Jackson Purchase Medical Center Clinical Student Orientation Form

Please read all written materials. Ask your instructor to explain any information that you do not understand.

1. Mission, Vision, and Value Statements 2. Information Security Awareness 3. Tobacco Free Campus 4. Student Parking 5. Infection Control 6. Environment of Care Safety and Emergency Codes 7. Population Specific Issues and Cultural Awareness 8. Patient Safety 9. Do Not Use Abbreviations 10. Patient Rights and Responsibilities 11. Pain 12. Dress Code 13. Code of Conduct 14. HIPAA 15. Meditech Training Manual (for Nursing Students)

Please send the following documents to our HR department prior to your start date. Fax all information to the attention of JPMC HR to (270)251-4507.

I have read and understand the Jackson Purchase Medical Center Student Orientation Information. All of my questions have been answered satisfactorily.

Print Name:______________________________________________________________________

Signature:________________________________________________________________________

Date:____________________________________________________________________________

School:___________________________________________________________________________

Major/Program:____________________________________________________________________

Start Date:_______________________________ End Date:__________________________________

1. Clinical Student Orientation Form (this form) 2. LifePoint IT&S Security Access Form 3. Confidentiality and Security Agreement 4. HIPAA Acknowledgment 5. Code of Conduct Acknowledgment 6. Personal Data Sheet

7. Drug Screen 8. Background Check 9. Proof of TB skin test 10. Proof of Hepatitis B Vaccine or declination 11. Proof of Blood Borne pathogen Training

LifePoint IT&S Security Access Form (Facility) FIELDS MARKED WITH AN * ASTERIK ARE REQUIRED. FORMS WILL BE RETURNED IF ANY REQUIRED FIELDS ARE LEFT BLANK.

(1) Applicant Last Name*

(2) Applicant First Name*

(3) MI or "NA"*

(4) Work Address

1099 MEDICAL CENTER CIRCLE

(5) City, State, Zip code

MAYFIELD, KY 42066

(6) JPMC Phone Number* EXT.

(7) Date of birth*

(8) SS# of Requester*

(9) User Type* XLife Point Contractor Company name & phone # required for Contractor/Vendor Vendor

(10B) Exp. Date for Contract or Vendor*

Expiration and Approval Requirements Expiration date must be supplied in field 10 for “Contractors” and “Vendors”. The expiration date should be the end of the contract or engagement period.

(14) Department #*

(15) Department Name* or School Name

(16) Job Title* - ie. Nursing Student, etc

(17) Universal ID

(17a.) Network login if different from UID (17b) Domain

LPNT (18) Applicant Signature *

(19) E-Mail Address (20) Date*

Authorizing Security Coordinator Statement

By signing this request I am stating that I have reviewed the above information for completeness and it is accurate to the best of my knowledge. Also I have reviewed the Information Security Agreement and verified that it has been completely filled out and signed. Also that I verify this request and authorize its processing. 2 signatures required.

(21) Managers Signature*

(22) Security Coordinator Signature (23) Date

(24) Managers Printed Name*

(25) Security Coordinators Printed Name

(26) Phone Number of HDIS / LSC

270-251-4263

Applicant has Information Confidentiality & Security Agreement on file Yes No Action*: New Change Delete Terminate Effective Date*:__________

Access Granted By HDIS/LSC Level Other Comments Imaging - Fortis Collections Meditech Internet Access HOST/Mainframe SMART Kronos Additional Access:____________

Confidentiality and Security Agreement I understand that the facility or business entity named below (the “Company”) in which or for whom I work, volunteer or provide services, or with whom the entity (e.g., physician practice) for which I work has a relationship (contractual or otherwise) involving the exchange of health information (the “Company”), has a legal and ethical responsibility to safeguard the privacy of all patients and to protect the confidentiality of their patients’ health information. Additionally, the Company must assure the confidentiality of its human resources, payroll, fiscal, research, internal reporting, strategic planning, communications, computer systems and management information (collectively, with individually identifiable health information and protected health information, “Confidential Information”). In the course of my employment / assignment at the Company, I understand that I may come into the possession of this type of Confidential Information. I will not use company systems to access patient information if it is not necessary to perform my job related duties. This includes NOT accessing my own health information or that of my child or person’s for which I am personal representative via the company systems. The Company’s Privacy and Security Policies available on the Company intranet (on the Security Page) and the internet (under Ethics & Compliance). I further understand that I must sign and comply with this Agreement in order to obtain authorization for access to Confidential Information.

Signing this document, I acknowledge that I have read this Agreement and I agree to comply with all the terms and conditions stated above.

Employee/Consultant/Vendor/Office Staff/Physician Signature Facility Name and COID Date

Employee/Consultant/Vendor/Office Staff/Physician Printed Name Business Entity Name

June 8, 2010 Attachment to LPNT.IS.SEC.005

1. I will not disclose or discuss any Confidential Information with others, including friends or family, who do not have a need to know it.

2. I will not in any way divulge, copy, release, sell, loan, alter, or destroy any Confidential Information except as properly authorized.

3. I will not discuss confidential information where others can overhear the conversation, even if the patient’s name is not used. I will make every reasonable attempt to refrain from practices that might lend itself to unintended breach of patient confidentiality.

4. I will not make any unauthorized transmissions, inquiries, modifications, or purgings of Confidential Information.

5. I agree that my obligations under this Agreement will continue after termination of my employment, expiration of my contract, or my relationship ceases with the Company.

6. Upon termination, I will immediately return any documents or media containing Confidential Information to the Company.

7. I understand that I have no right to any ownership interest in any information accessed or created by me during my relationship with the Company.

8. I will act in the best interest of the Company and in accordance with its Code of Conduct at all times during my relationship with the Company.

9. I understand that violation of this Agreement may result in disciplinary action, up to and including termination of employment, suspension and loss of privileges, and/or termination of authorization to work within the Company, in accordance with the Company’s policies.

10. I will only access or use systems or devices I am officially authorized to access, and will not demonstrate the operation or function of systems or devices to unauthorized individuals.

11. I understand that I should have no expectation of privacy when using Company information systems. The Company may log, access, review, and otherwise utilize information stored on or passing through its systems, including e-mail, in order to manage systems and enforce security.

12. I will practice good workstation security measures such as locking up electronic media devices when not in use, using screen savers with activated passwords appropriately, and position screens away from public view.

13. I will practice secure electronic communications by transmitting Confidential Information only to authorized entities, in accordance with approved security standards.

14. I will:

a. Use only my officially assigned User-ID and password (and/or token (e.g., SecurID card)).

b. Use only approved licensed software.

c. Use a device with virus protection software.

15. I will never:

d. Share/disclose user-IDs, passwords or tokens.

e. Use tools or techniques to break/exploit security measures.

f. Connect to unauthorized networks through the systems or devices.

16. I will notify my manager, Local Security Coordinator (LSC), or appropriate Information Services person if my password has been seen, disclosed, or otherwise compromised, and will report activity that violates this agreement, privacy and security policies, or any other incident that could have any adverse impact on Confidential Information.

