Related Conflict of Interest Policies

Title : Relationships with Post-Acute Services Providers Number : 920, Version : 8

I. Purpose/Population: A. Purpose : To provide guidance regarding facility and patient access that may be given to providers of Post-acute Services, both affiliated and non-affiliated with Banner Health (“BH”), and to restrict relationships between non-BH affiliated providers and BH employees designed to solicit patient referrals. B. Population : All Employees. II. Definitions: A. BH Provider: A provider of Post-acute Services that is owned or managed by BH. B. Non-BH Provider: A provider of Post-acute Services that is not owned or managed by BH. C. Patient: Patient, patient’s family or legally authorized representative. D. Post-acute Services: Home health care, hospice, acute rehabilitation facilities, behavioral health facilities, infusion or home medical equipment services, skilled nursing facilities and long-term acute care hospitals. E. Post-acute Services Provider: A provider of Post-acute Services, including both BH Providers and Non-BH Providers. III. Policy: A. This policy does not apply to reviews of medical record and other patient information by representatives of payors who are financially responsible for the reimbursement of health care services provided to patients in BH facilities and who have been properly authorized to review such information and does not apply to relationships with providers of non-Post-acute Services. B. Patient/Medical Record Access Policy. 1. Patients admitted to BH facilities have rights regarding privacy and confidentiality with respect to their person and their medical information. Accordingly, BH will assure that only authorized Post-acute Services Providers are given access to Patients and BH maintained medical records. Patient authorization can be explicit (with specific verbal or written consent) or can be implicit (i.e., those selected providers with a legitimate need to know confidential information in order to further the delivery of care to the patients who have selected them). 2. BH personnel will not give representatives of Non-BH Providers the names of patients who have been admitted or discharged from the facility. Similarly, Non-BH Providers should not be given access to and will not be permitted to view a Patient’s medical record without the Patient’s consent. 3. Representatives of BH Providers may receive confidential patient information and access to a patient’s medical records at the request of BH discharge and case management personnel for the sole purpose of consulting with representatives of BH Providers with respect to the appropriate discharge plan and placement of such patient. 4. Information regarding the number of referrals made to Non-BH Providers may not be released to Non-BH Providers unless mandated by law or any third-party payor contract to which BH is a party. Such information may, however, be provided to BH providers. 5. Post-acute Services Providers who have been selected by a patient will be provided with discharge orders and other information necessary to provide Post-acute Services to that

Page 2 of 5