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

PRIVACY POLICY FOR ALLCARE PLUS PHARMACY, INC.

AllCare Plus Pharmacy, Inc.’s (“AllCare Plus Pharmacy”) Privacy Policy describes the information collection and use practices at AllCare Plus Pharmacy. We include a description of the choices you can make about the way your information is collected and used. Our Privacy Policy applies to the information collected about you by AllCare Plus Pharmacy and associated with your medication and services needs.

In some circumstances, AllCare Plus Pharmacy’s use of your information will also be subject to the requirements of the Health Information Portability and Accountability Act (frequently referred to as “HIPAA”). In those circumstances, the terms of AllCare Plus Pharmacy’s HIPAA Notice of Privacy Practices, which is set forth below, will apply. If you have questions about which policy applies to information you have submitted, please do not hesitate to contact us.

We may change our internal processes or we may offer new features at AllCare Plus Pharmacy and if appropriate, we will revise this Privacy Policy accordingly. The information we obtain from you will be treated in accordance with the Privacy Policy in effect as of the date you provide information to us. If you do not agree with the privacy practices described in this policy, you should not provide us with information.

AllCare Plus Pharmacy wants you to know maintaining the privacy of your health information (Protected Health Information, or “PHI”) is central to our role as your trusted pharmacy. PHI is information about you, including basic information that may identify you and relates to your past, present, and future health or condition and dispensing of prescription products to you.

Our Pledge Regarding Your Health Information:

We pledge to protect the privacy of your health information as required by federal and state laws, regulations, and other applicable authorities and to keep you informed of your rights with this Notice. Our pharmacy personnel are committed to protecting the confidentiality of your PHI and will only disclose your PHI to a person other than you or your personal representative when permitted under federal or state law. This protection extends to any PHI that is oral, written, or electronic, such as prescriptions transmitted via fax, modem, or other electronic device. This Notice describes your rights and the obligations we have regarding the use and disclosure of your PHI. In some circumstances, as described below in this Notice, the laws permit us in serving your pharmacy needs to use and disclose your PHI without your express permission. In all other circumstances, we will obtain your written authorization before we use or disclose your PHI. Under federal and applicable state law, we are required to follow the terms of the Notice currently in effect. HIPAA’s standards may be pre-empted by certain state laws relating to the privacy of health information. Please see State notices at the end of this provision.

RIGHT TO RECEIVE COUNSELING

Anyone receiving mediations or pharmacy services from AllCare Plus Pharmacy, Inc. has the right to ask for and receive counseling regarding the same from the Pharmacy. Please contact us at 1-833-383-3533 if you have questions or desire such counseling.

NOTICE OF PRIVACY PRACTICES

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 about you (as a patient of this practice) 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:

AllCare Plus Pharmacy’s practice is dedicated to maintaining the privacy of our customer’s PHI. In conducting our business, we will create records regarding our customers and the treatment and services we provide to each customer. We are required by law to maintain the confidentiality of health information that identifies an individual. We also are required by law to provide our customers with this notice of our legal duties and the privacy practices that we maintain in our practice concerning our customers’ PHI. By federal and state law, we must follow the terms of the Notice of Privacy Practices that we have in effect at the time.

We realize that these laws may be unfamiliar or difficult to understand, but we nevertheless must provide everyone we serve with the following important information:

• How we may use and disclose a customer’s PHI,
• Our Customer’s privacy rights in their PHI,
• Our obligations concerning the use and disclosure of a customer’s PHI.

The terms of this notice apply to all records containing a customer’s PHI, that are created or retained by our practice. We reserve the right to revise or amend this Notice of Privacy Practices. Any revision or amendment to this notice will be effective for all of our customers’ records that our practice has created or maintained in the past, and for any of such 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 anyone may request a copy of our most current Notice at any time.

B. If you have questions about this Notice, please contact us:

AllCare Plus Pharmacy, Inc.
50 Bearfoot Road
Northborough, MA 01532
ATTN: Privacy Request
1-833-383-3533 (phone)
1-844-740-1211 (fax)

Information Use

Your protected health information may be used and disclosed by AllCare Plus Pharmacy and others outside AllCare Plus Pharmacy that are involved in your care and treatment for the purpose of providing health care services to you. Your protected health information may also be used and disclosed as necessary to pay health care bills and to otherwise support the operation of AllCare Plus Pharmacy.

