Wesleyan Senior Living respects your right to privacy and will make every effort to protect it when you visit our web site or contact us via e-mail. Here are some things you should know about how we protect your privacy:

E-Mail
When you send e-mail to Wesleyan Senior Living we will not routinely keep or share your e-mail address with anyone outside of our staff. We will only use your e-mail address to respond to your requests for information or to forward it to the appropriate agency capable of meeting your needs.

Information Collection
When you visit our web site, we collect certain information about your visit that does not identify you personally. We can tell the type of computer, browser, and web service you are using. We also know the date and time you visit and the pages you visit. Collecting this information helps us design the site according to your needs.

Information Security
With respect to security, we use industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. We have appropriate security measures in place in our physical facilities to protect against the loss, misuse, or alteration of information that we have collected from you at our site. We do not sell, trade or provide confidential information to any other companies or entities.

NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.  PLEASE REVIEW IT CAREFULLY.  IF YOU HAVE ANY QUESTIONS ABOUT THIS NOTICE PLEASE CONTACT OUR PRIVACY OFFICER, DIANE L. COLETTI AT (440) 284-9279.

Wesleyan Senior Living and each of the related entities listed at the end of this Notice use health information about you for your treatment, to obtain payment for treatment, for our administrative health care operations and for other purposes.  We understand that information about you and your health is personal, and we are committed to protecting this information.  This notice describes how we may use and disclose your personal health information and your rights and our legal duties regarding our use and disclosure of this information.

Wesleyan Senior Living is required by law to abide by the terms of this notice.  We reserve the right to change our privacy practices and to make the new provisions effective for all protected health information we maintain.  Revised notices will be available upon request.

This Notice of Privacy Practices is effective December 6, 2006.

We use and disclose our Residents’ health information for a variety of reasons.  Under Federal law, we have the right to use and/or disclose your health information to provide treatment, to obtain payment for our services and to carry out our health care operations without your prior consent or authorization.  However, we will ask for your prior written consent for most disclosures of your health information to third parties in order to comply with more stringent requirements under Ohio law.  For uses and disclosures other than for treatment, payment and health care operations, both Federal and Ohio law, with exceptions described below, require us to have your written authorization.  If we disclose your health information to an outside entity so that the entity may perform a function on our behalf, we will enter into an agreement with that entity to protect your information in the same manner that we must protect it.

The following information describes and gives examples of how we may use and disclose your health information:

For Treatment, Payment and Health Care Operations:

For Treatment: We will use and disclose your protected health information to provide, coordinate or manage your health care and related services.  For example, information provided to a nurse will be disclosed to the treating physician so that the physician may better treat you.  Health care providers will also record actions taken by them in the course of your treatment and note how you responded to the treatment.  This information may be disclosed to other physicians, facilities or agencies to whom you are referred for additional treatment or evaluation and to outside entities performing ancillary services, such as lab work or x-rays.

For Payment: We may use or disclose your protected health information to others to bill and collect payment for your health care services.  For example, a bill containing identifying information and which may contain information regarding your diagnosis, treatment and supplies used in treatment may be sent to a third party payor such as an insurance company or to a federal program such as Medicare.  We may use third parties to perform billing and collection services for us or to provide other services in connection with our payment activities, and they may be provided access to your protected health information in order to provide those services.

Health Care Operations: We may use or disclose your protected health information for operational purposes.  For example, we may use a sign-in sheet at the registration desk where you will be asked to sign your name and indicate which resident you are seeing.  In addition, we may use your information to evaluate the performance of our staff, access the quality of care, assess outcomes in your case and similar cases, and learn how to improve our facilities and services.  We may disclose your protected health information to advisors, including attorneys, accountants and other consultants to perform audits, advise us on operational issues, or to assist in strategic or other planning and evaluation activities.

Fundraising: We may contact you or engage another party to contact you for fundraising activities supported by our office.  If you do not want to be contacted for fundraising efforts, you must notify our Privacy Officer in writing.

Uses and Disclosures of Health Information That Do Not Require Your Consent or Authorization:

Required by Law: We may use or disclose your protected health information as required by law.  For example, Wesleyan Senior Living may disclose information for judicial and administrative proceedings pursuant to legal authority; to report information on abuse and neglect; or to assist law enforcement in their duties.

Public Health: We may use or disclose your protected health information for public health activities such as assisting public health authorities or other legal authorities to prevent or control disease, injury or disability.

Health Oversight Activities: We may use or disclose your protected health information for government health oversight activities.

Health and Safety: We may use or disclose your protected health information to avert a serious threat to the health or safety of you or any other person.

