NOTICE OF PRIVACY PRACTICES
Effective Date: July 1, 2004

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED OR DISCLOSED AND HOW YOU CAN ACCESS THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

At CCS Medical, we are committed to using your health information responsibly and in compliance with the law. This Notice of Privacy Practices, which is required by federal, is intended to help you understand how we collect, use and disclose your health information.

WHO MUST ABIDE BY THE NOTICE

CCS Medical, Inc. and its related entities, their employees, staff and other personnel (collectively “CCS Medical”), including:

DEGC Enterprises (U.S.), Inc.	KeyMed, Inc.	Medical Express Depot, Inc.
MedShip Direct, Inc.	MP TotalCare, Inc.	MP TotalCare Medical, Inc.
MP TotalCare Services, Inc.	Secure Care Medical, Inc.	MedStar Diabetic Supply, LP

UNDERSTANDING YOUR PROTECTED HEALTH INFORMATION

Your health information includes information on your diagnosis, treatment, medical supplies needed, prescriptions and future plan of treatment. These records are used to plan your care and to communicate with other healthcare providers about your care.

OUR LEGAL DUTIES

• We are required by law to maintain the privacy of your health information and to provide you a copy of this Notice.
• We are required to abide by the terms of this Notice until we adopt a new one.
• We are required to post our current Notice on our web site: www.ccsmed.com

YOUR RIGHTS

Although your health record is the physical property of CCS Medical, the information belongs to you. By law, you have the following rights:

• You have the right to access your health information in our medical records, subject to certain limitations. Please make this request in writing to our Privacy Officer. Your request must be signed and it should specifically list the information you want copied (i.e. “I want copies of my records from June 1, 2003 - October 31, 2003.”). We may charge a fee for the cost of providing the records.
• You have the right to obtain an accounting of certain disclosures of your information. This is a list of the times we have given your information to others after April 14, 2003 for purposes other than treatment, payment and healthcare operations or releases pursuant to a signed authorization. Your request should be in writing and sent to the Privacy Officer. We may charge a fee for providing more than the first list. The right to receive this information is subject to certain exceptions, restrictions and limitations.
• You have the right to ask us to communicate with you at a special address or by special means. We will not ask for an explanation. We will agree to reasonable requests which are made request in writing to our Privacy Officer.
• You have the right to ask us, in writing, to restrict how we use or disclose your health information.
  We will consider your request, but we are not required to agree to it.
• You have the right to ask us to amend your health information you believe is incorrect or incomplete. You must make this request in writing to the Privacy Officer and explain the reason you believe the information is not correct or complete. We may deny your request if we did not create the information, if it is not part of the records we use to make decisions about you, if it is not something you would be permitted to inspect or copy, or if it is complete and accurate.
• We may ask for your written authorization if we plan to use or disclose your health information for reasons not covered in this Notice. If you authorize us to use or disclose your information, you have the right to revoke the authorization at any time, in writing, unless we have released information prior to receiving your revocation. For more information about authorizations, please contact our Privacy Officer.

WE MAY USE AND DISCLOSE YOUR HEALTH INFORMATION IN THE FOLLOWING WAYS

CCS Medical is required to inform you of how we may use your health information. We may use your health information for a number of purposes, including treatment, payment and healthcare operations. For each purpose, we have written a brief explanation.

Service and Treatment - As it pertains to CCS Medical, treatment means providing you with medications, supplies and durable medical equipment services as ordered by your physician. Treatment also includes coordination and consultation with your physician and other healthcare providers.

Payment - We will use and disclose your information as necessary to obtain payment for the services and supplies we provide to you.

Friends and Family - We may disclose to a family member, other relative, close personal friend or any other person identified by you, the health information directly relevant to such person's involvement with your care or payment related to your health care.

Healthcare Operations - We may use or disclose your health information for activities that are needed to operate CCS Medical, such as compliance, quality assurance, business planning and management, certain marketing activities and general administrative activities.

