HIPAA Notice of Privacy

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

Effective May 20, 2026.

PLEASE REVIEW IT CAREFULLY.

This Notice pertains to Synchrony Pharmacy (if elected as your pharmacy). Synchrony Pharmacy (referred to as “Campus”) is required by law to provide you with this Notice so that you will understand how we may use or share your information from your Designated Record Set. The Designated Record Set includes financial and health information referred to in this Notice as “Protected Health Information” (PHI) or simply “health information.” We are required by law to maintain the privacy of your PHI and to provide you with this Notice of our legal duties and privacy practices. If you have any questions about this Notice, please contact the Executive Director.

How We May Use and Disclose Protected Health Information About You

The following categories describe the ways that we use and disclose health information. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall into one of the categories.

For Treatment

We may use or disclose health information about you to provide you with medical treatment. We may disclose health information about you to doctors, nurses, therapists or other Campus personnel who are involved in taking care of you at a Campus. For example, a doctor treating you for a broken leg may need to know if you have diabetes because diabetes may slow the healing process. In addition, the doctor may need to tell the dietitian if you have diabetes so that we can plan your meals. Different departments of a Campus also may share health information about you in order to coordinate your care and provide you medication, lab work and x-rays. We may also disclose health information about you to people outside the Campus who may be involved in your medical care after you leave a Campus. decisions when authorizing disclosure to others

For Payment

We may use and disclose health information about you so that the treatment and services you receive at a Campus may be billed to you, an insurance company or a third party. For example, in order to be paid, we may need to share information with your health plan about services provided to you. We may also tell your health plan about a treatment you are going to receive to obtain prior approval or to determine whether your plan will cover the treatment.

For Health Care Operations

We may use and disclose health information about you for our day-to-day health care operations. This is necessary to ensure that all Residents receive quality care. For example, we may use health information for quality assessment and improvement activities and for developing and evaluating clinical protocols. We may also combine health information about many Residents to help determine what additional services should offer. what services should be discontinued, and whether certain new treatments are effective. Health information about you may be used by our corporate office for business development and planning, cost management analyses, insurance claims management, risk management activities, and in developing and testing information systems and programs. We may also use and disclose information for professional review, performance evaluation, and for training programs. Other aspects of health care operations that may require use and disclosure of your health information include accreditation, certification. licensing and credentialing activities, review and auditing, including compliance reviews. medical reviews, legal services and compliance programs. Your health information may be used and disclosed for the business management and general activities of the Campus including resolution of internal grievances, customer service and due diligence in connection with a sale or transfer of the Campus. In limited circumstances, we may disclose your health information to another entity subject to HIPAA for its own health care operations.

Other Allowable Uses of Your Health Information

Business Associates

There are some services provided in our Campus through contracts with business associates. Examples include medical directors; outside attorneys and a copy service we use when making copies of your health record. When these services are contracted, we may disclose your health information so that they can perform the job we have asked them to do and bill you or your third-party payer for services rendered. To protect your health information, however, we require the business associate to appropriately safeguard your information.

Providers

Many services provided to you, as part of your care at our Campus, are offered by participants in one of our organized healthcare arrangements (OHCA). These participants include a variety of providers such as physicians (e.g., MD, DO, Podiatrist, Dentist, Optometrist), therapists (e.g., Physical therapist, Occupational therapist. Speech therapist), portable radiology units, clinical labs, hospice caregivers, pharmacies, psychologists, LCSW’s, and suppliers (e.g., prosthetic, orthotics).

Treatment Alternatives

We may use and disclose health information to tell you about possible treatment options or alternatives that may be of interest to you.

Health-Related Benefits and Services and Reminders

We may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that maybe of interest to you, unless you ask us, in writing, not to contact you for these purposes.

Fundraising Activities

We may use certain health information about you to contact you in an effort to raise money as part of a fund raising effort. We may disclose certain health information to a foundation related to the Campus so that the foundation may contact you in raising money for the Campus. We will only release contact information, such as your name, address and phone number and the dates you received treatment or services at the Campus. Please note that you always have the right to “opt out” of receiving any future communications and any such decision will have no impact on your treatment or payment for services.

Campus Directory

Unless you object. we may include information about you in the Campus directory while you are a Resident. This information may include your name, location in the Campus, your general condition(e.g., fair, stable, etc.) and your religion. The directory information, except for your religion, may be disclosed to people who ask for you by name. Your religion may be given to a member of the clergy, such as a priest or rabbi, even if they do not ask for you by name. This is so your family, friends and clergy can visit you in the Campus and generally know how you are doing.

Individuals Involved in Your Care or Payment for Your Care

Unless you object, we may disclose health information about you to a friend or family member who is involved in your care. We may also give information to someone who helps pay for your care. In addition, we may disclose health information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status and location. Although you have a right to request reasonable restrictions on these disclosures, we will only be able to grant those restrictions that are reasonable and not too difficult to administer, none of which would apply in the case of an emergency.

As Required or Allowed By law

We will disclose health information about you when required or allowed to do so by federal, state or local law.

To Avert a Serious Threat to Health or Safety

We may use and disclose health information about you to prevent a serious threat to your health and safety or the health and safety of the public or another person. We would do this only to help prevent the threat.

Organ and Tissue Donation

If you are an organ donor, we may disclose health information to organizations that handle organ procurement to facilitate donation and transplantation.

Military and Veterans

If you are a member of the armed forces, we may disclose health information about you as required by military authorities. We may also disclose health information about foreign military personnel to the appropriate foreign military authority.