The following statements apply to physicians using any Company systems containing patient identifiable health information (e.g. HMS, Meditech, eCW):

17. I will only access software systems to review patient records or Company information when I have a business need to know, as well as any necessary consent. By accessing a patient’s record or Company information, I am affirmatively representing to the Company at the time of each access that I have the requisite business need to know and appropriate consent, and the Company may rely on that representation in granting such access to me.

18. I will accept full responsibility for the actions of my employees who may access the Company software systems and Confidential Information.

19. I have no intention of varying the volume or value of referrals I make to the Company in exchange for Internet access service or for access to any other Company information.

20. I have not agreed, in writing or otherwise, to accept Internet access in exchange for the referral to the Company of any patients or other business.

21. I understand that the Company may decide at any time without notice to no longer provide access to any systems to physicians on the medical staff unless other contracts or agreements state otherwise. I understand that if I am no longer a member of the facility’s medical staff, I may no longer use the facility’s equipment to access the Internet.

I acknowledge that I have received training for LifePoint Hospital’s Patient Privacy Program. I understand that it represents mandatory policies of the organization and my facility, and I agree to abide by it. Signature Position Printed Name Social Security Number Date Facility

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I acknowledge that I have received LifePoint Hospitals’ Code of Conduct. I understand that it representsmandatory policies of the organization, and I agree to abide by it.

Signature______________________________________________________________________________________________

Position _______________________________________________________________________________________________

Printed Name__________________________________________________________________________________________

Date __________________________________________________________________________________________________

Facility ________________________________________________________________________________________________

Acknowledgment

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Personal Data Sheet

Please print

Student Name:________________________________________________________________

Address:_____________________________________________________________________

_____________________________________________________________________________

Telephone Number:____________________________________________________________

In case of emergency notify:

Name:__________________________________________

Relationship:_____________________________________

Telephone Number:_______________________________

Cell Phone Number:_______________________________

Address:_________________________________________

________________________________________________

PATIENT PRIVACY PROGRAM

Health Insurance Portability and Accountability Act- HIPAA

Dear LifePoint Facility Workforce Members, LifePoint Hospitals takes pride in every aspect of patient care provided by our facility staff and business associates. As mentioned in our Code of Conduct brochure, Common Ground, we strive to provide high quality, accessible, and compassionate health care to non-urban communities. Part of that high quality, accessible care includes providing every effort to protect our patient’s privacy. In order to make that possible, we must inform you of what it takes to protect patient health information (PHI) during and as part of your everyday duties that will contribute to the privacy of our patients. We will refer to this information as our Patient Privacy Program. The Patient Privacy Program included in this publication has been developed to help guide us in our compliance requirements for the Health Insurance Portability and Accountability Act of 1996. These compliance requirements apply to all members of the LifePoint Facility Workforce – both paid and unpaid and under our direct control. This Privacy Program will impact your daily activities while at work and at home because it is important that our commitment to patient privacy goes beyond the physical walls of our facilities. Much of this program’s content may seem second nature to you. This is to be expected and understandable. In fact, we expect that you will not find much of this information new or unusual to your current interactions with fellow employees, patients, physicians, and others with whom you work. As with the Code of Conduct we will depend on you to apply your own ethical practices that will help enforce and achieve the principles discussed in this program. Consider this program simply as a way to reinforce and remind you of the Privacy principles crucial to protecting patient information. Nevertheless, situations will arise that are confusing. Again, just as with issues related to the Code of Conduct, you may have questions about the ethical and practical application of the privacy requirements contained in this document. If you have further questions or are faced with a decision that you are not able to make given the resources you have been provided, or just need assistance with a concern or complaint, we urge you to consult your supervisor, another member of the management team, your facility Privacy Officer, the Corporate Privacy Officer or the Ethics and Compliance line a 1-877-508-LIFE (5433). We assure you that there will be no retribution for any inquiry or for reporting a possible breach of the Patient Privacy Program. All LifePoint Facility Workforce members play a critical role in the success of this company and the satisfaction of our patients. Thank you for joining with us in upholding our Patient Privacy Program. Sincerely, Kenneth C. Donahey Chairman and Chief Executive Officer

CONTENTS Purpose of Our Patient Privacy Program………………………………………………………..2

Leadership Responsibilities…………………………………………………………………………..2 Relationships with Our Health Care Partners…………………………………………………3

Patients………………………………..……………………………………………………………3 Notice of Privacy Practices………………………………………………………..3 Emergency Treatment………………………………………………………………3 Patient Rights……………………………………………………………………………………3

Patient Rights to Access…………………………………………………………….3 Right to Amend or Correct………………………………………………………..4 Right to an Accounting of Disclosures………………..………………………4 Alternate/Confidential Communications…………………………………….4 Restrictions on Uses and Disclosures of Patient Information………..4 Affiliated Entities/Healthcare Partnerships…………………………………………..5

The Organized Health Care Arrangement (OHCA)……………………..…………5 Business Associates…………………………………………………………………………….5 Business Information Practices……………………………………………………………………..6

Documentation Retention and Disposal of Information………………6 Retention of Records………………………………………………………………..6 Disposal of Documents & Records……………………………………………..6 Workplace Practices……………………………………………………………………………………..7 Authority and Guidance……………………………………………………………………..7 HIPAA Compliance Program Provisions………………………………………………7 Training………………………………………………………………………………….8 Complaints……………………………………………………………………………..8 Sanctions………………………………………………………………………………..8 Mitigation……………………………………………………………………………….8 HIPAA Committee Objectives……………………………………………………………..8 Privacy Policies & Procedures……………………………………………………………..9 Notice of Privacy Practices……………………………………………………….9 Business Associates…………………………………………………………………9 Minimum Necessary……………………………………………………………….9 Authorization Requirements…………………………………………………..10 Verification……………………………………………………………………………10 Release of Information Standards……………………………………………10 Psychotherapy Notes………………………………………………………………11 Personal Representatives………………………………………………………..11 Marketing & Fundraising………………………………………………………..11 Research……………………………………………………………………………….11 Summary………………………………………………………………………………11

Acknowledgment/Wallet Card……………………………………………………………………..12

TThhee PPuurrppoossee ooff tthhee PPrriivvaaccyy PPrrooggrraamm Our Privacy Program provides guidance to all members of the LifePoint Workforce concerning our daily duties and activities associated with the privacy and confidentiality of our patient’s information. This guidance takes the form of our obligation to comply with the Health Insurance Portability and Accountability Act, Standards for Privacy of Individually Identifiable Health Information, 45 CFR Parts 160 and 164. This obligation applies to all of our workforce who interact with our patients, our affiliated physicians, and business associates. April 14, 2003 was the deadline for compliance with this obligation. This Privacy Program is a critical component of our overall ethics and compliance program. We have developed this program as a method to inform and train our workforce regarding the compliance requirements for the Privacy Standards within the Health Insurance Portability and Accountability Act and comply with applicable state laws and regulations. The Privacy Program is intended to become part of our everyday operations and working processes and be easily understood. In most cases, the compliance requirements will be able to be addressed and carried out by local staff and management. Some subjects may arise in which additional guidance is needed that would require assistance from those directly involved in order to have sufficient direction. We promote local management autonomy in order to meet local needs, however, the policies set forth by this program are mandatory and must be followed.

