THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU (AS A PATIENT OF THIS PRACTICE) MAY BE USED AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

WHO WILL FOLLOW THIS NOTICE

This Notice describes Caduceus Privacy Practices and that of:

• all employees;
• all medical staff; and
• other of Caduceus' personnel.

OUR COMMITMENT TO YOUR PRIVACY

Caduceus Corporation (the "Practice") 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;
• provide you with this Notice of our legal duties and Privacy Practices;
• follow the terms of this Notice currently in effect.

The terms of this Notice apply to all records containing your PHI that are created or retained by our Practice. We reserve the right to revise or amend this Notice. Any revision or amendment to this Notice will be effective for all of your records that our Practice has created or maintained in the past, and for any of your records that we may create or maintain in the future. Our Practice will post a copy of our current Notice in our offices in a visible location at all times, and you may request a copy of our most current Notice at any time. The Notice will contain on the first page, in the top right hand corner, the effective date.

IF YOU HAVE QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT:

Karen Merlotti, Privacy Officer
Caduceus Corporation, Suite100
11222 Tesson Ferry Road.
St. Louis, MO 63123
314-843-1866
314-843-7484 Fax

WE MAY USE AND DISCLOSE YOUR PROTECTED HEALTH INFORMATION (PHI) IN THE FOLLOWING WAYS

We understand that medical information about you and your health is personal. We are committed to protecting PHI about you. We create a record of the care and services you receive from the Practice. We need this record to provide you with quality care and to comply with certain legal requirements. All reasonable efforts will be made to safeguard your PHI. These Privacy Practices refer to oral, written, and electronic communications. All efforts will be used to minimize the amount of PHI disclosed for any purpose. The following categories describe the different ways in which we may use and disclose your PHI.

For Treatment. We may use your PHI to treat you or to assist others in your treatment. Additionally, we may disclose your PHI to others who may indirectly assist in your care, such as your pharmacy, oxygen equipment supplier or home health agency. An example is when the doctor writes a prescription for you. We may also use and disclose your PHI to inform you of any potential treatment options or alternatives and or health-related benefits or services that may be of interest to you. We may disclose your PHI to others who directly assist in your care such as family members or other physicians.

For Payment. Our Practice may use and disclose your PHI in order to bill and collect payment from you, an insurance company, or a third party for the services and items you may receive from us. An example might be if we call your health insurer to inquire if your benefits include a sleep study (so that the insurer might pay for the test). We may provide your insurer with details of your treatment to determine if your insurer will cover, or pay for, your treatment. This may include 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. We may disclose your PHI to other health care providers and entities to assist in their billing and collection efforts.

For Health Care Operations. Our Practice may use and disclose your PHI to operate our Practice. Some examples of operations include reviews of the quality of care you have received from us, and conducting cost-management and business planning activities for our Practice. Other operations might include use or disclosure of PHI for detection of health care fraud and abuse or to assist with compliance, and for appointment reminders. This also includes the sale, transfer, merger or consolidation of all or part of the Practice to another potential health care entity and involves the due diligence related to the activities listed above. We may disclose PHI to our Practice personnel for learning purposes.

For Release of Information to Family/Friends. We may release PHI about you to a family member or friend who is directly involved in your care. We may tell your family and friends of your location in a hospital and condition. In addition we may disclose PHI about you to an entity assisting in a disaster relief effort so that your family can be notified about your location, status, and condition. If you request we may limit or exclude any and all PHI that will be released to any individual who you specify may or may not receive this information. You need to Contact the Privacy Officer listed above or in each office if you want to limit PHI disclosure.

For Disclosures Required By Law. Our Practice will use and disclose your PHI when we are required to do so by federal, state or local law.

For our Business Associates. There may be some services provided in our Practice though contacts with Business Associates. Examples include our lawyers, accountants, billing companies, management companies, equipment vendors, and consultants. When these services are contracted, we may disclose some or your entire PHI to our Business Associates so that they can perform the job we've asked them to do. To protect your PHI, however, we require the Business Associates to appropriately safeguard you information in compliance with the HIPAA Privacy laws (Health Insurance Portability And Accountability Act of 1996).

