APS - Privacy Practices

NOTICE OF PRIVACY PRACTICES Effective Date: 04/14/2003

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

OUR PLEDGE REGARDING PROTECTED HEALTH INFORMATION:

We understand that protected health information about you and your
health is personal. We are committed to protecting protected health
information about you. We create a record of the care and services you
receive from Advanced Pharmacy Solutions. We need this record to
provide you with quality care and to comply with certain legal
requirements. This notice applies to all of the records of your care
generated for or by Advanced Pharmacy Solutions, whether made by
Advanced Pharmacy Solutions personnel, your physician, or any entity we
coordinate with to provide for your care. Your physician and other
healthcare providers may have different policies or notices regarding
the use and disclosure of your protected health information created in
their office.

This notice will tell you about the ways in which we may use and
disclose protected health information about you. We also describe your
rights and certain obligations we have regarding the use and disclosure
of protected health information.

We are required by Federal and State law to:

Make sure that protected health information that identifies you is
kept private;

Give you this notice of our legal duties and privacy practices with
respect to protected health information about you; and

Follow the terms of the notice that is currently in effect.

HOW WE MAY USE AND DISCLOSE PROTECTED HEALTH INFORMATION ABOUT YOU:

The following categories describe different ways that we use and
disclose protected health information. For each category of uses or
disclosures we will explain what we mean and try to give some examples.
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
within one of the categories.

For Treatment. We may use or disclose protected health information
about you to provide, coordinate, and manage your health care services.
For example, we may disclose protected health information about you to
a medical supply vendor for custom fitted products or direct delivery
purposes. Also, different departments of Advanced Pharmacy Solutions
may share protected health information about you in order to coordinate
the different things you need, such as prescriptions, supplies and
equipment. We also may disclose protected health information about you
to people outside Advanced Pharmacy Solutions who may be involved in
your medical care. As examples, your physician, family members,
caregivers, nursing agencies, clergy or others we use to provide
services that are part of your care and best addresses your health
needs.

For Payment. We may use and disclose protected health information
about you so that the treatment and services you receive from Advanced
Pharmacy Solutions may be billed to and payment may be collected from
you, an insurance company, or a third party. For example, we may need
to use or disclose your protected health information such as your
diagnosis, demographics, services, medications, or supplies needed for
your care so your health plan will pay us or reimburse you for services
provided. 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.

We may also disclose your protected health information to another
entity for the payment activities of that entity. For example, if it
was necessary to coordinate care with a nursing agency for the
administration of a medication, we may disclose information about you
to the nursing agency in order for them to bill your insurance plan.

For Health Care Operations. We may use and disclose protected health
information about you for Advanced Pharmacy Solutions operations. These
uses and disclosures are necessary to run Advanced Pharmacy Solutions
and make sure that all of our patients receive quality care. For
example, we may use protected health information to review our services
and to evaluate the performance of our staff in caring for you. We may
also use protected health information about many Advanced Pharmacy
Solutions patients to decide what additional services we should offer
or what services are not needed. We may also disclose information to
other Advanced Pharmacy Solutions personnel for review and training
purposes. We may also combine the protected health information we have
with protected health information from other agencies to compare how we
are doing and see where we can make improvements in the care and
services we offer. We may remove information that identifies you from
this set of protected health information so others may use it to study
health care and health care delivery without learning who the specific
patients are.

We may use or disclose your protected health information to insure the
smooth operations of the office and our service to you, such as but not
limited to, reminders left on your answering device (or any other
device designated by a caregiver, family member or emergency contact)
for the purpose of supply orders, medications or delivery/pick-up time
notifications.

Your information may be disclosed to business associates that perform
various services for us, such as, but not limited to, direct delivery,
maintenance/support, or accounting purposes. We require our business
associates to appropriately safeguard any information we share with
them.

Subject to certain restrictions, we may also disclose your protected
health information to other entities for their own health care
operations. For example, we may release information to your health plan
in order for them to run quality-related activities and performance
measures.

Service Communications. We may use or disclose your protected
health information to insure quality of service such as but not limited
to, reminders left on your answering device (or any other device
designated by a caregiver, family member or emergency contact) for the
purpose of orders, medications or delivery/pick-up time notifications.

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

Health-Related Benefits and Services. We may use and disclose
protected health information to tell you about health-related benefits
or services that may be of interest to you.