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All LifePoint Facility Workforce members are obligated to follow our Patient Privacy Program. As with the Code of Conduct, we expect our leaders to set the example of model program compliance.

Our leaders must ensure that those on their team have sufficient information to comply with our privacy program policies, the regulations and applicable laws as well as be a resource for promoting the highest standards of ethical responsibility. Our environment must encourage everyone in the organization to raise concerns when they arise. We must never sacrifice patient privacy in the pursuit of personal curiosity or attempt to inform persons who do not need to know.

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RReellaattiioonnsshhiippss wwiitthh OOuurr HHeeaalltthhccaarree PPaarrttnneerrss Patients Our intent is to provide our patients with the most seamless approach to health care processes as possible. In doing so, we will integrate operational processes and collections of information between our other healthcare partners whenever possible. Our healthcare partners are defined as other providers involved with the patient care process such as our medical staff physicians, allied health professionals, etc. For this reason, certain regulations require providers to notify patients of their privacy practices. Therefore, upon admission, each patient is provided with a written statement informing them of our privacy practices. This document is referred to as our Notice of Privacy Practices. Notice of Privacy Practices: This notice describes how patient health information is used and how it may be disclosed as part of our everyday treatment, payment, and operations purposes. It explains patient rights concerning how the patient can make decisions about their health information and what mandatory reasons may require disclosure of their health information. The notice also provides information as to how a patient or employee can report a concern or file a complaint. The notice will be provided to each patient upon the first visit to one of our facilities and anytime requested thereafter. The patient will be asked to acknowledge their receipt of the Notice in writing. Emergency Treatment: Patient care and the rules regarding how patient information is used or disclosed will never interfere with emergency treatment situations. While certain regulations require information to be handled in specific ways, it is not the intent of these regulations to cause any interruption in patient care. For this reason, there may be some exceptions to the statements made in the Notice of Privacy Practices. These determinations will be made by qualified personnel on an as needed basis and only when faced by decisions that are in the best interest of the patient’s care and safety. Patient Rights In addition to patient rights related to treatment processes, patients also have certain rights as to how their information is used and disclosed. These rights include: Patient Right to Access: Patients have the right to access any of their information that is defined as part of our facility designated record set. A designated record set is defined as the portions of patient information that are collected and retained by our facilities or business associates and used to make decisions about the patient. This information includes both clinical and financial information. A patient can request to see, read, and even ask for a copy of their information.

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If the request is not urgent or needed for continued care, our facility staff can take up to 30 days in most cases to fulfill this request, longer if the information is not stored on the facility premises. At any rate, the patient should always be notified within 30 days or sooner regarding what the status of their request is. In most cases, the request may even be fulfilled the same day. Right to Amend or Correct: Should a patient read or see something in their patient information that they may feel is not correct or needs further clarification; they have the right to request that the information be amended or corrected. Usually, our staff will need to confirm the request with the healthcare professional that made the entry. Once this has been done, the patient will be notified as to whether their request can be fulfilled. There may be some instances that the request is denied based on the author’s opinion regarding the accuracy of the information, or the ability to make the correction based on the availability of the record and/or the technical capability to do so. In any case, the patient should always be notified within 30 days of the status of their request, preferably in writing. Right to an Accounting of Disclosures: Patients also have the right to request a listing of uses or disclosures of their information that may have been made without their authorization. Remember, patient information can include anything listed as part of the facility designated record set. Our facilities are required by certain state and federal regulations to release patient information for purposes such as law enforcement and public health reasons. We keep a listing of uses such as this in case the patient should ask to be informed of these uses. Sometimes it takes significant resources to prepare this listing, which is why we have up to 60 days to fulfill the request. In any case, the patient should be notified of the status of their request within 60 days, also preferably in writing. Alternate/Confidential Communications: Another request that can be made by a patient is that we cooperate with requests to communicate with the patient at another address or phone number than the one they registered with. There may be reasons, not required to be explained, that a patient prefers to not have information mailed or called to the registration address or other address on file. It is our intent to comply with this request but if the patient cannot give a sound alternate point of communication then there may be times that we cannot agree. If the patient does not respond to communications provided at the alternate locations, then we may, after a reasonable period of time, attempt to communicate with the patient if necessary at other addresses we have on file. This will likely only be done when continued care or billing requires more aggressive efforts. Restrictions on Uses and Disclosures of Patient Information: Even though we explain or give examples of how we intend to use patient information, there may be times when the patient requests additional restrictions as to how their information is used or disclosed. Patients have the right to request that access or disclosure of their information be restricted and we will attempt to honor the requests if possible. We will not be able to restrict uses or disclosures related to treatment, for the facility’s internal operations, or if it is after we have already used or disclosed information. We will try to accommodate other requests to the best of our ability to do so.

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Affiliated Entities/Healthcare Partnerships Affiliated health care professionals, primarily physicians that share common ownership, may be designated or integrated within our health care components as a single covered entity. This will provide for a smooth and seamless visit and treatment process for patients within our facilities. We must structure our affiliated relationships so that we are in compliance with legal requirements. Such arrangements will promulgate a single encounter and documentation process for the patient. The most common arrangement that you will see when we have an affiliation with another physician or treatment service will be an Organized Healthcare Agreement (OHCA) or perhaps a Business Associate relationship. These affiliations are often crucial to completing the treatment process for many of our facilities. The Organized Healthcare Arrangement (OHCA) The arrangement referred to as an OHCA allows our affiliated partners to use and disclose patient information with each other without the need for separate patient authorization and other regulatory requirements of HIPAA. Other examples of an OHCA may include a clinically integrated setting in which patients receive care from more than one health care provider- physician clinic, or perhaps a joint arrangement where diagnostic or therapeutic services are shared such as in the case with an MRI or dialysis. All processes and risks associated with the treatment process are shared between both parties of the OHCA. Likewise, participants within the OHCA will also share this same Notice and utilize other forms as the hospital does related to the use and disclosure of protected health information. Medical Staff members will be sent a letter appraising them of their status as part of our organized healthcare arrangement. Business Associates Many products and services our facilities and healthcare professionals use may also require the use of patient information in order for these products and services to be provided. We refer to these relationships as our Business Associates. A Business Associate uses patient information on our behalf to provide us with a needed product or service. Anytime our facilities are engaged with a Business Associate described here, it is necessary for us to ensure that our contract language includes the same standard of compliance as our own policies and procedures. Business Associates are expected to use patient information with the same care and concern that any of our facility employees would do. Should the Business Associate use any other agents or subcontractors to help them with the work we contracted with them – they would be expected to conform to the same requirements as the Business Associate. Even though HIPAA does not apply to a

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Business Associate, they are still contractually obligated to provide the same level of confidentiality and privacy for patient information that we do. We are required to obtain a Business Associate Agreement (BAA) for all new contracts or contracts that will be updated by October of 2002 by April 2003. For contracts that are existing and do not have a renewal date until after October, 2002- we have until April 2004 to secure a B.A.A.

