciplinary action.

Our privacy policy and practices apply to both current and former clients, so you can be assured that we will protect the confidentiality of your information even if you no longer fill prescriptions with us.
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Effective Date
This Notice is effective as of April 14, 2003. 

Your Health Information Rights
You have the following rights with respect to PHI about you:
1. Obtain a paper copy of the Notice upon request. You may request a copy of the Notice at any time. Even if you have agreed to receive the Notice electronically, you are still entitled to a paper copy. You may obtain a paper copy by calling Hollister-Stier Pharmacy Customer Service at 1-800-992-1120, or by downloading a copy from our website: http://www.hollister-stier.com.

2. Request a restriction on certain uses and disclosures of PHI. You have the right to request additional restrictions on our use or disclosure of PHI about you for treatment, payment, health care operations, communication with individuals involved in your care or by our Business Associates by submitting a written request for the restriction. Please submit your request by mail to the following address:

Attn: Pharmacy Privacy Officer
Hollister-Stier Pharmacy
Tapio Center - Suite 225
Turquoise Flag Bldg.
104 S. Freya St.
Spokane, WA 99202

Please be aware that we may not be able to agree to your requested limitation if it results in our not being able to provide health care products and services to you, or if we are required to use and disclose the PHI under federal or state law. All requests for limitations on the use and disclosure of your PHI must be submitted to our Pharmacy Privacy Officer in writing.

3. Inspect and obtain a copy of PHI. You have the right to access and copy PHI about you contained in a designated record set for as long as we maintain the PHI. The designated record set usually will include prescription and billing records. To inspect or copy PHI about you, you must send a written request. Please submit your request by mail to the following address:

Attn: Pharmacy Privacy Officer
Hollister-Stier Pharmacy
Tapio Center - Suite 225
Turquoise Flag Bldg.
104 S. Freya St.
Spokane, WA 99202

We may charge you a fee for the costs of copying, mailing and supplies that are necessary to fulfill your request. We may deny your request to inspect and copy in certain limited circumstances. If you are denied access to PHI about you, you may request that the denial be reviewed.

4. Request an amendment of PHI. If you believe that PHI we maintain about you is incomplete or incorrect, you may request that we amend it. You may request an amendment for as long as we maintain the PHI. To request an amendment, you must send a written
request to:

Attn: Pharmacy Privacy Officer
Hollister-Stier Pharmacy
Tapio Center - Suite 225
Turquoise Flag Bldg.
104 S. Freya St.
Spokane, WA 99202

You must include a reason that supports your request. In certain cases, we may deny your request for amendment. If we deny your request for amendment, you have the right to file a statement of disagreement with the decision and we may give a rebuttal to your statement.

5. Receive an accounting of disclosures of PHI. You have the right to receive an accounting of the disclosures we have made of PHI about you after April 14, 2003 for most purposes other than treatment, payment, or health care operations. The accounting will exclude certain disclosures, such as disclosures made directly to you, disclosures you authorize, disclosures to friends or family members involved in your care, and disclosures for notification purposes. The right to receive an accounting is subject to certain other exceptions, restrictions, and limitations. To request an accounting, you must submit a request in writing to:

Attn: Pharmacy Privacy Officer
Hollister-Stier Pharmacy
Tapio Center - Suite 225
Turquoise Flag Bldg.
104 S. Freya St.
Spokane, WA 99202

Your request must specify the time period, but may not be longer than six years. The first accounting you request within a 12 month period will be provided free of charge, but you may be charged for the cost of providing any additional accountings in the same 12 month period. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time.

6. Request communications of PHI by alternative means or at alternative locations. For instance, you may request that we contact you about medical matters only in writing or at a different residence address or post office box. To request confidential communication of PHI about you by an alternative means or at an alternative location, you must submit a request in writing to:

Attn: Pharmacy Privacy Officer
Hollister-Stier Pharmacy
Tapio Center - Suite 225
Turquoise Flag Bldg.
104 S. Freya St.
Spokane, WA 99202

Your request must state how or where you would like to be contacted. We will accommodate all reasonable requests. 

HOW WE MAY USE YOUR PHI

1. FOR TREATMENT
We will use your health care information to treat you. For example, we will use health care information to :

• Review and interpret your prescriptions.
• Screen your prescriptions to make sure the prescribed medications are safe for you.
• Contact your physician to resolve questions about your prescriptions.
• Refill your prescriptions when you ask us to do so.
• Notify you of drug recalls or other problems with your medications

2. FOR PAYMENT
We will use your health care information to receive payment for products and services. For example, we may:

• Bill you for your prescriptions.
• Contact your third party payor (for example, your insurance company or pharmaceutical benefits manager) to check your co-payment amount.
• Check to see if specific medications are covered under your plan.
• Provide your health plan, insurance provider, or its agents with the health information they need to pay us for the medications we dispense, and so that they may otherwise manage your prescription benefit.The information on or accompanying the bill may include your identification, as well as the prescriptions you are taking.

3. FOR HEALTH CARE OPERATIONS
We will use your PHI to carry out health care operations. For example, we may use information in your health record to:

• Monitor and evaluate the performance of our pharmacists.
• Train our pharmacy personnel.
• Collect medical history and drug allergy information from you.
• Communicate with you regarding the status of your prescriptions.
• Provide customer service.
• Review and resolve grievances.

