THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

BHC is committed to maintaining the confidentiality of your information. The purpose of this notice is to inform you of how BHC may use and disclose your Personal Health Information (referred to in this notice as "personal information"). BHC is required by law to maintain the privacy of your personal information and to provide you with notice of BHC's legal duties and privacy practices. BHC will abide by the terms set forth in this notice.

Why do we collect your personal information? We collect personal information to ensure that you receive all the quality services covered by your EAP plan.

How do we protect your personal information? We go to great lengths to protect your personal information as required by state and federal law. We provide training to our employees to enable them to strictly adhere to our privacy policies and practices.

How do we use and disclose your personal information? We don't use or disclose your personal information unless you give us authorization to do so, except as permitted or required by state and federal law in the situations listed below:

• Treatment: We may use and disclose your personal information for our treatment activities such as providing counseling services, contacting you to provide appointment reminders, or coordinating your care. If we refer you to another service provider, we may need to contact that provider to discuss your care and coordinate your treatment.
• Payment: When a sub/affiliate service provider bills BHC for services, we will evaluate the claim for payment. If BHC is not responsible for payment, we will notify the provider of the denial. With certain plans, your personal information may be used to obtain reimbursement for the services you receive.
• Health Care Operations: We may use and disclose your personal information for our internal operations. Only BHC employees, required by their job duties, or authorized agents of BHC will access your personal information and will do so only for such purposes as: processing records into our confidential database, scheduling appointments, supervising BHC employees, assuring quality, and analyzing the integrity of our data etc.
• Coordination of EAP Referrals with Health Plans: BHC acts as the "gateway" to the behavioral healthcare benefits of some employer health plans. If your health plan design requires an EAP referral from BHC to optimize your reimbursement for treatment by a non-EAP provider, we will coordinate our referral with your health plan or your network care coordinator and disclose to them all necessary information related to your condition, care, and treatment.
• Utilization Reports: BHC provides its client organizations with a quarterly utilization report which summarizes, in a statistical format, the services provided to employees and dependents during the reporting period. This report does not contain the names or any other reasonably identifying information of those receiving services and is used by client organizations merely to verify that they are receiving valuable services for the money they are spending to make the EAP available to their employees. In certain limited situations, outside auditors may gather information to track the quality, cost-effectiveness and trends of the services BHC provides.
• Disclosures Required by Law: There are limited situations when we are permitted or required to disclose health information without your signed authorization. By law, counselors have a duty to report victims of abuse, neglect or domestic violence, the intention to harm self or others, or (in some states) the presence of certain communicable diseases. Counselors may also be required to disclose personal information for health oversight activities such as investigations, audits, and inspections; for lawsuits and similar proceedings; for law enforcement purposes; for workers' compensation or other similar programs if you are injured at work; and for specialized government functions such as intelligence and national security.

What are your rights regarding the use and disclosure of your personal information?

• You have a right to inspect or receive a copy of the personal information contained in your clinical record. This right is limited and does not include the right to view or to obtain copies of psychotherapy notes. By law, we may also limit your access to your clinical record if we determine that providing the information could possibly harm you or another person. However, you have the right to request a review of that decision.
• You may also request that your information be amended, however, BHC is not obligated to amend its records if we believe the requested amendment to be inaccurate.
• You have the right to request additional restrictions on our use or disclosure of your personal information. We may be unable to agree to your requested restriction. If we do, we'll abide by our agreement (except as necessary to handle an emergency).
• You have a right to receive a paper copy of this notice should you request it.
• You have a right to request an accounting of disclosures for purposes other than for treatment, payment, or health care operations. You are entitled to such an accounting for the 6 years prior to your request for all disclosures made after April 14, 2003.
• You may revoke your authorization at any time with a written statement.
• You may request limits to where and how you are contacted. Occasionally, a BHC employee will have need to contact you to reschedule or remind you of appointments, coordinate treatment, or follow-up with your progress etc. If you desire to limit where or when you may be contacted, please specify so with your counselor. Additionally, BHC sends follow-up and quality assurance letters to individuals who receive our services. If you would prefer not to receive the follow-up letter, or would like it to be sent to a different address, please specify so with your counselor.

What if you are concerned that your privacy rights have been violated? If you feel BHC has violated your confidentiality rights, you may file a complaint by contacting either our privacy officer or Brent Hale, Ph.D. at 1-800-926-9619. Your privacy is one of our greatest concerns and there is never a penalty to you if you choose to file a complaint with us or with the U.S. Department of Health and Human Services.

When is this notice effective and can it ever change? The effective date of this privacy notice is April 14, 2003. We reserve the right to change our privacy practices and the terms of this notice at any time.