BBuussiinneessss IInnffoorrmmaattiioonn PPrraaccttiicceess Documentation, Retention and Disposal of Information Documentation: In accordance with the regulatory compliance standards of 45 CFR, parts 160, 164, and other state regulations; LifePoint is also required to document, retain, and dispose of health information with specific care. Our facilities are responsible for the integrity, safety and accuracy of all the patient information we collect and maintain as part of our designated record sets. Retention of Records: HIPAA requires documentation to be maintained for a minimum period of six (6) years; longer if state laws or other company policy determines a longer term to be more sufficient. Retention requirements include documentation on workforce training and education, authorizations, requests or requisitions for access, accounting of disclosures, requests for confidential/alternate communications, complaint logs concerning reports of potential privacy violations as well as investigation and resolution or sanctions applied as a result of the complaint. Also included in the retention requirement is documentation and assessment of minimum necessary access, appointment of personal representatives and especially any requests for amendment or restriction of access even if the requests have been denied. There may be exceptions related to HIPAA that cannot be maintained but those exceptions are usually the result of the material or information not being part of the facilities defined designated record set. All facilities will have documentation as part of the Patient Access policy that declares what components of patient information, primarily by department, will be part of their designated record sets. An example of information that may not be part of a facility designated records set would be information collected as part of our internal quality monitoring or internal audit process. All other medical and business related documents and their references to documentation requirements, retention, and disposal are addressed in the LifePoint Record Management Policy.

Disposal of Documents and Records: While disposal and destruction procedures are also thoroughly addressed within our Ethics and Compliance policies, HIPAA expounds that obligation to ensure that the processes we use also take patient privacy into consideration. We must assess our current disposal and destruction processes to include all elements that might contain individually identifiable health information (IIHI). This requires us to think beyond the paper record and consider other items such as patient ID am bands, addressograph cards, diskettes, CDs and even our PCs that may be retired or replaced. Any medium that could potentially contain IIHI must be considered as part of our processes.

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WWoorrkkppllaaccee PPrraaccttiicceess Authority and Guidance We must ensure, as a Company, that we have done our best to implement proper administrative, technical, and physical safeguards to protect patient health information from any intentional and unintentional use or disclosure. In order for LifePoint to establish responsibility for compliance with the HIPAA Privacy Standards, it is important to understand the provisions of our HIPAA Compliance Program. Each LifePoint facility must appoint a Facility Privacy Officer. The Privacy Officer should also have a committee of individuals that assist with the oversight and accountability of the privacy standards. This committee does not have to be a separately operating unit but must meet on a routine basis to ensure consistency and continuity of the HIPAA Compliance Program. The Privacy Officer must also be a member of the Facility Ethics and Compliance Committee. The Privacy Officer is responsible for reporting the status of the facility’s HIPAA Compliance at least quarterly to the Ethics and Compliance Officer or Committee. As part of the Compliance Program – the Privacy Officer must be sure that facility efforts are focused on the protection of patient rights as defined under the HIPAA Privacy Standards by ensuring that the facility workforce has been educated, trained, and practice the principles related to access, use and disclosure of patient health information (PHI). Special care must be taken to reduce incidental uses and disclosures by ensuring reasonable safeguards and that minimum necessary standards are in place. An example of an incidental use or disclosure might be glimpsing patient information on a sign-in sheet or overhearing a conversation about patient information at a nursing station while visiting a friend or relative. Guidance will be provided to establish minimum necessary access to satisfy access requirements for the workforce to perform their job related duties. It is important to remember that patient information learned while at work cannot be discussed with friends, family members, or neighbors; nor should patient information be accessed to satisfy one’s curiosity about a friend or family member currently being treated in your facility unless you have direct treatment/processing responsibilities for the patient. New facility policies and procedures have been developed and existing policies may be used to compliment the corporately-approved HIPAA Compliance policies, but it is expected that the Corporate HIPAA policies will be used as the basis for compliance. HIPAA Compliance Program Provisions The main provisions of the Compliance Program include the development and implementation of policies and procedures that ensure workforce training; a complaint filing process for both patients and employees; our workforce must also understand that we have the responsibility to inform patients of their rights to make decisions and access their own information. The provisions also include

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a disciplinary and sanction process as well as mitigation and non-retaliation for any event reported in good faith. As mentioned previously, we are required to keep documentation of all of these provisions. Training: The HIPAA Privacy Standards require that all LifePoint workforce members be trained by April 14, 2003 and annually thereafter. Some policy changes may require additional education. It is important to focus training efforts on the purpose of HIPAA and how it impacts that workforce member’s ability to perform their job with respect to the privacy standards. Complaints: Patients and employees have the right to file a complaint or report a concern regarding any potential patient privacy violations. Just like with the standards recognized in the LifePoint Code of Conduct, all good faith attempts to report a potential/suspected violation will be logged, investigated, and appropriate action taken to resolve any confirmed violation. We encourage all workforce members to report, when it is appropriate, all complaints to their immediate supervisor. The supervisor will in turn advise the employee of the proper steps to follow or how to contact the facility privacy officer to ensure the concern is documented. If this recommendation is not appropriate, the employee or other member of the workforce or patient is encouraged to go directly to the Facility Privacy Officer or call the Ethics and Compliance Hotline at 1-800-508-LIFE (5433). Sanctions: All reports of suspected violations will be investigated and if confirmed, appropriate action or sanction will be applied up to the point of employee termination or revocation of Medical Staff privileges if necessary. The LifePoint complaint Process and Disciplinary Action policy describes the events that should take place. We encourage local autonomy and decision making in all LifePoint facilities. As with all LifePoint policies, the precise disciplinary action will be subject to and depend on the nature, severity, and frequency of the violation. Mitigation: If a facility has determined that a member of the workforce or even a business associate has misused confidential health information, the facility will communicate this to the Facility Privacy Officer. Refer to the Complaint Process and Disciplinary Guidelines policy if any employee is found to have misused health information. If a business associate has misused the information, the facility must proceed to investigate the misuse, determine if the misuse was serious or repeated and counsel the business associate as appropriate. If the business associate continues to violate or misuse information, then the facility has the right to terminate the business associate agreement based on breach of contract. HIPAA Committee Objectives The Privacy Officer should have a committee of individuals that assist with the oversight and accountability of the privacy standards. This committee does not have to be a separately operating unit but must meet on a routine basis to ensure consistency and continuity of the HIPAA Compliance Program. The Privacy Officer must also be a member of the Facility Ethics and Compliance Committee. The HIPAA Committee should consist of multidisciplinary team members to include hospital wide departmental representation and physician representation.

