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Privacy Policy

Purpose

To ensure that EOM Healthcare Group (the “Company”) and any and all owners, directors, officers, clinical staff, employees, independent contractors, consultants, and others currently or potentially working for the Company (“Associates”) comply with applicable laws that grant residents or a resident’s legal representative (collectively referred to herein as the “resident”) the right to adequate notice of the uses and disclosures of the resident’s protected health information (“PHI”)

Policy

It is the policy of the Company that individuals have the right to adequate notice of the uses and disclosures of their PHI, for as long as the PHI is maintained by the Company.

Procedure

I. NOTICE OF USE AND DISCLOSURE

A. Provision of Notice

The Compliance and Ethics Officer shall approve a Notice of Privacy Practices (the “Notice”) acceptable under State and Federal law to be provided to each resident: (i) prior to the time of first service delivery when the individual executes the Notice of Privacy Practices Acknowledgment Form; (ii) in an emergency treatment situation, as soon as is reasonably practicable after the emergency treatment situation, or (iii) upon request of a resident.

B. Web Site Notice

If the Company maintains a website containing information about the Company’s customer service or benefits, it shall make the Notice available electronically through the website.

C. Posting of Notice

The Company shall post the Notice in a clear and prominent location where residents will be able to read the Notice. The Company shall make copies of the Notice available for individuals to take with them.

II. ACKNOWLEDGEMENT

Except in an emergency, the Company shall make a good faith effort to obtain a written acknowledgment of receipt of the Notice. If no acknowledgment can be obtained, the Company shall document its efforts and the reasons why acknowledgment was not obtained. In emergency treatment situations, acknowledgment shall be obtained from the individual as soon as reasonably practical.

III. REVISIONS TO NOTICE

The Compliance and Ethics Officer must promptly revise and distribute to residents the Notice whenever there is a material change to the uses and disclosures of PHI, changes in residents’ rights or the Company’s duties, or other privacy practices stated in the Notice. Thereafter, the revised Notice shall be utilized when providing the Notice to an individual.

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