Research

Under certain circumstances, we may use and disclose health information about you for research purposes. For example, a research project may involve comparing the health and recovery of all Residents who received one medication to those who received another, for the same condition. All research projects, however, are subject to a special approval process. This process evaluates a proposed research project and its use of health information, trying to balance the research needs with Residents’ need for privacy of their health information. Before we use or disclose health information for research, the project will have been approved through this research approval process. We may, however, disclose health information about you to people preparing to conduct a research project so long as the health information they review does not leave a Campus. Any other research will require your written authorization.

Workers’ Compensation

We may disclose health information about you for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.

Reporting

Federal and state laws may require or permit the Campus to disclose certain health information related to the following:

Public Health Risk

We may disclose health information about you for public health purposes, including prevention or control of disease, injury or disability, reporting births and deaths, reporting child abuse or neglect. reporting reactions to medications or problems with products, notifying people of recalls of products, notifying a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease.

Health Oversight Activities

We may disclose health information to a health oversight agency for activities authorized by law. These oversight activities may include audits, investigations, inspections. and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Judicial and Administrative Proceedings

If you are involved in a lawsuit or a dispute, we may disclose health information about you 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 by someone else involved in the dispute. but only if efforts have been made to tell you about the request or to obtain an order protecting the information requested.

Reporting Abuse, Neglect or Domestic Violence

Notifying the appropriate government agency if we believe a Resident has been the victim of abuse, neglect or domestic violence.

Law Enforcement

We may disclose health information when requested by a law enforcement official: In response to a court order, subpoena, warrant, summons or similar process, to identify or locate a suspect, fugitive, material witness. or missing person, about you, the victim of a crime if, under certain limited circumstances, we are unable to obtain your agreement. about a death we believe may be the result of criminal conduct. about criminal conduct at the Campus, and in emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.

Coroners, Medical Examiners and Funeral Directors

We may disclose medical information to a coroner or medical examiner. This may be necessary to identify a deceased person or determine the cause of death. We may also disclose medical information to funeral directors as necessary to carry out their duties.

National Security and Intelligence Activities

We may disclose health information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Correctional Institution

Should you be an inmate of a correctional institution, we may disclose to the institution or its agents health information necessary for your health and the health and safety of others.

Other Uses of Health Information

Other uses and disclosures of health information not covered by this Notice or the laws that apply to us will be made only with your written permission.

Your Rights Regarding Health Information About You

Right to Inspect and Copy

With some exceptions, you have the right to review and copy your health information. A copy may be made available to you either in paper or electronic format if we use an electronic health format. Under federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding; and PHI that is subject to a law prohibiting access. Depending on the circumstances, you may have the right to request a second review if our Privacy Officer denies your request to access your PHI. Please note that you may not inspect or copy your PHI if your physician believes that the access requested is likely to endanger your life or safety or that of another person, or if it is likely to cause substantial harm to another person referenced within the information. As before, you have the right to request a second review of this decision.

Right to Amend

If you feel that health information in your record is incorrect or incomplete, you may ask us to amend the information. You have this right for as long as the information is kept by or for the Campus. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that: was not created by us, unless the person or entity that created the information is no longer available to make the amendment; is not part of the health information kept by or for the Campus; or is accurate and complete. If we deny your request for amendment, you have the right to file a statement of disagreement with us and we may respond to your statement in writing and provide you with a copy.

Right to an Accounting of Disclosures

You have the right to request an “accounting of disclosures”. This is a list of certain disclosures we made of your health information, other than those made for purposes such as treatment, payment, or disclosures to you or pursuant to your written authorization.

Right to Request Restrictions

You have the right to request a restriction or limitation on the health information we use or disclose about you. For example, you may request that we limit the health information we disclose to someone who is involved in your care or the payment for your care. You could ask that we not use or disclose information about a surgery you had to a family member or friend. If you pay for a particular service in full, out-of-pocket. on the date of service, you may ask us not to disclose any related PHI to your health plan. You may also ask us not to disclose your PHI to certain family members or friends who may be involved in your care or for other notification purposes described in this Privacy Notice, or how you would us to communicate with you regarding upcoming appointments, treatment alternatives and the like by contacting you at a telephone number or address other than at home. Please note that we are only required to agree to those restrictions that are reasonable and which are not too difficult for us to administer. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you emergency treatment. Under certain circumstances, we may choose to terminate our agreement to a restriction if it becomes too burdensome to carry out. Finally, please note that it is your obligation to notify us if you wish to change or update these restrictions.

Right to Request Alternate Communications

You have the right to request that we communicate with you about medical matters in a confidential manner or at a specific location. For example, you may ask that we only contact you via mail to a post office box. You should contact our Privacy Officer or Executive Director to exercise any of these rights.

Right to Receive Notice of a Breach

You have the right to receive written notice in the event we learn of any unauthorized acquisition, use or disclosure of your PHI that was not otherwise properly secured as required by HIPAA. We will notify you of the breach as soon as possible but no later than sixty (60) days after the breach has been discovered.

Right to a Paper Copy of This Notice

You have the right to a paper copy of this Notice of Privacy Practices even if you have agreed to receive the Notice electronically. You may ask us to give you a copy of this Notice at any time. You may obtain a copy of this Notice by emailing comply@trilogyhs.com. To obtain a paper copy of this Notice, contact the Executive Director.

Changes to This Notice

We reserve the right to change this Notice. We will post a copy of the current Notice in the Campus and on the website.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with the Campus or with the Secretary of the Department of Health and Human Services.

To file a complaint online go to trilogyhs.ethicspoint.com. You may also file a complaint by calling our hotline at 1-800-908-8618.

You will not be penalized for filing a complaint.