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The Compliance Committee should be utilized to review hospital specific procedures and issues to ensure the HIPAA Compliance Program requirements are being met. It may also be necessary for committee members to assist with certain activities associated with assessing or implementing compliance requirements. The Facility Privacy Officer will chair the committee and make recommendations for committee functions when appropriate. Privacy Policies & Procedures Guidance will be provided for all the required privacy standards in the form of policies and procedures. Some of the policies have already been mentioned in previous information where appropriate. Others policies are described below: Notice of Privacy Practices: All patients will receive a Notice of Privacy Practices informing them of how we intend to use and disclose their patient health information. This notice will generally be given out during the registration process so it is important that all registrars understand what the information in the Notice means and who to refer the patient to if there are questions that cannot be answered. We must also document in our records that the patient has been given the notice – this will most likely be done using the acknowledgment section on the conditions of admission form. The notice also describes how the patient can file a complaint and what to do if they are not satisfied with the results of the complaint. All patients and employees can file a complaint with the Secretary of the Department of Health and Human Services if they do not feel their complaint has been handled appropriately or to their satisfaction. It is recommended to always try to resolve the patient complaint to the best of your ability and to the patient’s satisfaction if possible but we do recognize that there may be extenuating circumstances or valid reasons for which this cannot be done. Business Associates: As explained in earlier sections of this brochure, a Business Associate is a person or vendor that we have engaged to provide us with a service that requires the use of protected health information (PHI) on our behalf. Whenever a relationship like this exists, it is required that we have a specific contractual addendum or agreement in place that the Business Associate has agreed to. Even though a Business Associate is not required to comply with the HIPAA regulations, they are required to provide services per our expectations and based upon what we need in order to ensure appropriate business practices. Since we chose to engage a Business Associate to help us provide these services then it is in our best interest to ensure that the Business Associate can also provide the same level of patient access and decision making abilities that we would if we were able to provide the service ourselves. Minimum Necessary: Minimum necessary access must be evaluated and established to satisfy access to information required for an employee to perform their job related duties. A matrix describing the appropriate access and reason for the access will be reviewed and revised at least annually. This matrix is organized by job title to capture all of the positions in a LifePoint facility. Whenever an employee has access to more than is required to do their job, it is still the employee’s responsibility to know what appropriate use of patient health

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information is. Additional information that is acquired or accessed should not be divulged or discussed in any way if it is not required or needed to perform your job. Authorization Requirements: It is no longer appropriate for a patient or requestor to just write a note requesting access to information. Authorizations require specific elements to be considered valid authorizations. Your facility will be using either a standardized form provided by Corporate or your existing forms will be modified to include the standard elements. Authorizations should be used to release any form of information that could be individually identifiable health information (IIHI). IIHI can be created by any department in the facility that has records or components listed in the facility designated record set. Authorizations will be needed to release to any requestor other than the patient or the patient’s representative except as noted in the exceptions for mandatory release and release without authorization in the Release of Information Standards policy. Authorizations must be kept for a minimum of six years. Verification: It is also very important to verify who the requestor of any patient health information is unless the request is routine and previously determined to be within guidelines suggested in the release of information standards. The authorization form has a special box to indicate what method was used to verify the identity of the requestor. Whenever a requestor does not provide the proper identification, it is permissible to refuse the release of information until you have had the opportunity to satisfactorily perform the verification process. Remember there may be times that verification must occur verbally as well as in person. Be sure you understand how this may impact your particular work setting especially if you should ever be in the position to make a decision regarding release of health information. Release of Information Standards: This policy sets standards by which a LifePoint facility should operate when releasing protected health information both for internal and external uses and disclosures. There are several facets of this policy that cover mandatory use and disclosure where patient information can be used or released without the patient’s authorization as well as what must NOT be released unless there is a patient authorization. There are also specific situations in which a patient should be given the opportunity to opt out or agree or object to the use or disclosure. This policy provides specific guidance for the release of information to law enforcement personnel that should be referred to anytime a request is received and it is unclear as to how the request should be handled. In any circumstance, if you are not sure what the appropriate decision should be, then do not hesitate to seek additional guidance from your supervisor or Facility Privacy Officer. Remember, unless the request is one involving a life threatening circumstance or other urgent/emergent situation, it is “OK” to take the time to seek guidance regarding the correct decision to be made. Do make note that there may be some state laws that are stricter or provide a greater right to privacy for the patient than the Corporate policies provide. If that should be the case, your privacy officer will provide the guidance necessary to make the right decision or refer to Corporate legal counsel if necessary.

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Psychotherapy Notes: For those LifePoint facilities that provide specialized psychotherapy services or have Psychiatric units/floors, there are specific rules and additional requirements that must be noted when requests to release psychotherapy notes are received. It is important to understand what a psychotherapy note is and how it differs from other patient health/medical record components. Often times the psychotherapy notes are not even kept in the same locations as the rest of the patient record. All requests for psychotherapy notes must be provided on a separate request form and separate authorization for release of information should be used. Personal Representatives: Sometimes a patient is not always able to be present or does not feel confident enough to make decisions regarding how their health information should be used and disclosed. For this reason, a patient is allowed to appoint, formally or informally, another individual to make these decisions for them. The facility Conditions of Admission form or other mechanism should be used to give the patient the opportunity to agree or object to this appointment. Whenever possible, it is advisable to get his appointment documented but sometimes it is necessary to take a verbal request. This documentation should be retained for at least 6 years. Formal appointments may be done in the form of a power of attorney or custodial relationship or as required by individual state law. Marketing & Fundraising Activities: These activities should never use patient health information (PHI) or individually identifiable health information (IIHI) without a patient’s express consent to do so. If in doubt, please contact your Facility Privacy Officer, the Corporate Privacy Officer, or call the Ethics and Compliance Hotline. Research: Generally, LifePoint facilities do not participate in research activities with large universities or vendor programs. Should the need to do this arise, it is very important to obtain a patient authorization to use/disclose any patient health information while participating in the research activity. Patient authorization will also include a statement that must be signed by the patient in which the patient understands that the results of the research activity will not be available for the patient to review including any documentation made with regard to the patient’s condition until after the research event has been completed. It is recommended that any participation in an event or activity of this nature be approved by Corporate.

Summary

LifePoint Hospitals has set forth this program to establish a consistent training program for all members of our workforce. It is not our intent for any of these policies and procedures to be interpreted as a waiver of patient rights regarding how their information should be used; nor shall we use any of this information to retaliate against our workforce members or any of our patients. We trust you will find this information helpful and useful as you perform your duties while both at work and elsewhere. Remember, we care about our patients and their right to privacy.

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L I F E P O I N TH o s p i t a l s, i n c.

Common GroundC o d e o f C o n d u c t

Dear Employee:

At LifePoint Hospitals, we take pride in the fact that our hospitals share a vision — to provide high quality,accessible and compassionate health care to non-urban communities.

To make that vision a reality, each of us shares a commitment to the highest ethical and legal standards. Wecall this shared commitment “common ground.” Only upon common ground can we build the success of ourhospitals and our company.

The Code of Conduct included in this publication was developed to help guide us in our daily activities andinteractions with colleagues, patients, affiliated physicians and others with whom we work. We ask that youreview the Code carefully. Your understanding of it and commitment to it is crucial to our success.

Much of the Code’s content may seem second nature to you. This is understandable. In fact, we expect thatyou will not be surprised by these provisions. We depend on you to have your own personal code of ethicsthat will be responsive to the principles discussed in this Code. In many cases, the Code simply serves toreinforce our understanding of how we should conduct ourselves and our business.

Nevertheless, ours is a complex professional environment. Situations arise that are confusing. At one time oranother, you may have questions about ethical or legal issues. This Code contains information to help resolvethose issues. If you have further questions or you are faced with a situation that you believe is not consistentwith the Code, we urge you to consult immediately with your supervisor, another member of management atyour hospital, your local ethics and compliance officer, or the corporate ethics and compliance officer. You mayalso call the corporate ethics line at 1-877-508-LIFE (5433). We assure you that there will be no retribution forany inquiry or for reporting a possible breach of the Code.