Others Involved in Your Care or Payment for Your Care. We may
disclose your protected health information to people such as family,
relatives, friends and those who are helping care for or helping you
pay your medical bills. The information disclosed will directly relate
to that person's involvement in your health care. You can agree or
object to such a disclosure. If you are unable to agree or object, we
may disclose such information that, in our professional judgement, we
deem to be necessary and in your best interests. We also may disclose
your protected health information to an entity authorized to handle
disaster relief efforts so that those involved in your health care can
receive information about your location or health status.

Incidental Disclosures. We may disclose PHI incidental to our
provision of treatment, payment, or health care operations. For
example, in our telephone discussions with physicians, PHI might be
overheard by a member of our staff other than the staff member placing
the call.

Business Associates. There are some services provided by us through
contracts with business associates. Examples may include mailing or
delivery services. When these services are contracted for, we may
disclose PHI about you to our business associate only to the extent
necessary so that they can perform the job we have asked them to do. To
protect PHI about you, we require the business associate to
appropriately safeguard the PHI.

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

Workers' Compensation. We may disclose protected health information
to the extent necessary to comply with state law for workers'
compensation or other similar programs.

To Avert a Serious Threat to Health or Safety. We may use and
disclose protected health information about you when necessary to
prevent a serious threat to your health and safety or the health and
safety of the public or another person. Any disclosure, however, would
only be to someone able to help prevent the threat.

Public Health Risks. We may be required to disclose your protected
health information for public health activities. These include but are
not limited to the following:

To report certain diseases, injuries, disability.

To report births and deaths.

To disclose information of concern to the Food and Drug
Administration or to report reactions to medications, problems with
products, to notify people of recalls of products they may be using.

To notify a person who may have been exposed to a disease or may be
at risk for contracting or spreading a disease or condition.

To report child abuse, neglect, or to notify the appropriate
government authority, such as a social worker or protective services
agency, if we believe a patient has been the victim of abuse, neglect
or domestic violence. We will disclosure this type of information to
the extent required by law, if you agree to the disclosure, or if the
disclosure is allowed by law and we believe it is necessary to prevent
serious harm to you or someone else or the law enforcement or public
official that is to receive the report represents that it is necessary
and will not be used against you.

Health Oversight Activities. We may disclose protected health
information to a health oversight agency for activities authorized by
law. These oversight activities include, for example, 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.

Ø Research. Under certain circumstances, we may disclose protected
health information about you for research purposes, provided certain
measures have been taken to protect your privacy.

Organ and Tissue Donation. If you are an organ donor, we may
disclose your protected health information to people involved with
obtaining, storing, or transplanting organs, tissues, or eyes of
cadavers for donation purposes.

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

Judicial and Administrative Proceedings. We may disclose protected
health information about you in response to a court or administrative
order. We may also disclose protected health information about you in
response to a subpoena, discovery request, or other lawful process.

Law Enforcement. We may release protected health information if
asked to do so 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 the victim of a crime if, under certain limited circumstances,
we are unable to obtain the person's agreement;

About a death we believe may be the result of criminal conduct;

About criminal conduct within the agency; 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 release
protected health information to a coroner or medical examiner. This may
be necessary, for example, to identify a deceased person or determine
the cause of death. We may also release protected health information
about patients of Advanced Pharmacy Solutions to funeral directors as
necessary to carry out their duties.

National Security and Intelligence Activities. We may release
protected health information about you to authorized federal officials
for intelligence, counterintelligence, and other national security
activities authorized by law.

Protective Services for the President and Others. We may disclose
protected health information about you to authorized federal officials
so they may provide protection to the President, other authorized
persons or foreign heads of state or conduct special investigations.

Correctional Institution. If you are an inmate of a correctional
institution or under the custody of a law enforcement official, we may
release protected health information about you to the correctional
institution or law enforcement official. This release would be
necessary (1) for the institution to provide you with health care; (2)
to protect your health and safety or the health and safety of others;
or (3) for the safety and security of the correctional institution.

OTHER USES OF PROTECTED HEALTH INFORMATION:

Other uses and disclosures of protected health information not covered
by this notice or the laws that apply to us will be made only with your
written permission. If you provide us permission to use or disclose
protected health information about you, you may revoke that permission,
in writing, at any time. If you revoke your permission, we will no
longer use or disclose protected health information about you for the
reasons covered by your written authorization. You understand that we
are unable to take back any disclosures we have already made with your
permission, and that we are required to retain our records of the care
that we provided to you.