Set forth below are examples of the types of uses and disclosures of your protected health care information that AllCare Plus Pharmacy is permitted to make. These examples are not meant to be exhaustive, but rather to describe for you the types of uses and disclosures that may be made by AllCare Plus Pharmacy.

The following categories describe the different ways in which we may use and disclose your PHI.

1. Treatment. We may use your PHI to assist others in your treatment. Additionally, we may disclose your PHI to others who may assist in your care, such as your spouse, children or parents. Finally, we may also disclose your PHI to other health care providers for purposes related to your treatment.
2. Payment. We may use and disclose your PHI in order to bill and collect payment for the services and items you may receive from us. 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. We may disclose your PHI to other health care providers and entities to assist in their billing and collection efforts.
3. Health care operations. We 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, our practice may use your PHI to evaluate the quality of care you received from us, or to conduct cost-management and business planning activities for our practice. We may disclose your PHI to other health care providers and entities to assist in their health care operations.
4. Appointment reminders. We may use and disclose your PHI to contact you and remind you of an appointment.
5. Treatment options. We may use and disclose your PHI to inform you of potential treatment options or alternatives.
6. Health-related benefits and services. We may use and disclose your PHI to inform you of health-related benefits or services that may be of interest to you.
7. Release of information to family/friends. Unless you object, we 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.
8. Disclosures required by law. We will use and disclose your PHI when we are required to do so by federal, state or local law.
9. Business associates. We also may need to share your protected health information with certain of our “business associates,” third parties that perform various activities (e.g., billing, transcribing records) for AllCare Plus Pharmacy. Whenever an arrangement between AllCare Plus Pharmacy and a business associate involves the use or disclosure of your protected health information, we will have in place the legally required safeguards to protect the privacy of your health information.

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. We may disclose your PHI to public health authorities that are authorized by law to collect information for the purpose of:

• 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,A recall is an action taken when a product is found to be in violation of laws and regulations administered by the FDA. Medications may be recalled for a variety of reasons including safety, mislabeling, contamination and deviations in strength or potency. Recalls may be conducted by a voluntary action by the manufacturer/supplier, by request from the FDA, or by a legally mandated order from the FDA. There are three recall classifications:
• Class I: products that could cause serious health problems or death;
• Class II: products that may cause a temporary or reversible adverse health problem or where the probability of a serious health problem is remote; and
• Class III: products that are unlikely to cause any adverse health problems but violate FDA manufacturing or labeling laws. Pharmacies are notified of recalled medications from a variety of sources including drug manufacturers, compounding pharmacies, outsourcing facilities, drug wholesalers and other vendors, and government agencies such as the FDA, state departments of health, and boards of pharmacy. The FDA has a Web site that lists all recalls: (www.fda.gov/Safety/Recalls/default.htm). Patients will be notified by phone immediately if they potentially have medication on hand that is affected by the recall and will be instructed by a Pharmacist as to what the next steps will be in the recall process.

• 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.

We may disclose your protected health information to a government authority that is authorized by law to receive reports of child abuse or neglect. In addition, we may disclose your protected health information if we believe that you have been a victim of abuse, neglect or domestic violence to the governmental entity or agency authorized to receive such information. In this case, the disclosure will be made consistent with the requirements of applicable federal and state laws.

1. Health oversight activities. We 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. In particular, we may disclose your protected health information, if authorized by law, to a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading the disease or condition.
   We may disclose your protected health information to a person or company required by the Food and Drug Administration to report adverse events, product defects or problems, biologic product deviations, track products; to enable product recalls; to make repairs or replacements; or to conduct post marketing surveillance, as required.
2. Lawsuits and similar proceedings. We 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.
3. 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).

