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BARRON
PHARMACY
Policies and Procedures
for Compliance with
HIPAA Privacy Standards
Respect for Patient's Privacy
All employees of Barron Pharmacy shall respect the privacy of a patient's personally
identifiable health information/protected health information (hereinafter "PHI") and shall not use
and disclose PHI except as described in the Notice of Privacy Practices of Barron Pharmacy or
otherwise permitted by HIPAA. If an employee has any question concerning the use and
disclosure of PHI, the employee shall consult with the Pharmacy Privacy Officer. Any violation
by an employee of a patient's privacy shall be grounds for disciplinary action, including
termination of employment.

Notice of Privacy Practices
Effective April 14, 2003, all patients shall be given the written Notice of Privacy Practices of
Barron Pharmacy. An actual, physical handing of the written Notice of the Privacy Practices
shall be attempted, rather than asking the patient if he or she wants a written Notice of Privacy
Practices. This policy shall continue for the six-month period concluding October 14, 2003, at
which time the patient may be asked if he or she has received a written Notice of Privacy
Practices. This policy is adopted on the good faith belief that the majority of patients will have
received the written Notice of Privacy Practices during the six-month period referred to
immediately above.

If a patient states that a Notice of Privacy Practices was received on a previous visit to the
pharmacy, the employee shall ask the patient if, at the time of receipt of the written Notice of
Privacy Practices, the patient signed the appropriate document available at Barron Pharmacy
acknowledging that the patient received the Notice of Privacy Practices.

The written Notice of Privacy Practices of Barron Pharmacy shall be posted in a conspicuous
place, where it can be easily viewed by patients and others.

The written Notice of Privacy Practices shall be placed upon the website of Barron Pharmacy.

The written Notice of Privacy Practices shall remain current and shall be revised as necessary,
with any revised written Notice of Privacy Practices being posted in a conspicuous place,
where it can be easily viewed by patients and others, and made available in printed form for
any person requesting a printed version of the written Notice of Privacy Practices.
Any person who is not a patient, but who requests the written Notice of Privacy Practices of
Barron Pharmacy, is entitled to receive the written Notice of Privacy Practices even though not
a patient.

Patient Acknowledgement
of Receipt of Notice
of Privacy Practices
At any time a patient is given the written Notice of Privacy Practices, the patient shall be
requested to sign the appropriate document available at Barron Pharmacy acknowledging that
the patient received the Notice of Privacy Practices.

If at any time a patient refuses to sign the document acknowledging receipt of the written
Notice of Privacy Practices, the employee shall notify the patient that Barron Pharmacy is
required to obtain the patient's signature. If the patient continues to refuse to sign the
document, then the employee shall notify the Pharmacy Privacy Officer or pharmacist on duty
of the refusal, so that the good faith effort to obtain the signature can be appropriately
documented.

If a patient requests that a Notice of Privacy Practices be provided in a manner other than in
writing, such as by electronic mail, the request shall be referred to the Pharmacy Privacy
Officer.

For patients not able to physically visit Barron Pharmacy, then a reasonable effort shall be
made to deliver the written Notice of Privacy Practices to the patient and obtain the patient's
signature acknowledging receipt of the written Notice of Privacy Practices. In such situations,
delivery can be accomplished by U.S. mail, special courier, electronic mail, delivery to the
patient's home, or delivery to the patient's caregiver who does physically visit the pharmacy. If
acknowledgement of receipt of the written Notice of Privacy Practices cannot be obtained, the
Pharmacy Privacy Officer shall document the good faith effort to deliver the written Notice of
Privacy Practices and obtain the patient's signature acknowledging receipt of the written Notice
of Privacy Practices.

Accommodating Patient Rights
Patients possess a variety of rights related to their PHI at Barron Pharmacy. The rights, in
addition to the right to receive a written Notice of Privacy Practices, include the following:

1. A request for access to pharmacy records;
2. A request to amend pharmacy records;
3. A request for an accounting;
4. A request for confidential communication; and
5. A request to file a complaint.

Any employee receiving a request from a patient related to any of the above-listed patient
rights shall immediately refer the request to the Pharmacy Privacy Officer, and if the Pharmacy
Privacy Officer is not available, the request shall be referred to the pharmacist on duty.

Any patient requesting the exercising of any of the above-listed rights shall be requested to
complete the form that relates to the patient right. However, if a patient refuses to complete the
form, and instead wants to exercise the right based only upon an oral request, the Pharmacy
Privacy Officer or pharmacist on duty shall make a good faith effort to accommodate the
patient request.

Every effort shall be made to accommodate a request of a patient to exercise a right granted
to the patient by HIPAA. All requests to exercise a patient right shall be promptly reviewed and
acted upon by the Pharmacy Privacy Officer. Where a patient is entitled to a written response
to a request to exercise a patient right, the written response shall be provided promptly to the
patient. Documentation of resolution and response of a request to exercise a patient right shall
be placed upon the appropriate Barron Pharmacy form as necessary or required by the form.

The Pharmacy Privacy Officer shall consult with the pharmacist on duty as necessary with
regard to any request related to a patient right.

Uses and Disclosures of PHI
Use and disclosure of PHI shall occur only in accordance with the written Notice of Privacy
Practices of Barron Pharmacy.

With respect to any use and disclosure of PHI, only the minimum necessary PHI shall be used
and disclosed, unless otherwise permitted by the Pharmacy Privacy Officer or pharmacist on
duty who is familiar with the rules concerning the minimum necessary standard.

Only the Pharmacy Privacy Officer and pharmacist on duty shall be allowed to request a
written authorization for a use and disclosure of PHI that is not described in the Notice of
Privacy Practices, or otherwise requires a written authorization pursuant to HIPAA.

Use and disclosure of PHI shall occur only with respect to the employees of Barron Pharmacy
who have an essential need for the PHI in order to carry out their job tasks and responsibilities.
Such employees shall not use or disclose PHI to other employees.

Any use and disclosure of PHI for purposes of marketing must be approved in advance by the
Pharmacy Privacy Officer.

Record Keeping Requirements
The initial written Notice of Privacy Practices and any revised written Notices of Privacy
Practices that may be prepared shall be maintained at Barron Pharmacy for at least six years
from the effective date stated on the written Notice of Privacy Practices.

The document used to record patients' signatures acknowledging receipt of the written Notice
of Privacy Practices shall be maintained at Barron Pharmacy for at least six years from the
date of the last patient signature contained on the document.

Any use and disclosure of PHI that is subject to the HIPAA accounting requirement shall be
maintained in an appropriate database, electronic or written, with performance of routine
backing up, and shall be maintained for at least six years from the date of the use and
disclosure.

All contracts with business associates shall include the HIPAA required "satisfactory
assurances" and shall be maintained in a readily retrievable manner.

Staff Training
Although not all employees will have access to PHI, it is the policy of Barron Pharmacy that all
employees will undergo staff training.

Staff training shall be accomplished by all current employees prior to the HIPAA implementation
deadline of April 14, 2003.

Staff training shall be accomplished within a reasonable time by all employees hired after the
HIPAA implementation deadline of April 14, 2003.

Staff training programs and materials shall be modified as needed to remain current, and all
employees shall be retrained as necessary.

Cooperation with Investigations and Compliance Reviews
It is the policy of Barron Pharmacy to fully cooperate with any investigation or compliance
review concerning the compliance of Barron Pharmacy with the HIPAA privacy standards.
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