You and every other LifePoint Hospitals employee play an important role in our future. We hope you will joinus in upholding our Code of Conduct. We know that together, standing on common ground, we can achieveour mission of Making Communities Healthier.

Sincerely,

William F. Carpenter III

President and Chief Executive Officer

Copyright © 2007 LifePoint Asset Management Company, Inc. All rights reserved. This document is non-public and containsconfidential and proprietary information and trade secrets of LifePoint Asset Management Company, Inc. No part of this documentmay be reproduced, retransmitted or otherwise distributed in any form or by any means, electronic or mechanical, including byphotocopying, facsimile transmission, recording, re-keying or using any information storage and retrieval systems without the priorexpress written permission of LifePoint Asset Management Company, Inc.

Note: All references to “LifePoint,” “LifePoint Hospitals,” “Company” or “Organization” in this Code of Conduct refer to LifePointHospitals, Inc. and/or its affiliated facilities, as applicable.

Purpose of Our Code of Conduct ....................2LifePoint’s High Five..............................................2

Leadership Responsibilities .............................3

Our Fundamental Commitmentto Stakeholders .................................................3

Relationships With OurHealth Care Partners.........................................4

Patients...........................................................4Patient Care and Rights........................................4Emergency Treatment...........................................5Patient Information ..............................................5

Affiliated Physicians .....................................5

Third-Party Payors .........................................6Coding and Billing for Services ............................6Cost Reports ...........................................................6

Regulatory Compliance....................................7

Dealing With Accrediting Bodies ....................7

Business Information........................................8Accuracy, Retention and Disposalof Documents and Records ..................................8Confidential Information .....................................8Electronic Media....................................................9Financial Reporting and Records.........................9

Workplace Conduct and EmploymentPractices ...........................................................10

Conflicts of Interest.............................................10Controlled Substances.........................................10Copyrights ............................................................10Diversity and Equal EmploymentOpportunity .........................................................10Harassment and Workplace Violence ...............10Health and Safety................................................11Hiring of Former and CurrentGovernment Employees .....................................11Inside Information and Securities Trading .......12License and Certification Renewals...................12Personal Use of LifePointHospitals’ Resources ............................................13

Relationships Among LifePointHospitals Employees............................................13Relationships With Subcontractors,Suppliers and Educational Institutions..............13Research ...............................................................14Substance Abuse and Mental Acuity ................14

Marketing Practices ........................................15Antitrust ...............................................................15Gathering Information About Competitors.....15Marketing and Advertising................................15

Environmental Compliance ...........................16

Business Courtesies ........................................17General .................................................................17Receiving Business Courtesies ............................17Extending Business Courtesies toNon-referral Sources ...........................................17Extending Business Courtesies toPossible Referral Sources ....................................18

Political Activities and Contributions ..........19

The Corporate Ethics and ComplianceProgram............................................................20

Program Structure...............................................20Resources for Guidance andReporting Violations ...........................................20Confidentiality and Retaliation .........................20Personal Obligation to Report...........................21Internal Investigation of Reports.......................21Corrective Action.................................................21Discipline ..............................................................22Internal Audit and Other Monitoring ..............22Acknowledgment Process ..................................22

Acknowledgment............................................23

Special SectionsSeeking Help............................................................12Common Ground.....................................................14Notice to All Employees Regarding Fraud............22

Table of Contents

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Purpose of OurCode of ConductOur Code of Conduct provides guidance to allLifePoint Hospitals employees and assists us incarrying out our daily activities within appropriateethical and legal standards. These obligations applyto our relationships with patients, affiliatedphysicians, third-party payors, subcontractors,independent contractors, vendors, consultants andone another.

The Code is a critical component of our overallethics and compliance program. We developed theCode to ensure that we meet our ethical standardsand comply with applicable laws and regulations.

The Code is intended to be a statement that iscomprehensive and easily understood. In someinstances, the Code deals fully with the subjectcovered. In many cases, however, the subjectdiscussed has so much complexity that additionalguidance is necessary for those directly involvedwith the particular area to have sufficientdirection.

Though we promote the concept of localmanagement autonomy to meet local needs, thepolicies set forth in this Code are mandatory andmust be followed.

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LifePoint’s High Five

At LifePoint Hospitals, we share a commonvision to provide high quality, accessible,compassionate and cost-effective health careto non-urban communities. To achieve this,we are committed to five core values:

Delivering High QualityPatient CareOur highest priority is caring for people —the friends, family and neighbors whom weserve in our communities.

Creating Excellent Workplacesfor our EmployeesWe are committed to providing employeeswith an environment based on respect andone that encourages personal andprofessional growth.

Supporting PhysiciansWe support physician practices by providinginnovative facilities, advanced technologyand a well-trained, organized clinical staff.

Providing Community ValueWe take pride in being a vital resource foreach community we serve. Most LifePointhospitals are the sole health care providersin their area and are actively involved intheir communities, supporting local civic andcharitable organizations.

Ensuring Fiscal ResponsibilityWe are fiscally responsible, ensuring that wemeet the capital needs of our hospitals andthe expectations of our stakeholders.

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While all LifePoint Hospitals employees areobligated to follow our Code, we expect ourleaders to set the example — to be in every respecta model. Leaders must ensure that those on theirteam have sufficient information to comply withlaw, regulation and policy, as well as the resourcesto resolve ethical dilemmas. They must help create

a culture within LifePoint that promotes thehighest standards of ethics and compliance. Thisculture must encourage everyone in theorganization to raise concerns when they arise. Wemust never sacrifice ethical and compliant behaviorin the pursuit of business objectives.

Leadership Responsibilities

3

We affirm the following commitments to LifePointHospitals stakeholders:

To our patients: We are committed to providinghigh quality care that is sensitive, compassionate,promptly delivered and cost-effective.

To our employees: We are committed toproviding a work setting that treats all employeeswith fairness, dignity and respect, and affordsthem an opportunity to grow, developprofessionally, and work in a team environment inwhich all ideas are considered.

To our affiliated physicians: We are committedto providing a work environment that has excellentfacilities, modern equipment and outstandingprofessional support.

To the communities we serve: We arecommitted to understanding the needs of thosecommunities and providing them with high quality,cost-effective health care. We realize that we as anorganization have a responsibility to help those inneed. We proudly support charitable contributionsand events in the communities we serve in aneffort to promote goodwill and further goodcauses.

To our shareholders: We are committed to thehighest standards of professional management,which we are certain can create unique efficienciesand innovative health care approaches and thusprovide favorable returns on our shareholders’investments over the long-term.

To our third-party payors: We are committed todealing with our third-party payors in a way thatdemonstrates our commitment to contractualobligations and reflects our shared concern forquality health care and bringing efficiency and costeffectiveness to health care. We encourage ourprivate third-party payors to adopt their own set ofcomparable ethical principles to recognize explicitlytheir obligations to patients, as well as the needfor fairness in dealing with providers.

