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.

This is the required Notice of Privacy Practices (“Notice”) of The Eliza Jennings Senior Care Network and its Organized Health Care Arrangement (OHCA). This Notice applies to and will be followed by all employees, staff, volunteers, students, trainees, and other workforce members of The Eliza Jennings Senior Care Network and its affiliated entities, including Eliza Jennings Home, Devon Oaks, The Renaissance, Acacia Place, and Eliza at Chagrin Falls.

Explanation of Forms

This Facility maintains medical and health information about you. This information is regulated by federal and state law. To comply with applicable law, we are required to provide you with this Notice and to follow the terms of the Notice currently in effect. In some circumstances, we may also require you to sign an authorization form.

Uses and Disclosures of Protected Health Information

We are permitted by law to use and disclose protected health information about you for purposes essential to providing care, including treatment, payment, and health care operations, without your authorization.

Treatment

Treatment includes consultations, diagnosis, provision of care, coordination of care, and referrals among health care providers.

Payment

Payment includes activities necessary for billing and collection, such as claims processing, eligibility determinations, utilization review, and collection activities.

Health Care Operations

Health care operations include activities such as quality assessment and improvement, staff training, licensing, accreditation, auditing, and general business management.

Substance Use Disorder Records – 42 CFR Part 2

Certain medical information related to the diagnosis, treatment, or referral for treatment of a substance use disorder may be subject to additional federal protections under 42 CFR Part 2. Substance use disorder records may be used or disclosed for treatment, payment, and health care operations as permitted by law. However, these records may not be used or disclosed to initiate or substantiate criminal charges, civil actions, administrative proceedings, or investigations against you without your written consent or a court order, except as otherwise permitted by law.

You have the right to revoke your consent to disclose substance use disorder records at any time, except to the extent that action has already been taken in reliance on your consent.

Prohibition on Use for Legal or Law Enforcement Action

We will not use or disclose your protected health information, including substance use disorder records, to investigate, prosecute, or bring civil, criminal, administrative, or legislative action against you, except as permitted or required by law.

Other Permitted Uses and Disclosures

We may use or disclose your protected health information without your authorization in the following circumstances, as permitted or required by law:

As Required by Law – When required to do so by federal, state, or local law

· Public Health Activities – For disease prevention, reporting, and public health surveillance

· Communicable Diseases – To persons at risk of exposure when authorized by law

· Health Oversight Activities – Audits, investigations, inspections, and licensure

· Abuse, Neglect, or Domestic Violence – Reporting to authorized government agencies

· Food and Drug Administration – Product monitoring, recalls, and safety reporting

· Legal Proceedings – In response to a court order or lawful process

· Law Enforcement – As permitted by law and subject to applicable limitations

· Coroners, Medical Examiners, and Funeral Directors – Identification and cause of death

· Organ and Tissue Donation – For donation and transplantation purposes

· Research – When approved by an institutional review board or as otherwise permitted

· Serious Threats to Health or Safety – To prevent or lessen a serious and imminent threat

· Military, Veterans, and National Security Activities – As authorized by law

· Workers’ Compensation – To comply with workers’ compensation laws

· Inmates and Correctional Institutions – As permitted when you are incarcerated

Fundraising

We may contact you to raise funds for Eliza Jennings. You have the right to opt out of receiving fundraising communications at any time by calling (216) 226-5000 or emailing development@elizajen.org.

Facility Directory

Unless you object, we may include your name, location, general condition, and religious affiliation in our facility directory. Religious affiliation is disclosed only to clergy. All other information may be disclosed to individuals who ask for you by name.

Individuals Involved in Your Care

Unless you object, we may disclose protected health information to family members, relatives, close friends, or other persons you identify who are involved in your care or payment for your care. If you are unable to agree or object, we may disclose such information if we determine it is in your best interest.

Authorized Uses and Disclosures

Other uses and disclosures not described in this Notice will be made only with your written authorization. You may revoke an authorization at any time in writing, except to the extent we have already relied on it.

Authorization is required for:

· Most uses and disclosures of psychotherapy notes

· Marketing communications

· Sale of protected health information

Your Rights

You have the right to:

· Inspect and receive a copy of your protected health information, including an electronic copy if maintained electronically

· Request transmission of your information to another person or entity

· Request an amendment to your medical record

· Receive an accounting of certain disclosures

· Request restrictions on certain uses and disclosures (we must honor restrictions for out-of-pocket paid services)

· Request confidential communications

· Receive a paper copy of this Notice

· Be notified following a breach of unsecured protected health information

Non-Discrimination and Non-Retaliation

We will not discriminate against you or retaliate against you for exercising your privacy rights, filing a complaint, refusing to authorize a disclosure, or participating in any privacy-related process.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with the HIPAA Privacy Officer at:

26376 John Road, Olmsted Township, Ohio 44138

Email: Privacy@elizajen.org

You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights. We will not retaliate against you for filing a complaint.

Changes to This Notice

We reserve the right to change this Notice at any time. The revised Notice will apply to all protected health information we maintain. Current notices are posted at our facilities and online at https://elizajennings.org/privacy-policy/.

Effective Date: September 2003 Revised: September 2013; January 2018; September 2020; October 2023; February 2026