NOTICE OF PRIVACY - COALITION AMERICA, INC.
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 HEALTH
INFORMATION MAY BE USED AND DISCLOSED, AND
HOW YOU CAN GET ACCESS TO YOUR INDIVIDUALLY
IDENTIFIABLE HEALTH INFORMATION. PLEASE REVIEW
THIS NOTICE CAREFULLY.

A. OUR COMMITMENT TO YOUR PRIVACY
Coalition America is dedicated to maintaining the privacy of your protected health information (PHI). In conducting our business, we will create records regarding you and the treatment and services we provide to you. We are required by law to maintain the confidentiality of health information that identifies you. We also are required by law to provide you with this notice of our legal duties and the privacy practices that we maintain in Coalition America concerning your PHI. By federal and state law, we must follow the terms of the notice of privacy that we have in effect at the time.

We realize that these laws are complicated, but we must provide you with the following important information:

• How we may use and disclose your PHI
• Your privacy rights in your PHI
• Our obligations concerning the use and disclosure of your PHI

The terms of this notice apply to all records containing your PHI that are created or retained by Coalition America. We reserve the right to revise or amend this Notice of Privacy. Any revision or amendment to this notice will be effective for all of your records that Coalition America has created or maintained in the past, and for any of your records that we may create or maintain in the future. Coalition America will post a copy of our current Notice in our office in a visible location at all times, and you may request a copy of our most current Notice at any time.

B. IF YOU HAVE QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT:
Coalition America

C. WE MAY USE AND DISCLOSE YOUR INDIVIDUALLY IDENTIFIABLE HEALTH INFORMATION (PHI) IN THE FOLLOWING WAYS
The following categories describe the different ways in which we may use and disclose your PHI.
1. Payment. Coalition America may use and disclose your PHI in order to bill and collect payment for the services and items received. For example, we may contact your health insurer to certify that you are eligible for benefits (and for what range of benefits), and we may provide your insurer with details regarding your treatment to determine if your insurer will cover, or pay for, your treatment. We also may use and disclose your PHI to obtain payment from third parties that may be responsible for such costs, such as family members. Also, we may use your PHI to bill you directly for services and items.
2. Health Care Operations. Coalition America may use and disclose your PHI to operate our business. As examples of the ways in which we may use and disclose your information for our operations, Coalition America may use your PHI to evaluate the quality of care you received from us, or to conduct cost-management and business planning activities for Coalition America.
3. Appointment Reminders. Coalition America may use and disclose your PHI to contact you and remind you of an appointment.
4. Treatment Options. Coalition America may use and disclose your PHI to inform you of potential treatment options or alternatives.
5. Health-Related Benefits and Services. Coalition America may use and disclose your PHI to inform you of health-related benefits or services that may be of interest to you.
6. Release of Information to Family/Friends. Coalition America may release your PHI to a friend or family member that is involved in your care, or who assists in taking care of you. For example, a parent or guardian may ask that a baby-sitter take their child to the pediatrician's office for treatment of a cold. In this example, the baby-sitter may have access to this child's medical information.
7. Disclosures Required By Law. Coalition America will use and disclose your PHI when we are required to do so by federal, state or local law.

D. USE AND DISCLOSURE OF YOUR PHI IN CERTAIN SPECIAL
CIRCUMSTANCES
The following categories describe unique scenarios in which we may use or disclose your identifiable health information:
1. Public Health Risks. Coalition America may disclose your PHI to public health authorities that are authorized by law to collect information for the purpose of:

• maintaining vital records, such as births and deaths
• reporting child abuse or neglect
• preventing or controlling disease, injury or disability
• notifying a person regarding potential exposure to a communicable disease
• notifying a person regarding a potential risk for spreading or contracting a disease or condition
• reporting reactions to drugs or problems with products or devices
• notifying individuals if a product or device they may be using has been recalled
• notifying appropriate government agency (ies) and authority (ies) regarding the potential abuse or neglect of an adult patient (including domestic violence); however, we will only disclose this information if the patient agrees or we are required or authorized by law to disclose this information
• notifying your employer under limited circumstances related primarily to workplace injury or illness or medical surveillance

2. Health Oversight Activities. Coalition America may disclose your PHI to a health oversight agency for activities authorized by law. Oversight activities can include, for example, investigations, inspections, audits, surveys, licensure and disciplinary actions; civil, administrative, and criminal procedures or actions; or other activities necessary for the government to monitor government programs, compliance with civil rights laws and the health care system in general.
3. Lawsuits and Similar Proceedings. Coalition America may use and disclose your PHI in response to a court or administrative order, if you are involved in a lawsuit or similar proceeding.
We also may disclose your PHI in response to a discovery request, subpoena, or other lawful process by another party involved in the dispute, but only if we have made an effort to inform you of the request or to obtain an order protecting the information the party has requested.
4. Law Enforcement. We may release PHI if asked to do so by a law enforcement official:

• Regarding a crime victim in certain situations, if we are unable to obtain the person's agreement
• Concerning a death we believe has resulted from criminal conduct
• Regarding criminal conduct at our offices
• In response to a warrant, summons, court order, subpoena or similar legal process
• To identify/locate a suspect, material witness, fugitive or missing person
• In an emergency, to report a crime (including the location or victim(s) of the crime, or the description, identity or location of the perpetrator)