USE AND DISCLOSURE OF YOUR PHI IN CERTAIN SPECIAL SITUATIONS

The following categories describe unique situations in which we may use or disclose your PHI:

For Public Health Risks. Our Practice may disclose your PHI to public health authorities that are authorized by law to collect information for purposes such as:

• maintaining vital records, such as births and deaths;
• reporting child abuse or neglect;
• preventing or controlling disease, injury or disability;
• notifying a person regarding a potential exposure to a communicable disease, or a potential risk for spreading or contracting a disease or condition;
• notifying a person regarding food or dietary supplements, reactions to drugs or problems with products or devices;
• notifying individuals if a product or device they may be using has been recalled or replaced or the subject of a lookback or post-marketing investigations; and
• notifying appropriate government agency (ies) and authority (ies) regarding the potential abuse or neglect of an adult patient (including domestic violence). We will only disclose this information if you agree or we are required or authorized by law to disclose this information.

For an Employer. Our Practice may disclose your PHI to an employer if all of these conditions exist:

• Caduceus is your employer or care was provided to you at your employer's request,
• the PHI consists of findings related to a work related illness or surveillance,
• the employer needs your PHI to comply with federal or state laws,
• Caduceus has provided a written notice to you that the PHI relating to a work related illness or surveillance will be disclosed to your employer.

For Health Oversight Activities. Our Practice 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, or compliance with civil rights laws and the health care system in general. We may disclose PHI to certain registries in accordance with applicable law. Such registries are intended to improve patient outcomes.

For Lawsuits and Similar Proceedings. Our Practice 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 a court or administrative order protecting the information the party has requested.

For 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 suspected criminal conduct at our offices;
• in response to a warrant, summons, court order, subpoena or similar legal process;
• to identify or locate a suspect, material witness, fugitive or missing person; and
• 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).

For Deceased Patients. Our Practice may release PHI to a medical examiner or coroner. This may be necessary, for example, to identify a deceased individual or to identify the cause of death. If necessary, we also may release information in order for funeral directors to perform their jobs.

For Organ and Tissue Donation. Our Practice may release your PHI to organizations that handle organ, eye or tissue procurement or transplantation, including organ donation banks, as necessary, to facilitate organ or tissue donation and transplantation if you are an organ donor.

For Serious Threats to Health or Safety. Our Practice 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.

For the Military. Our Practice may disclose your PHI if you are a member of U.S. or foreign military forces (including veterans) as required by the appropriate military command authorities. This may include foreign military personnel and their authorities.

For National Security. Our Practice may disclose your PHI to federal officials for intelligence, counterintelligence, and national security activities authorized by law. This may include disclosure of PHI to protect the President, other officials or foreign heads of state or to conduct special investigations.

For Inmates. Our Practice 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:

• for the institution to provide health care services to you;
• for the safety and security of the institution; and/or
• to protect your health and safety or the health and safety of other individuals. An inmate does not have the right to the Notice of Privacy Practices.

For Workers' Compensation. Our Practice may release your PHI for workers' compensation and similar programs to the extent necessary to comply with laws relating to workers' compensation or other similar programs established by law.

For Whistleblowers. A workforce member or business associate may disclose PHI provided that they believe in good faith that Caduceus Corporation has engaged in unlawful conduct or has engaged in care or services that potentially endangers patients, workers or the public. This disclosure can only be made to a health oversight agency, public health authority, health care accreditation organization, or an attorney (retained by the workforce member or Business Associate).

For Victims of a Crime. A workforce member who is a victim of a crime may disclose PHI to a law enforcement official if the PHI is about the suspected perpetrator of the crime and is limited to identifying the suspected perpetrator.