1. Deceased patients. We may release PHI to a medical examiner or coroner 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.
2. Organ and tissue donation. We 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.
3. Research. We may use and disclose your PHI for research purposes in certain limited circumstances. We will obtain your written authorization to use your PHI for research purposes except when an Internal Review Board or Privacy Board has determined that the waiver of your authorization satisfies all of the following conditions:
   (A) The use or disclosure involves no more than a minimal risk to your privacy based on the following: (i) an adequate plan to protect the identifiers from improper use and disclosure; (ii) an adequate plan to destroy the identifiers at the earliest opportunity consistent with the research (unless there is a health or research justification for retaining the identifiers or such retention is otherwise required by law); and (iii) adequate written assurances that the PHI will not be re-used or disclosed to any other person or entity (except as required by law) for authorized oversight of the research study, or for other research for which the use or disclosure would otherwise be permitted;
   (B) The research could not practicably be conducted without the waiver,
   (C) The research could not practicably be conducted without access to and use of the PHI.
4. Serious threats to health or safety. We 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.
5. Military. We 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.
6. National security. We may disclose your PHI to federal officials for intelligence and national security activities authorized by law. We also may disclose your PHI to federal 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.
7. Inmates. We 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.
8. Workers’ compensation. We may release your PHI for workers’ compensation and similar programs.
9. Communication Barriers. If AllCare Plus Pharmacy attempts to obtain consent from you but is unable to do so due to substantial communication barriers and AllCare Plus Pharmacy determines, using professional judgment, that you would consent to the use or disclosure under the circumstances, we may use and disclose your protected health information.
10. Disclosure Required By Law. We may use or disclose your protected health information to the extent that the use or disclosure is required by law. The use or disclosure will be made in compliance with the law and will be limited to the relevant requirements of the law. You will be notified, as required by law, of any such uses or disclosures.

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 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 work. In order to request a type of confidential communication, you must make a written request to:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request
   1-833-383-3533 (phone)
   1-844-740-1211 (fax)
   specifying the requested method of contact, or the location where you wish to be contacted. We 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:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)

   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,
• To whom you want the limits to apply.

In an emergency treatment situation, we may have to use or disclose your protected health information in a context in which consent for the release of information has not already been given. If this happens, we will try to obtain your consent to the release of information as soon as reasonably practicable after the delivery of the treatment. If we are required to treat you and has attempted to obtain your consent but is unable to obtain your consent, AllCare Plus Pharmacy may still use or disclose your protected health information to treat you.

1. 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:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)
   In order to inspect and/or obtain a copy of your PHI. We may charge a reasonable fee for the costs of copying, mailing, labor and supplies associated with your request. We 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.

   Under federal law, however, you may not inspect or copy the following records: psychotherapy notes; information compiled in reasonable anticipation of, or use in, a civil, criminal, or administrative action or proceeding, and protected health information that is subject to law that prohibits access to protected health information. In some circumstances, you may have a right to review a decision that denies you access to information. Please contact our Privacy Contact if you have questions about access to your health information.

2. 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 our practice. To request an amendment, your request must be made in writing and submitted to:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)
   You must provide us with a reason that supports your request for amendment. We 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 the practice; (c) not part of the PHI which you would be permitted to inspect and copy; or (d) not created by our practice, unless the individual or entity that created the information is not available to amend the information.

3. 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 our practice has made of your PHI for purposes not related to treatment, payment or operations. Use of your PHI as part of the routine patient care in our practice 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 to:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)
   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 October 1, 2002. 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. We will notify you of the costs involved with additional requests, and you may withdraw your request before you incur any costs.

4. Right to a paper copy of this notice. You are entitled to receive a paper copy of our notice of privacy practices. You may ask us to give you a copy of this notice at any time. To obtain a paper copy of this notice, contact
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)

5. Right to file a complaint. If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the Department of Health and Human Services. To file a complaint with us, contact:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)

   All complaints must be submitted in writing. You will not be penalized for filing a complaint.

6. Right to provide an authorization for other uses and disclosures. We 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 by you, 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 treatment.

   Again, if you have any questions regarding this notice or our health information privacy policies, please contact:
   AllCare Plus Pharmacy, Inc.
   50 Bearfoot Road
   Northborough, MA 01532
   ATTN: Privacy Request
   

   1-833-383-3533 (phone)
   1-844-740-1211 (fax)

   Massachusetts State Specific Provision:
   Medicaid Recipients: We will restrict disclosure of your PHI to purposes directly connected with the administration of your healthcare benefits.