YOUR RIGHTS REGARDING PROTECTED HEALTH INFORMATION ABOUT YOU:

You have the following rights regarding protected health information
we maintain about you:

Right to Inspect and Copy. You have the right to inspect and copy
protected health information that may be used to make decisions about
your care. Usually, this includes medical and billing records, but does
not include psychotherapy notes or information gathered for judicial
proceedings.

To inspect and copy protected health information that may be used to
make decisions about you, you must submit your request in writing to
the Privacy Officer. If you request a copy of the information, we may
charge a fee for the costs of copying, mailing or other supplies
associated with your request.

We may deny your request to inspect and copy in certain circumstances.
If you are denied access to protected health information, you may
request that the denial be reviewed. Another health care professional
chosen by Advanced Pharmacy Solutions will review your request and the
denial. The person conducting the review will not be the person who
denied your request. We will comply with the outcome of the review.

Right to Request Amendment. If you feel that protected health
information we have about you is incorrect or incomplete, you may ask
us to amend the information. You have the right to request an amendment
for as long as we maintain the information.

To request an amendment, your request must be made in writing and
submitted to the Privacy Officer. In addition, you must provide a
reason that supports your request.

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;

Is not part of the information which you would be permitted to
inspect and copy; or

Is accurate and complete.

If we deny your request to amend, we will notify you in writing. You
then have the right to submit to us a written statement of disagreement
with our decision and we have the right to rebut that statement.

Right to Request Restrictions. You have the right to request a
restriction or limitation on the protected health information we use or
disclose about you for treatment, payment or health care operations.
You also have the right to request a limit on the protected health
information we disclose about you to someone who is involved in your
care or the payment for your care, like a family member or friend. For
example, you could ask that we not use or disclose information about a
medication you received.

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
emergency treatment to you or required by law.

To request restrictions, you must make your request in writing to the
Privacy Officer. In your request, you must tell us (1) what information
you want to limit; (2) whether you want to limit our use, disclosure or
both; and (3) to whom you want the limits to apply, for example,
disclosures to your spouse.

Right to Request Confidential Communications. You have the right to
request that we communicate with you about medical matters in a certain
way or at a certain location. For example, you can ask that we only
contact you at work or by mail.

To request confidential communications, you must make your request in
writing to the Privacy Officer. We will not ask you the reason for your
request. We will accommodate all reasonable requests. Your request must
specify an alternative address or means of communication on how or
where you wish to be contacted or information as to how payment, if
any, will be handled.

Right to an Accounting of Disclosures. You have the right to request
an "accounting of disclosures" we have made of your protected health
information. The list will not include our disclosures related to:

Your treatment, our payment or health care operations;

Disclosures made to you or with your authorization;

For purposes of national security or law enforcement and
corrections; or

For certain health oversight activities.

Your request for an accounting of disclosures must be made in writing
and must state a time period for which you want an accounting. This
time period may not be longer than six years and may not include dates
before April 14, 2003. Your request should indicate in what form you
want the list (for example, on paper or electronically). The first
accounting that you request within a 12-month period will be free. For
additional lists within the same time period, we may charge for
providing the accounting, but we will tell you the cost in advance.

Right to a Paper Copy of This Notice. You have the right to receive
a paper copy of this notice. You may ask us to give you a copy of this
notice at any time.

To obtain a paper copy of this notice, please contact the Privacy
Officer at Advanced Pharmacy Solutions.

CHANGES TO THIS NOTICE:

We reserve the right to change our practices and this notice. We
reserve the right to make the revised or changed notice effective for
protected health information we already have about you as well as any
information we receive in the future. We will post a copy of the
current notice in our agency with the effective date. Upon request, we
will provide a revised notice to you.

COMPLAINTS:

You may complain to Advanced Pharmacy Solutions and 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. If you wish to file a complaint, please contact our Chief
Privacy Officer at 26611 Cabot Road, Suite B, Laguna Hills, CA 92653.
All complaints must be submitted in writing.

CONTACT INFORMATION:

If you have any questions or other concerns, please contact Advanced
Pharmacy Solutions Chief Privacy Officer at 26611 Cabot Road, Suite B,
Laguna Hills, CA 92653 or (949) 348-7900.

Sincerely,

James H. Roache, Pharm. D.

President and CEO