To our regulators: We are committed to anenvironment in which compliance with rules,regulations and sound business practices is woveninto the corporate culture. We accept theresponsibility to aggressively self-govern andmonitor adherence to the requirements of law andto our Code of Conduct.

To our joint venture partners: We are committedto fully performing our responsibilities to manageany jointly owned facilities in a manner that reflectsthe mission and values of each organization.

To our suppliers: We are committed to faircompetition among prospective suppliers and thesense of responsibility required of a good customer.

To our volunteers: The concept of voluntaryassistance to the needs of patients and their familiesis an integral part of the fabric of health care. Weare committed to ensuring that our volunteers feel asense of meaningfulness from their volunteer workand receive recognition for their volunteer efforts.

Our Fundamental Commitment to Stakeholders

Relationships With Our Health Care Partners

4

P A T I E N T S

Patient Care and Rights

Our mission is to provide high quality health careto all of our patients. We treat all patients withrespect and dignity and provide care that is bothnecessary and appropriate. We make no distinctionin the admission, transfer or discharge of patientsor in the care we provide based on race, color,religion or national origin. Clinical care is based onidentified patient health care needs, not on patientor organization economics.

Upon admission, each patient is provided with awritten statement of patient rights. This statementincludes the rights of the patient to make decisionsregarding medical care and conforms to allapplicable state and federal laws.

We assure patient involvement in all aspects oftheir care and obtain informed consent fortreatment. As applicable, each patient or patientrepresentative is provided with a clear explanationof care including, but not limited to, diagnosis,treatment plan, right to refuse or accept care, caredecision dilemmas, advance directive options,estimates of treatment costs, organ donation andprocurement, and an explanation of the risks andbenefits associated with available treatmentoptions. Patients have the right to request transfersto other hospitals. In such cases, the patient will begiven an explanation of the benefits, risks andalternatives.

Patients are informed of their right to makeadvance directives. Patient advance directives willbe honored within the limits of the law and theorganization’s mission, philosophy and capabilities.

Patients and their representatives will be accordedappropriate confidentiality, privacy, security andprotective services, opportunity for resolution ofcomplaints and pastoral counseling. Any

restrictions on a patient’s visitors, mail, telephoneor other communications must be evaluated fortheir therapeutic effectiveness and must be fullyexplained to and agreed upon by the patient orpatient representative. During prolonged stays inthe hospital, patients have the right to refuse toperform tasks in or for the hospital.

Patients are treated in a manner that preservestheir dignity, autonomy, self-esteem, civil rights andinvolvement in their own care. LifePoint Hospitalsemployees receive training about patient rights inorder to clearly understand their role in supportingthem.

Compassion and care are part of our commitmentto the communities we serve. We strive to providehealth education, health promotion and illnessprevention programs as part of our efforts toimprove the quality of life of our patients and ourcommunities.

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Emergency Treatment

We follow the Emergency Medical Treatment AndLabor Act (EMTALA) in providing emergencymedical treatment to all patients, regardless oftheir ability to pay. Anyone with an emergencymedical condition is treated and admitted basedon medical necessity. In an emergency situation,financial and demographic information will beobtained only after the immediate needs of thepatient are met. We do not admit or dischargepatients simply on their ability to pay.

Patients will only be transferred to anotherhospital upon their request or if their medicalneeds cannot be met at the LifePoint hospital andappropriate care is knowingly available at anotherhospital. Patients will only be transferred after theyhave been stabilized within the capabilities andcapacity of the transferring hospital, and areformally accepted for treatment at the receivinghospital.

Patient Information

We collect information about the patient’s medicalcondition, history, medication and family illnessesto provide the best possible care. We realize thesensitive nature of this information and arecommitted to maintaining its confidentiality. Wedo not release or discuss patient-specificinformation with others unless it is necessary toserve the patient or authorized by law.

LifePoint Hospitals employees must never discloseconfidential information that violates the privacyrights of our patients. No LifePoint employee,affiliated physician or other health care partner hasa right to any patient information other than thatnecessary to perform his or her job.

Patients can expect that their privacy will beprotected and that patient-specific information willbe released only to persons authorized by law orby the patient’s written consent. In an emergencysituation, when requested by an institution or

physician then treating the patient, the patient’sspecific authorization is not required by law, butthe name of the institution and the personrequesting the information must be verified.

A F F I L I A T E D P H Y S I C I A N S

Any business arrangement with a physician mustbe structured to ensure precise compliance withlegal requirements. Such arrangements must be inwriting and approved by the Corporate Legaldepartment.

In order to ethically and legally meet all standardsregarding referrals and admissions, we will adherestrictly to two primary rules:

1. We do not pay for referrals. We accept patientreferrals and admissions based solely on thepatient’s clinical needs and our ability to renderthe needed services. We do not pay or offer to payanyone — employees, physicians or other persons— for referral of patients or to induce referrals.Violation of this policy has grave consequences forthe organization and the individuals involved,including civil and criminal penalties and possibleexclusion from participation in federally fundedhealth care programs.

2. We do not accept payments for referralsthat we make. No LifePoint Hospitals employeeor any other person acting on behalf of theorganization is permitted to solicit or receiveanything of value, directly or indirectly, inexchange for the referral of patients. Similarly,when making patient referrals to another healthcare provider, we do not take into account thevolume or value of referrals that the provider hasmade (or may make) to us.

All employees, medical staff members and privilegedpractitioners should immediately report violations orsuspected violations to a supervisor or member ofmanagement, the local ethics and complianceofficer, the corporate ethics line or the corporateethics and compliance officer.

Relationships With Our Health Care Partners cont.

T H I R D - P A R T Y P AY O R S

Coding and Billing for Services

We will take great care to ensure that all billings togovernmental and other payors reflect truth andaccuracy and conform to all pertinent federal andstate laws and regulations.

We prohibit any employee or agent of LifePointHospitals from knowingly presenting or causing tobe presented claims for payment or approval thatare false, fictitious or fraudulent.

We will operate oversight systems designed toverify that claims are submitted only for servicesactually provided and that services are billed asprovided. These systems will emphasize the criticalnature of complete and accurate documentation ofservices provided. As part of our documentationeffort, we will maintain current and accuratemedical records.

Any subcontractors engaged to perform billing orcoding services must have the necessary skills,quality assurance processes, systems andappropriate procedures to ensure that all billingsfor governmental and other payors are accurateand complete. LifePoint prefers to contract withsuch entities that have adopted their own ethicsand compliance programs. Third-party billingentities, contractors and preferred vendors that weconsider must be approved consistent with ourcorporate policy on this subject.

For coding questions, contact the 3M Nosology lineat 1-800-537-1666. For questions concerning billingissues, contact your local business office director.

Cost Reports

Our business involves reimbursement undergovernment programs that require the submissionof certain reports of our costs of operation. We willcomply with federal and state laws relating to allcost reports. These laws and regulations definewhich costs are allowable and outline theappropriate methodologies to claim reimbursementfor the cost of services provided to programbeneficiaries. Given their complexity, all issuesrelated to the completion and settlement of costreports must be communicated through orcoordinated with our Reimbursement department.

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Relationships With Our Health Care Partners cont.