5. Serious Threats to Health or Safety. Coalition America may use and disclose your PHI when necessary to reduce or prevent a serious threat to your health and safety or the health and safety of another individual or the public. Under these circumstances, we will only make disclosures to a person or organization able to help prevent the threat.
6. Military. Coalition America may disclose your PHI if you are a member of U.S. or foreign military forces (including veterans) and if required by the appropriate authorities.
7. National Security. Coalition America may disclose your PHI to federal officials for intelligence and national security activities authorized by law. We also may disclose your PHI to federal officials in order to protect the President, other officials or foreign heads of state, or to conduct investigations.
8. Inmates. Coalition America may disclose your PHI to correctional institutions or law enforcement officials if you are an inmate or under the custody of a law enforcement official. Disclosure for these purposes would be necessary: (a) for the institution to provide health care services to you, (b) for the safety and security of the institution, and/or (c) to protect your health and safety or the health and safety of other individuals.
9. Workers' Compensation. Coalition America may release your PHI for workers' compensation and similar programs.

E. YOUR RIGHTS REGARDING YOUR PHI
You have the following rights regarding the PHI that we maintain about you:
1. Confidential Communications. You have the right to request that Coalition America communicate with you about your health and related issues in a particular manner or at a certain location. In order to request a type of confidential communication, you must make a written request to Coalition America specifying the requested method of contact, or the location where you wish to be contacted. Coalition America will accommodate reasonable requests. You do not need to give a reason for your request.
2. Requesting Restrictions. You have the right to request a restriction in our use or disclosure of your PHI for treatment, payment or health care operations. Additionally, you have the right to request that we restrict our disclosure of your PHI to only certain individuals involved in your care or the payment for your care, such as family members and friends. We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you. In order to request a restriction in our use or disclosure of your PHI, you must make your request in writing to Coalition America. Your request must describe in a clear and concise fashion:

1. the information you wish restricted
2. whether you are requesting to limit Coalition America use, disclosure or both and
3. to whom you want the limits to apply

3. Inspection and Copies. You have the right to inspect and obtain a copy of the PHI that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes. You must submit your request in writing to Coalition America in order to inspect and/or obtain a copy of your PHI. Coalition America, Inc. may charge a fee for the costs of copying, mailing, labor and supplies associated with your request. Coalition America may deny your request to inspect and/or copy in certain limited circumstances; however, you may request a review of our denial. Another licensed health care professional chosen by us will conduct reviews.
4. Amendment. You may ask us to amend your health information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for Coalition America. To request an amendment, your request must be made in writing and submitted to Coalition America. You must provide us with a reason that supports your request for amendment. Coalition America 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 PHI kept by or for Coalition America; (c) not part of the PHI which you would be permitted to inspect and copy; or (d) not created by Coalition America, unless the individual or entity that created the information is not available to amend the information.
5. Accounting of Disclosures. All of our patients have the right to request an accounting of disclosures. An accounting of disclosures is a list of certain non-routine disclosures Coalition America has made of your PHI for non-treatment or operations purposes. Use of your PHI as part of the routine patient care in Coalition America is not required to be documented. For example, the doctor sharing information with the nurse; or the billing department using your information to file your insurance claim. In order to obtain an accounting of disclosures, you must submit your request in writing. 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. The first list you request within a 12-month period is free of charge, but Coalition America may charge you for additional lists within the same 12-month period. Coalition America will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.
6. Right to a Paper Copy of This Notice. You are entitled to receive a paper copy of our notice of privacy Coalition America. You may ask us to give you a copy of this notice at any time. To obtain a paper copy of this notice, contact Coalition America.
7. Right to File a Complaint. If you believe your privacy rights have been violated, you may file a complaint with Coalition America or with the Secretary of the Department of Health and Human Services. To file a complaint with Coalition America, contact Coalition America . All complaints must be submitted in writing. You will not be penalized for filing a complaint.
8. Right to Provide an Authorization for Other Uses and Disclosures. Coalition America will obtain your written authorization for uses and disclosures that are not identified by this notice or permitted by applicable law. Any authorization you provide to us regarding the use and disclosure of your PHI may be revoked at any time in writing. After you revoke your authorization, we will no longer use or disclose your PHI for the reasons described in the authorization. Please note: we are required to retain records of your care.

Again, if you have any questions regarding this notice or our health information privacy policies, please contact Coalition America .

RepriceNow and HIPAA
According to Arnall, Golden and Gregory, LLP
HIPAA imposes standard file formats for many healthcare transactions. RepriceNow does not currently involve an exchange of healthcare information under the ten HIPAA regulated EDI transactions. RepriceNow involves the transmission of an EOB from a business associate (CAI) to a health plan. The regulated transmission is between a health plan and a healthcare provider. That the health plan later transmits the EOB to a provider has no legal bearing on RepriceNow for purposes of HIPAA's Transactions and Code Sets Rule, as CAI is not itself transmitting the information to a provider on behalf of the plan.
Therefore, the health plans that submit information to the CAI database via RepriceNow need not standardize the format of their submissions. Further, CAI need not standardize RepriceNow's acceptance of client data, nor the transmittal of a discount price and EOB back to the client. The Transactions and Code Sets Rule does not include a standard related to repricing and the transmission of an EOB from a business associate to a health plan, making any compliance effort meaningless.

However, HIPAA's Privacy Rule and Proposed Security Rule would apply to the protected health information used, disclosed and maintained by CAI's RepriceNow product. CAI's clearinghouse functions will cause CAI to be a covered entity for purposes of HIPAA. As such, CAI must protect the health information that it uses, discloses and maintains in accordance with the Privacy Rule and the Security Rule (once finalized).