Our Privacy Practices

Your information. Your Rights. Your Responsibilities.

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.

Effective Date: January 19, 2026

If you have any questions about this notice, please contact:

Privacy Officer: Hannah Bowman Title: Health Information Manager Phone: 412-325-4229

A. OUR COMMITMENT TO YOUR PRIVACY

LIFE Pittsburgh is a Program of All-Inclusive Care for the Elderly (PACE) organization. We are committed to protecting the privacy of your medical information and complying with all applicable federal and state laws, including the Health Insurance Portability and Accountability Act (HIPAA), Medicare and Medicaid requirements, and the PACE regulations.

In conducting our business, we create and maintain records about you and the care and services you receive. These records are our property; however, the information in them belongs to you. We are required by law to:

• Maintain the privacy and confidentiality of your medical information

• Provide you with this Notice of Privacy Practices describing our legal duties and privacy practices

• Follow the terms of this notice currently in effect

This notice explains:

• How we may use and disclose your medical information

• Your rights regarding your medical information

• Our legal duties regarding your medical information

Changes to This Notice

We reserve the right to change this notice at any time. Any changes will apply to all medical information we maintain, including information created or received before the change. The current notice will be posted in our facilities and available upon request.

B. HOW WE MAY USE AND DISCLOSE YOUR MEDICAL INFORMATION

The following categories describe the ways we may use and disclose your medical information. Not every use or disclosure is listed, but all permitted uses fall within these categories.

Treatment

We may use and disclose your medical information to provide, coordinate, or manage your health care and related services. This includes sharing information among physicians, nurses, therapists, social workers, and other members of your care team.

Interdisciplinary Team (IDT)

PACE services are delivered through an Interdisciplinary Team (IDT). We may share your medical information among IDT members and with contracted providers to assess your needs, develop and update your plan of care, and ensure appropriate delivery of PACE services.

Payment

We may use and disclose your medical information to obtain payment for services provided to you. This includes billing Medicare, Medicaid, and other responsible parties, determining eligibility, and verifying enrollment and capitation payments.

Health Care Operations

We may use and disclose your medical information for health care operations, including quality assessment and improvement activities, program management, care coordination, training, accreditation, licensing, audits, and compliance with PACE program requirements.

PACE Program Administration and Oversight

As a PACE organization, LIFE Pittsburgh participates in the Medicare and Medicaid programs and is subject to oversight by the Centers for Medicare & Medicaid Services (CMS) and the Pennsylvania Department of Health. We may use and disclose your medical information as necessary for PACE program administration, monitoring, audits, quality improvement, compliance reviews, enrollment activities, and capitation validation.

Treatment Alternatives and Health-Related Services

We may use and disclose your medical information to inform you about treatment options, benefits, or services that may be of interest to you.

Participant Directory

While you are a PACE participant, we may include limited information about you in a directory, such as your name, general condition, and religious affiliation. Directory information (except religious affiliation) may be shared with individuals who ask for you by name. You may opt out of the directory by notifying the Privacy Officer.

C. OTHER PERMITTED USES AND DISCLOSURES

Required by Law

We may use or disclose your medical information when required by federal, state, or local law.

Public Health Activities

We may disclose your medical information for public health purposes, including preventing or controlling disease, reporting abuse or neglect, reporting reactions to medications, and responding to product recalls, as required by law.

Abuse, Neglect, or Domestic Violence

We may disclose your medical information to appropriate government authorities if we believe you are a victim of abuse, neglect, or domestic violence, unless disclosure would place you at risk of harm.

Health Oversight Activities

We may disclose your medical information to health oversight agencies for activities authorized by law, including audits, investigations, inspections, licensure, certification, and compliance monitoring related to the PACE program.

Legal Proceedings and Law Enforcement

We may disclose your medical information in response to court orders, subpoenas, or other lawful processes, and to law enforcement officials as permitted by law.

Coroners, Medical Examiners, and Funeral Directors

We may disclose medical information to coroners, medical examiners, or funeral directors as necessary.

Serious Threats to Health or Safety

We may use or disclose your medical information to prevent or lessen a serious and imminent threat to your health or safety or that of others.

Specialized Government Functions

We may disclose medical information for military, national security, intelligence, or protective services activities as required by law.

Workers’ Compensation

We may disclose your medical information for workers’ compensation or similar programs.

Contractors and Business Associates

We may share your medical information with contractors, vendors, and business associates that perform services on our behalf, such as transportation providers, home care agencies, pharmacies, and adult day service providers. These entities are required by law and by contract to protect your information.

D. USES AND DISCLOSURES REQUIRING YOUR AUTHORIZATION

We will obtain your written authorization before using or disclosing your medical information for purposes not described in this notice or not otherwise permitted by law.

