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.

I. Who We Are

This Notice describes the privacy practices of American Exchange Life Insurance Company; American Pioneer Health Plans, Inc.; American Pioneer Life Insurance Company; American Progressive Life & Health Insurance Company of New York; Constitution Life Insurance Company; GlobalHealth, Inc.; Marquette National Life Insurance Company; MemberHealth, LLC; Pennsylvania Life Insurance Company; SelectCare Health Plans, Inc.; SelectCare of Oklahoma, Inc.; SelectCare of Texas, LLC; The Pyramid Life Insurance Company and Union Bankers Insurance Company (“we” or “us”) as wholly owned subsidiaries of Universal American, as well as the managed care organizations owned or operated by Heritage Health Systems, Inc. (Abri Health Plan, Inc.’s Medicare Advantage plans are administered by us).

We provide health benefits to you under the terms of your health insurance policy (“Your Health Plan”).

II. Our Privacy Obligations

We are required by federal and state law to protect the privacy of individually identifiable health information about you (“Your Protected Health Information”) and to provide you with this Notice of our legal duties and privacy practices. When we use or disclose Your Protected Health Information, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).

State Pre-emption – Some states’ laws are more stringent than Federal Privacy laws with regard to these requirements. We will comply with all applicable laws.

III. Uses and Disclosures for Payment and Health Care Operations

A. We may use and disclose to others Your Protected Health Information as necessary to pay your healthcare provider(s) for health benefits covered by Your Health Plan or for other healthcare operations necessary to provide these health benefits to you, without your express, implied, or specific consent or authorization. In addition and without limitation, we may use and disclose to others Your Protected Health Information as follows:

1. Payment. We may use and disclose Your Protected Health Information to obtain payment of our premiums and to determine and fulfill our responsibility to provide health benefits under Your Health Plan — for example, to make coverage determinations, administer claims and coordinate benefits with other coverage you may have.

2. Health Care Operations. We may use and disclose Your Protected Health Information for our health care operations — for example, to do business planning, provide customer service and conduct quality assessment and improvement activities.

3. Treatment. We may use and disclose Your Protected Health Information for our health care operations — for example, to do business planning, provide customer service and conduct quality assessment and improvement activities.

B. Use or Disclosure with Your Authorization. We may use or disclose Your Protected Health Information for any reason other than payment and health care operations only when (1) you give us your written authorization (“Your Authorization”) or (2) there exists an exception as described in Section IV below. You may revoke Your Authorization, except to the extent we have taken action in reliance on it, by delivering a written revocation statement to the Privacy Office identified below.

IV. Uses and Disclosures Without Your Consent or Your Authorization

A. As Required by Law. We will use or disclose Your Protected Health Information when required to do so by applicable international, federal, state or local law.

B. Business Associates. We may disclose Your Protected Health Information to our business associates that perform functions on our behalf or provide us with services if the information is necessary for such functions or services. For example, we may use another company to perform administration services on our behalf with respect to Your Health Plan. All of our business associates are obligated, under contracts with us, to protect the privacy of Your Protected Health Information and are not allowed to use or disclose any information other than as specified in our contract.

C. Marketing Communications. We may use and disclose Your Protected Health Information for marketing communications made by us to you.

D. Public Health Activities. We may disclose Your Protected Health Information for the following public health activities and purposes: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse or neglect to the government authority authorized by law to receive such reports; and (3) to alert a person who may have been exposed to a communicable disease.

E. Victims of Abuse, Neglect or Domestic Violence. We may disclose Your Protected Health Information if we reasonably believe you are a victim of abuse, neglect or domestic violence to the appropriate state agency as required or permitted by applicable state law.

F. Health Oversight Activities. We may disclose Your Protected Health Information to a government agency that oversees the health care system or ensures compliance with the rules of government health programs such as Medicare or Medicaid.

G. Judicial and Administrative Proceedings. We may disclose Your Protected Health Information in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

H. Law Enforcement Officials. We may disclose Your Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order or other lawful process.

I. Health or Safety. We may disclose Your Protected Health Information to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety.