This information will be used in an effort to continually improve the quality and effectiveness of the pharmacy and health care services that we provide.

We may disclose health information to business associates if they need to receive this information to provide a service to us and will agree to abide by specific HIPAA rules relating to the protection of health information.

OTHER REQUIRED OR PERMITTED DISCLOSURES OF PHI

We may disclose your health care information to the following entities and/or under given circumstances:

• to the Food and Drug Administration (FDA) relative to adverse events regarding drugs, foods, supplements, and other health products or to post marketing surveillance to enable product recalls, repairs, or replacement;
• to Public Health or legal authorities charged with preventing or controlling disease, injury, or disability. For example, we may use or disclose your PHI when necessary to prevent a serious threat to your health and/or to the health and safety of others.
• Worker's compensation: We may disclose PHI about you as authorized by and as necessary to comply with laws relating to worker's compensation or similar programs established by law.
• Law Enforcement
  Under certain conditions, we may disclose your PHI to law enforcement officials. For example, some reasons may include:
  (1) when required by law or some other legal process,
  (2) when necessary to locate or identify a suspect, fugitive, material witness, or missing person, or;
  (3) when necessary to provide evidence of a crime that occurred on our premises.
• As Required by Law. We will disclose your PHI when required to do so by federal, state, or local law.
• For Health Oversight Activities. We may disclose your PHI to an oversight agency for activities authorized by law. These Health Oversight Activities may include audits, investigations, inspections, and credentialing, as necessary for licensure and for the government to monitor the health care system, government programs, and compliance with civil rights laws.
• For Judicial and Administrative Proceedings. If you are involved in a lawsuit or a dispute, we may be required by law to disclose your PHI in response to a court or administrative order. We may also disclose health information about you in response to a subpoena, discovery request, or other lawful process instituted by someone else involved in the dispute, but only if efforts have been made, either by the requesting party or us, to tell you about the request or to obtain an order protecting the information requested.
• For Research. We may disclose your PHI to researchers when their research has been approved by an institutional review board or privacy board that has reviewed the research proposal and established protocols to ensure the privacy of your information;
• To Coroners, Medical Examiners, and Funeral Directors: We may release PHI about you to a coroner or medical examiner. This may be necessary, for example, to identify a deceased person, determine the cause of death or other duties as authorized by law. We may also disclose PHI to funeral directors, consistent with applicable law, to carry out their duties.
• To Organ or Tissue Procurement Organizations. Consistent with applicable law, we may disclose your PHI to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of organs for the purpose of tissue donation and transplant.
• Notification: We may use or disclose your PHI to notify, or assist in notifying a family member, personal representative, or another person responsible for your care, regarding your location and general condition.
• Fundraising: We may contact you as part of a fundraising effort.
• Correctional Institution. If you are or become an inmate of a correctional institution, we may disclose to the institution or its agents PHI necessary for your health, and the health and safety of others.
• To Avert a Serious Threat to Health or Safety. We may use and disclose your PHI when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.
• Military and Veterans. If you are a member of the armed forces, we may release PHI about you as required by military command authorities. We may also release PHI about foreign military personnel to the appropriate foreign military authority.
• For National Security, Intelligence Activities, and Protective Services for the President and Others. We may release PHI about you to federal officials for intelligence, counterintelligence, for the protection to the President, and for other national security activities authorized by law;
• In Cases of Victim Abuse or Neglect. We may disclose PHI about you to a government authority if we reasonably believe you are a victim of abuse or neglect. We will only disclose this type of information to the extent required by law, if you agree to the disclosure, or if the disclosure is allowed by law and we believe it is necessary to prevent serious harm to you or someone else.
• Other Uses and Disclosure of PHI. We will obtain your written authorization before using or disclosing your PHI for purposes other than those provided for above (or as otherwise permitted or required by law). You may revoke an authorization in writing at any time. Upon receipt of the written revocation, we will stop using or disclosing your PHI, except to the extent that we have already taken action in reliance on the authorization. 

Hollister-Stier Pharmacy may also share health information with:

• You: We are permitted to disclose your health information to you. For example, we may inform you of the status of your prescription order or we may contact you to provide refill reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.
• Family members and others involved in your care: In certain circumstances, we are permitted to disclose your PHI to family members, a close personal friend, or any other person. We may disclose to a family member, other relative, close personal friend or any other person you identify, PHI directly relevant to that person's involvement in your care or payment related to your care. For example: If a family member calls a customer service representative on your behalf, we may provide the family member with information about your prescriptions, but only if he or she is able to give us certain information about you; for example, your prescription number.
  
  We may provide you or those person(s) identified by you, with an annual Patient Profile Report if you request one for tax purposes. We may release information to parents or guardians as allowed by law.
  
  For More Information or to Report a Problem
  If you have questions or would like additional information about Hollister-Stier's Privacy Practices, you may call Hollister-Stier Pharmacy Customer Service at 1-800-992-1120 or write to:
  
  Attn: Pharmacy Privacy Officer
  Hollister-Stier Pharmacy
  Tapio Center - Suite 225
  Turquoise Flag Bldg.
  104 S. Freya St.
  Spokane, WA 99202
  
  If you believe your privacy rights have been violated, you can file a complaint with our Privacy Officer or with the Secretary of Health and Human Services. There will be no retaliation for filing a complaint. 

Version 1.0
Effective April 14, 2003