Upon Death; Organ and Tissue Donation: We may disclose your protected health information to funeral directors or coroners to enable them to carry out their lawful duties.  In addition, your health information may be used or disclosed for cadaveric organ, eye or tissue donation purposes.

Research: We may use your protected health information for research purposes when the research has been approved by an institutional review board or privacy board that has reviewed the research proposal and established protocols to ensure the privacy of your protected health information.

Government Functions: We may use or disclose your protected health information to specialized government functions such as protection of public officials or reporting to various branches of the armed services that may require use or disclosure of your health information.

Workers’ Compensation: We may use or disclose your protected health information in order to comply with the laws, regulations and requirements related to workers’ compensation.

Treatment Alternatives: We may use or disclose your protected health information to tell you about treatment alternatives or other health-related benefits and services that may be beneficial.

Uses and Disclosures of Health Information Requiring Us to Give You an Opportunity to Object:

Others Involved in Your Healthcare: Unless you object, we may use or disclose your protected health information to a member of your family, a relative, a close friend or any other person you identify if that information directly relates to that person’s involvement in your health care.  If you are unable to agree or object to such disclosure, we may disclose such information as necessary if we determine it to be in your best interest based on our professional judgment.  We may use or disclose your information to notify or assist in notifying a family member, personal representative or any other person responsible for your care, general condition or in the event of death.

Facility Directories: Your name, location and general condition may be put into our facility directory for disclosure to callers or visitors who ask for you by name.  In addition, your religious affiliation may be shared with clergy.

Photos:  Unless you object, photos and/or videos are taken during various Resident events and displayed during the year.  Photos are also taken for identification purposes and may be included on an identification badge.  Photos and/or videos may be shown on the inhouse TV channel, displayed on bulletin boards and included in various facility publications. (3/22/06)

Birthdays:  Unless you object, birthdays are posted in the form of a birthday list on the inhouse TV channel and internal publications and may include the month and day.  The year of birth is not published. In celebration of your birthday, your name may be mentioned at the monthly birthday dinner or other activity. (3/22/06)

Uses and Disclosures of Health Information That Require Your Authorization:

Generally, Wesleyan Senior Living must have your written authorization to use or disclose your health information for purposes not described above.  Authorizations can be revoked at any time unless we have already acted based on your permission.

Your Health information Rights

To inspect and copy your protected health information as provided in 45 CFR §164.524: You may inspect and obtain a copy of your protected health information that is contained in your medical record for as long as we retain the information.  Your right to obtain and copy protected health information may be limited.  For example, you may not inspect or copy notes from psychotherapy sessions or information compiled in anticipation of, or use in, a civil, criminal or administrative action or proceeding.  Please contact our Privacy Officer for questions or to exercise this right.

To request a restriction on certain uses and disclosures of your health information as provided in 45 CRF § 164.522: You may request that any part of your protected health information not be used or disclosed for the purposes of treatment, payment or healthcare operations.  Wesleyan Senior Living may not be able to agree to your request.  Your request must be in writing to our Privacy Officer and must specifically describe what information you would like to restrict and to whom you would like the restriction to apply.

To request to receive confidential communications by alternative means or at an alternative location: We will accommodate all reasonable requests.  This request may be conditioned on the receipt of additional payment information or clarification.  Please make this request in writing to our Privacy Officer.

To amend your protected health information as provided in 45 CFR § 164.526: If you believe your health information is not correct or is incomplete, you may submit a request to amend your health information to us in writing, including an explanation why you believe the information is not correct or is incomplete.  If we do not agree to amend your information, we will provide you with a reason for our denial of your request, and you will have an opportunity to submit a statement of disagreement.  Please contact our Privacy Officer about any questions regarding amending your protected health information.

To obtain a paper copy of this notice upon request.

To receive an accounting of certain uses and disclosures of your protected health information as provided by 45 CFR § 164.528.

To revoke your authorization to use or disclose protected health information except to the extent action has already been taken.

Complaints

You may send complaints to Wesleyan Senior Living and/or to the Department of Health and Human Services if you believe your privacy rights have been violated.  You will not be retaliated against for filing a complaint.  A complaint may be filed at the following address:

Wesleyan Senior Living Privacy Complaints
Diane L. Coletti P.O. Box 8050
Privacy Officer U.S. Department of Health and Human Services
807 West Avenue Centers for Medicare and Medicaid Services
Elyria, OH 44035 7500 Security Boulevard
Baltimore, MD 21244-1850

The following entities and locations listed below have adopted this Notice and agree to adhere to the standards expressed in this Notice.

Wesleyan Senior Living Foundation
807 West Avenue
Elyria, Ohio  44035