Information to Patients - We may use your health information to provide you with information about treatment options or other health-related services.
Required by Law or Law Enforcement - We may disclose your health information to others as required by law. This may include reporting information to government agencies that monitor the health care system. This also includes providing information to locate a suspect, fugitive, missing person or in connection with suspected criminal activity. We may also disclose information in response to court orders, subpoenas or other lawful requests.

Public Health and Oversight - We may disclose health information to agencies authorized by law to conduct health oversight activities, including audits, investigations, licensing and similar activities.

To Report Abuse - We may disclose health information when the information relates to a victim of abuse, neglect or domestic violence.

Other Specialized Purposes - We may disclose your health information for a number of other specialized purposes. We will only disclose as much information as is necessary for the purpose. Under certain circumstances, we may disclose information to avert a serious threat or harm.

Business Associates - We may disclose health information to attorneys, accountants and other non-employees acting on behalf of CCS Medical. These individuals or entities are called Business Associates and they are asked to sign written contracts agreeing to safeguard the confidentiality of your information.

CHANGES TO THIS NOTICE

Please be advised that CCS Medical reserves the right to change the terms of its Notice of Privacy Practices and to make those changes applicable to all health information maintained at that time.

Any new or revised Notices are available upon request or by visiting www.ccsmed.com.

FOR MORE INFORMATION, TO REPORT A PROBLEM OR FILE A COMPLAINT

Please contact:

CCS Medical
Attn: Privacy Officer
14255 49th St N, Suite 301
Clearwater, FL 33762
Toll Free 1-866-885-9087

If you think your privacy has been violated, you may also file a complaint with the Secretary of the Department of Health and Human Services.

To file a complaint with the Community Health Accreditation Program (CHAP), contact 1-800-656-9656.

For Florida Residents Only- To report a complaint to Florida’s Agency for Healthcare Administration (AHCA) regarding the services that you receive, please call toll free 1-888-419-3456.
To report non-emergency concerns of abuse, neglect or exploitation, please call toll free 1-800-96-ABUSE (22873).

We will not retaliate against you for filing a complaint.

MEDICARE SUPPLIER STANDARDS

1. A supplier must be in compliance with all applicable Federal and State licensure and regulatory requirements.
2. A supplier must provide complete and accurate information on the DMEPOS supplier application. Any changes to this information must be reported to the National Supplier Clearinghouse within 30 days.
3. An authorized individual (one whose signature is binding) must sign the application for billing privileges.
4. A supplier must fill orders from its own inventory, or must contract with other companies for the purchase of items necessary to fill the order. A supplier may not contract with any entity that is currently excluded from the Medicare program, any State health care programs, or from any other Federal procurement or non-procurement programs.
5. A supplier must advise beneficiaries that they may rent or purchase inexpensive or routinely purchased durable medical equipment, and of the purchase option for capped rental equipment.
6. A supplier must notify beneficiaries of warranty coverage and honor all warranties under applicable State law, and repair or replace free of charge Medicare covered items that are under warranty.
7. A supplier must maintain a physical facility on an appropriate site.
8. A supplier must permit CMS, or its agents to conduct on-site inspections to ascertain the supplier's compliance with these standards. The supplier location must be accessible to beneficiaries during reasonable business hours, and must maintain a visible sign and posted hours of operation.
9. A supplier must maintain a primary business telephone listed under the name of the business in a local directory or a toll free number available through directory assistance. The exclusive use of a beeper, answering machine or cell phone is prohibited.
10. A supplier must have comprehensive liability insurance in the amount of at least $300,000 that covers both the supplier's place of business and all customers and employees of the supplier. If the supplier manufactures its own items, this insurance must also cover product liability and completed operations.
11. A supplier must agree not to initiate telephone contact with beneficiaries, with a few exceptions allowed. This standard prohibits suppliers from calling beneficiaries in order to solicit new business.
12. A supplier is responsible for delivery and must instruct beneficiaries on use of Medicare covered items, and maintain proof of delivery.
13. A supplier must answer questions and respond to complaints of beneficiaries, and maintain documentation of such contacts.
14. A supplier must maintain and replace at no charge or repair directly, or through a service contract with another company, Medicare-covered items it has rented to beneficiaries.
15. A supplier must accept returns of substandard (less than full quality for the particular item) or unsuitable items (inappropriate for the beneficiary at the time it was fitted and rented or sold) from beneficiaries.
16. A supplier must disclose these supplier standards to each beneficiary to whom it supplies a Medicare-covered item.
17. A supplier must disclose to the government any person having ownership, financial, or control interest in the supplier.
18. A supplier must not convey or reassign a supplier number; i.e., the supplier may not sell or allow another entity to use its Medicare billing number.
19. A supplier must have a complaint resolution protocol established to address beneficiary complaints that relate to these standards. A record of these complaints must be maintained at the physical facility.
20. Complaint records must include: the name, address, telephone number and health insurance claim number of the beneficiary, a summary of the complaint, and any actions taken to resolve it.
21. A supplier must agree to furnish CMS any information required by the Medicare statute and implementing regulations.
22. All suppliers must be accredited by a CMS-approved accreditation organization in order to receive and retain a supplier billing number. The accreditation must indicate the specific products and services, for which the supplier is accredited in order for the supplier to receive payment of those specific products and services (except for certain exempt pharmaceuticals).
23. All suppliers must notify their accreditation organization when a new DMEPOS location is opened.
24. All supplier locations, whether owned or subcontracted, must meet the DMEPOS quality standards and be separately accredited in order to bill Medicare.All suppliers must disclose upon enrollment all products and services, including the addition of new product lines for which they are seeking accreditation.
25. Suppliers must meet the surety bond requirements specified in 42 CFR 424.57(c).