YOUR RIGHTS REGARDING YOUR PHI

You have the following rights regarding the PHI that we maintain about you:

Right to Request Confidential Communications. You have the right to request that our Practice communicate with you about your health and related issues in a particular manner or at a certain location. For instance, you may ask that we contact you at home, rather than at work. In order to request a type of confidential communication, you must make a written request to our Privacy Officer. You need to specify the requested method of contact, or the location where you wish to be contacted. Our Practice will accommodate reasonable requests.

Right to Request Restrictions. You have the right to request a restriction or limitation on our use or disclosure of your PHI for treatment, payment or health care operations. Additionally, you have the right to request that we restrict or limit 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 our Privacy Officer. Your request must describe in a clear and concise fashion:

• the information you wish restricted,
• whether you are requesting to limit our Practice's use, disclosure or both; and
• to whom you want the limits to apply.

We will provide you with a written notice if we do not agree to your request.

Any restriction may be terminated if:

• you request it either in writing or by oral agreement (which is documented by us);
• if we notify you, that we are terminating our agreement to restrict or limit the use of PHI. This would only then allow disclosure of PHI created after the termination date.

Right to Inspect and Copy. You have the right to inspect and obtain a copy of the PHI that may be used to make decisions about your care including patient medical records and billing records. This does not include:

• psychotherapy notes;
• records received by us but not originally created by us; or
• information created in plans for use in a civil, criminal or administrative process.

You must submit your request in writing to our Privacy Officer. Our Practice will charge a fee for the costs of copying, mailing, labor and supplies associated with your request.

Our Practice may deny your request to inspect and or copy your PHI in certain limited circumstances; however, you may request a review of our denial. Another licensed health care professional chosen by us will conduct reviews. Their decision will be final.

Right to Provide an Authorization for Other Uses and Disclosures. Our Practice 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 that we are required to retain records of your care that we provided to you and we are unable to take back any disclosures we have already made in reliance upon your current authorization.

Right to an Accounting of Disclosures. You have the right to request an "accounting of disclosures." An "accounting of disclosures" is a list of certain non-routine disclosures our Practice has made of your PHI for reasons other than for treatment, payment or healthcare operations. Use or disclosure of your PHI as part of the routine patient care in our Practice is not required to be documented in the accounting of disclosures. In order to obtain an accounting of disclosures, you must submit your request in writing to our Privacy Officer. 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 our Practice may charge you for additional lists within the same 12- month period. Our Practice will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.

Right to Amend. 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 our Practice. To request an amendment, your request must be made in writing and submitted to our Privacy Officer. You must provide us with a reason that supports your request for amendment. This Right to Amend relates to PHI created on or after April 14, 2003, only. Our Practice 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 in our opinion is:

• accurate and complete;
• not part of the PHI kept by or for the Practice;
• not part of the PHI which you would be permitted to inspect and copy;
• not created by our Practice, unless the individual or entity that created the information is not available to amend the information.

We will provide a written reason for denying your request. If you disagree with our denial, you may forward a rebuttal. We have the right to forward a second denial. You may request in writing that we include your request, our denial of that request, your rebuttal and our second denial in any future release of PHI. If we agree to your request, we will contact you and the others who may need the amended PHI.

Right to File a Complaint. If you believe your privacy rights have been violated, you may file a complaint with our Practice or with the Secretary of the Department of Health and Human Services. To file a complaint, contact our Privacy Officer. All complaints must be submitted in writing to the address below. You will not be penalized for filing a complaint.

Right to a Paper Copy of This Notice. You are entitled to receive a paper copy of our Notice of Privacy Practices at any time. You will receive an initial copy with your first visit. Any future requests may be requested by contacting our Privacy Officer. You may ask us to give you a copy of this Notice at any time.

Again, if you have any questions regarding this Notice or our health information privacy policies, please contact:

Karen Merlotti, Privacy Officer
Caduceus Corporation, Suite100
11222 Tesson Ferry Rd.
St. Louis, MO 63123
314-843-1866
314-843-7484 Fax

3/3/2003