Specifically, we will not use or disclose your medical information without your written authorization for:

• Marketing purposes

• The sale of your medical information

• Most uses and disclosures of psychotherapy notes

You may revoke your authorization in writing at any time, except to the extent that action has already been taken based on your authorization.

Your Choices Regarding Your Health Information

For certain health information, you have the right to tell us your preferences about how we share your information. If you have a clear preference, please let us know, and we will follow your instructions, except where disclosure is required by law.

You have the right to choose whether we may:

• Share information with your family members, close friends, or others involved in your care or payment for your care

• Share information in a disaster relief situation

• Include limited information about you in a participant directory

If you are unable to tell us your preference (for example, if you are unconscious), we may share your information if we believe it is in your best interest or to prevent a serious and imminent threat to health or safety.

Certain uses and disclosures of your health information require your written authorization, as described below.

• YOUR RIGHTS REGARDING YOUR MEDICAL INFORMATION

You have the right to:

• Request restrictions on certain uses and disclosures

You have the right to request a restriction on our use or disclosure of your medical information for treatment, payment or health care operations. Additionally, you have the right to request that we limit our disclosure of your medical information to individuals involved in our care or the payment for your care, such as family members and friends.

We are not required to agree to your request; however, if we do agree, we are bound by our agreement except when otherwise required by law, in emergencies, or when the information is necessary to treat you.

To request a restriction on our use or disclosure of your medical information, you must make your request in writing to Hannah Bowman, Health Information Manager. Your request must be stated in a clear and concise fashion:

(1) the information you wish restricted.

(2) whether you are requesting to limit our practice’s use disclosure or both; and

(3) to whom you want the limits to apply.

• Request confidential communication

You have the right to request that LIFE Pittsburgh communicate with you about your health and related issues in a particular manner, or at a certain location. For instance, you may ask that we contact you by telephone, or at home, rather than at work.

To request a type of confidential communication, you must make a written request to Hannah Bowman specifying the requested method of contact, or the location where you wish to be contacted. LIFE Pittsburgh will accommodate reasonable requests. You do not need to give a reason for your request.

• Inspect and obtain a copy of your medical information

You have the right to inspect and obtain a copy of the medical information that may be used to make decisions about you, including patient medical records and billing records, but not including psychotherapy notes. You must submit your request in writing to Hannah Bowman in order to inspect and/or obtain a copy of your medical information.

• Request amendments to your medical information

You may ask us to amend your medical information if you believe it is incorrect or incomplete, and you may request an amendment for as long as the information is kept by or for LIFE Pittsburgh. You must provide us with a reason that supports your request for amendment.

LIFE Pittsburgh will deny your request if you fail to submit your request (and the reasoning

supporting the request) in writing. Also, we may deny your request if you ask us to amend

information that is:

 accurate and complete

 not part of the medical information kept by or for LIFE Pittsburgh

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

 not created by LIFE Pittsburgh, unless the individual or entity that created the

 information is not available to amend the information.

• Receive an accounting of disclosures

You have the right to request an accounting of disclosures. An accounting of disclosures is a list of certain disclosures LIFE Pittsburgh has made of your medical information.

All requests for an accounting of disclosures must state a time period that may not be longer than six years and may not include dates before January 19, 2016. The first list you request within a 12-month period is free of charge, but our practice may be to charge you for additional requests within the same 12-month period. LIFE Pittsburgh will notify you of any costs involved with additional requests, and you may withdraw your request before you incur any costs.

• Obtain a paper copy of this notice

You are entitled to receive a paper copy of our notice of privacy practices. You may ask us to

give you a copy of this notice at any time. To obtain a copy of this notice, contact Hannah Bowman.

• File a complaint without fear of retaliation

If you believe your privacy rights have been violated, you may file a complaint with LIFE

Pittsburgh. To file a complaint, contact Hannah Bowman at 412-325-4229. All complaints must be submitted in writing.

Requests must be made in writing to Hannah Bowman, LIFE Pittsburgh Privacy Officer. Fees may apply as permitted by law.

E. COMPLAINTS

If you believe your privacy rights have been violated, you may file a complaint with LIFE Pittsburgh or with the U.S. Department of Health and Human Services. You will not be retaliated against for filing a complaint.

You may also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, by mail, phone, or online. Filing a complaint will not affect your benefits, and LIFE Pittsburgh will not retaliate against you for filing a complaint.

U.S. Department of Health and Human Services Office for Civil Rights 200 Independence Avenue, SW Washington, D.C. 20201 Phone: 1-877-696-6775 Website: https://www.hhs.gov/hipaa/filing-a-complaint/

This Notice of Privacy Practices is intended to comply with HIPAA and CMS PACE Manual Chapter 4 requirements.



LIFE Pittsburgh 875 Greentree Road, One Parkway Center, Pittsburgh, PA 15220 - 412-388-8050