STATEMENT OF PATIENT PRIVACY RIGHTS (MEDICARE/MEDICAID/INSURANCE)

• You have the right to know why we need to ask you questions. We are required by law to collect health information to make sure:
  1) You get quality health care, and 2) Payment for Medicare/Medicaid and insurance patients is correct.
• You have the right to have your personal healthcare information kept confidential.
  See our Notice of Privacy Practices
• You have the right to refuse to answer questions.
  We may need help in collecting your health information. If you choose not to answer, we will fill in the information as best we can. You do not have to answer every question to receive services.
• You have the right to look at your personal health information.
  See our Notice of Privacy Practices

ACCOUNT BALANCE POLICY

It is our policy to review all customer accounts with unpaid balances greater than 60 days to determine whether the account is eligible to receive additional shipments of supplies or should be placed on hold. Hold means that we cannot ship new supply orders until the unpaid balance is resolved. It is also our policy to make every effort to work with our customers and their insurers so that it is not necessary to put an account on hold. In the unlikely event that your account is placed on hold and you feel there is information we have not considered, please immediately contact our Reimbursement Department at 1-800-557-8568.

Our Commitments to You

CCS Medical is committed to providing you with the supplies you need.
CCS Medical is committed to providing you with exceptional service regardless of your race, disability, national origin or religion.
CCS Medical is committed to ensuring that your personal information is protected and used appropriately in accordance with the Health Insurance Portability and Accountability Act (“HIPAA”) and CCS Medical’s “Notice of Privacy Practices”.
CCS Medical is committed to providing you with copies of your requested medical records in accordance with HIPAA and CCS Medical’s “Notice of Privacy Practices”.
CCS Medical is committed to providing you with a clear explanation of your charges and insurance payments upon request.
CCS Medical is committed to providing you with friendly customer service representatives that can assist you should a question or problem arise.

Our Expectations

CCS Medical expects you to inform us of any change in your healthcare status.
CCS Medical expects you to inform us should you change your physician.
CCS Medical expects you to inform us of any change of your insurance and/or coverage.
CCS Medical expects you to inform us of any address/ telephone changes.
CCS Medical expects you to promptly fulfill your financial obligations for the supplies that you receive.
CCS Medical expects you to inform us of any safety and/or service concerns that you have.
CCS Medical expects you to respect our staff.
CCS Medical expects you to honor the treatment plan recommended by your physician.