J. Specialized Government Functions. We may disclose Your Protected Health Information to units of the government with special functions, such as any branch of the U.S. military or the U.S. Department of State.

K. Workers’ Compensation. We may release Your Protected Health Information for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness.

L. Disclosure to You. We may disclose your medical information to you.

M. Disclosures to Individuals Involved with Your Health Care. We may use or disclose your medical information in order to tell someone responsible for your care about your location or condition. We may disclose your medical information to your relative, friend, or other person you identify, if the information relates to that person’s involvement with your health care or payment for your health care.

N. Research. We may use or disclose Your Protected Health Information, such as your medical information, for purposes of research if we first confirm that your privacy rights will be protected, for instance if a privacy board or Institutional Review Board determines that your privacy will not be put at risk and informs us of its determination.

V. Your Individual Rights

A. For Further Information; Complaints. If you desire further information about your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to Your Protected Health Information, you may contact our Privacy Office. You may also file written complaints with the Secretary of the U.S. Department of Health and Human Services. Upon request, the Privacy Office will provide you with the correct address for the Secretary. We will not retaliate against you if you file a complaint with us or the Secretary.

B. Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of Your Protected Health Information for payment and health care operations in addition to those explained in this Notice. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction. If you wish to request additional restrictions, please obtain a request form from our Privacy Office and submit the completed form to the Privacy Office. We will send you a written response.

C. Right to Receive Confidential Communications. We accommodate any reasonable request for you to receive Your Protected Health Information by alternative means of communication or at alternative locations.

D. Right to Inspect and Copy Your Protected Health Information. You may request access to our records that contain Your Protected Health Information in order to inspect and request copies of the records. Under limited circumstances, we may deny you access to a portion of your records. If you desire access to your records, please obtain a record request form from the Privacy Office and submit the completed form to the Privacy Office. If you request copies, we will charge you copying and mailing costs.

E. Right to Amend Your Records. You have the right to request that we amend Your Protected Health Information maintained in our enrollment, payment, claims adjudication and case or medical management records or other records used, in whole or in part, by or for us to make decisions about you. If you desire to amend these records, please obtain an amendment request form from the Privacy Office and submit the completed form to the Privacy Office. We will comply with your request unless special circumstances apply. If your physician or other health care provider created the information that you desire to amend, you should contact the provider to amend the information.

F. Right to Receive An Accounting of Disclosures. Upon request, you may obtain an accounting of certain disclosures of Your Protected Health Information made by us on or after April 14, 2003, excluding disclosures made earlier than six years before the date of your request. If you request an accounting more than once during a twelve (12) month period, we will charge you $.50 per page of the accounting statement and $5 per hour for clerical work necessary to complete the requested accounting.

G. Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice.

VI. Effective Date and Duration of This Notice

A. Effective Date: This Notice is effective on April 14, 2003.

B. Right to Change Terms of this Notice. We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all of Your Protected Health Information that we maintain, including any information we created or received prior to issuing the new notice. If we change this Notice, we will send the new notice to you if you are then covered by us. In addition, we will post any new notice on our Internet site at www.uafc.com.You also may obtain any new notice by contacting the Privacy Office.

VII. Privacy Office

You may contact the Privacy Office at:

For American Exchange Life Insurance Company, American Pioneer Life Insurance Company, American Progressive Life and Health Insurance Company of New York, Constitution Life Insurance Company, Marquette National Life Insurance Company, Pennsylvania Life Insurance Company, The Pyramid Life Insurance Company, and Union Bankers Insurance Company.

Privacy Office
Universal American
1001 Heathrow Park Lane
Suite 5001
Lake Mary, FL 32746
E-mail: PrivacyOffice@uafc.com

For Heritage Health Systems, Inc.; SelectCare of Texas, L.L.C.; SelectCare Health Plans, Inc.; American Pioneer Health Plans, Inc.; SelectCare of Oklahoma, Inc.; GlobalHealth, Inc. and Abri Health Plan, Inc.

Privacy Office
Heritage Health Systems, Inc.
4888 Loop Central Drive
Suite 700
Houston, Texas 77081