7

Hospitals affiliated with LifePoint Hospitals providevaried health care services in many states. Theseservices generally may be provided only pursuantto appropriate federal, state and local laws andregulations. Such laws and regulations may includesubjects such as certificates of need, licenses,permits, accreditation, access to treatment, consentto treatment, medical record keeping, access tomedical records and confidentiality, patients’ rights,terminal care decision-making, medical staffmembership and clinical privileges, corporatepractice of medicine restrictions, and Medicare andMedicaid regulations. The organization is subject tonumerous other laws in addition to these healthcare regulations.

We will comply with all applicable laws andregulations. All employees, medical staff members,privileged practitioners and contract serviceproviders must be knowledgeable about andensure compliance with all laws and regulationsand should immediately report violations orsuspected violations to a supervisor or member ofmanagement, the local ethics and complianceofficer, the corporate ethics line or the corporateethics and compliance officer.

LifePoint will be forthright in dealing with anybilling inquiries. Requests for information will beanswered with complete, factual and accurate

information. We will cooperate with and becourteous to all government inspectors and providethem with the information to which they areentitled during an inspection.

During a government inspection, you must neverconceal, destroy or alter any documents, lie ormake misleading statements to governmentrepresentatives. You should not influence anotheremployee to provide inaccurate information orobstruct, mislead or delay the communication ofinformation or records relating to a possibleviolation of law.

In order to ensure that we fully meet all regulatoryobligations, LifePoint Hospitals employees andaffiliated physicians must be informed about statedareas of potential compliance concern. TheDepartment of Health and Human Services, andparticularly its inspector general, has routinelynotified health care providers of areas in which itbelieves that insufficient attention is being given togovernment regulations. We should be diligent infollowing such guidance and reviewing appropriateelements of our system to ensure their correctness.

LifePoint Hospitals will provide its employees withthe information and education they need tocomply fully with all applicable laws andregulations.

Regulatory Compliance

LifePoint Hospitals will deal with all accreditingbodies in a direct, open and honest manner. Noaction should ever be taken in relationships withaccrediting bodies that would mislead theaccreditor or its survey teams, either directly orindirectly. Where LifePoint determines to seek anyform of accreditation, all standards of theaccrediting group are important and must befollowed.

The scope of matters related to accreditation ofvarious bodies extends beyond the scope of thisCode of Conduct. The purpose of our Code ofConduct is to provide general guidance on subjectsof wide interest within the organization.

Dealing With Accrediting Bodies

Business InformationAccuracy, Retention and Disposalof Documents and Records

Each LifePoint Hospitals employee is responsible forthe integrity and accuracy of our organization’sdocuments and records, not only to comply withregulatory and legal requirements but also toensure that records are available to defend ourbusiness practices and actions. No one may alter orfalsify information on any record or document.

Medical and business documents and records areretained in accordance with the law and our recordretention policy. Medical and business documentsinclude paper documents such as letters andmemos, computer-based information such as e-mailor computer files on disk or tape, and any othermedium that contains information about theorganization or its business activities. It isimportant to retain and destroy recordsappropriately according to our policy. You must nottamper with records or remove or destroy themprior to the date specified in company policy forsuch action.

Confidential Information

Confidential information about our organization’sstrategies and operations is a valuable asset.Although you may use our confidentialinformation to perform your job, you must notshare this information with others outside ofLifePoint Hospitals or your department unless youare doing so within the scope of your jobresponsibilities, and the person to whom youintend to disclose the information has a legitimatebusiness need to know this information. Violationof this policy may subject an employee totermination and other legal action.

As a condition of your employment with LifePointHospitals, you will not seek to benefit personally orpermit others to benefit through the use ordisclosure of our confidential information. Yourobligations are not limited to documents andmaterials that are specifically marked as“confidential.” If, however, a document is expresslymarked as “confidential,” you are expected tofollow all instructions noted on such documentpertaining to the photocopying, transmitting ordisclosing of any information contained therein.Examples of confidential information includepersonnel data maintained by the organization,patient lists and clinical information, pricing andcost data, information pertaining to acquisitions,divestitures, affiliations and mergers, financialdata, research data, strategic plans, marketingstrategies, techniques, employee lists, supplier andsubcontractor information, training materials,proprietary computer software and otherinformation not generally known by the public.

This provision does not restrict the right of anemployee to disclose, if he or she wishes,information about his or her own compensation,benefits or terms and conditions of employment.

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Electronic Media

All communications systems, electronic mail,intranet, Internet access or voicemail are theproperty of the organization and are to beprimarily used for business purposes. Highly limitedreasonable personal use of LifePoint Hospitals’communications systems is permitted; however, youshould assume that these communications are notprivate. Patient or confidential information shouldnot be sent through the intranet or the Internetunless security measures are in place that assureconfidentiality.

LifePoint reserves the right to periodically access,monitor and disclose the contents of the intranet,e-mail and voicemail messages. Access anddisclosure of individual employee messages mayonly be done with the approval of the CorporateLegal department.

Employees may not use internal communicationchannels or access the Internet at work to post,store, transmit, download or distribute anythreatening, knowingly reckless, maliciously falseor obscene materials. This prohibition includesanything constituting or encouraging a criminaloffense, giving rise to civil liability or otherwiseviolating any laws. Additionally, these channels ofcommunication may not be used to send chainletters, personal broadcast messages or copyrighteddocuments that are not authorized forreproduction, nor are they to be used to conduct ajob search or open misaddressed mail.

Employees may not install personal software onLifePoint computer equipment, and LifePoint-owned software may not be installed onemployees’ personal computers. While there areexceptions, there are very few. Please contact yourlocal director of information systems or refer to theLifePoint PC Software License Management policyfor more details.

Employees who abuse our communications systemsor use them excessively for non-business purposesmay lose these privileges and be subject todisciplinary action.

Financial Reporting and Records

We have established and maintain a high standardof accuracy and completeness in thedocumentation and reporting of all financialrecords. These records serve as a basis formanaging our business and are important inmeeting our obligations to patients, employees,shareholders, suppliers and others. They are alsonecessary for compliance with tax and financialreporting requirements.

All financial information must reflect actualtransactions and conform to generally acceptedaccounting principles. No undisclosed orunrecorded funds or assets may be established.

LifePoint Hospitals maintains a system of internalcontrols to provide reasonable assurances that alltransactions are executed in accordance withmanagement’s authorization and are recorded in aproper manner so as to maintain accountability ofthe organization’s assets.

Business Information cont.

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10

Workplace Conduct and Employment PracticesConflicts of Interest

A conflict of interest may exist if your outsideactivities or personal interests influence or appearto influence your ability to make objectivedecisions in the course of your job responsibilities.A conflict of interest may also exist if the demandsof any outside activities hinder or distract you fromthe performance of your job or cause you to useLifePoint Hospitals’ resources for non-Lifepointpurposes. It is your obligation to ensure that yourinterests remain free of conflicts in theperformance of your responsibilities at LifePoint. Ifyou have any question about whether an outsideactivity might constitute a conflict of interest, youmust obtain the approval of your supervisor beforepursuing the activity.

Controlled Substances

Some of our employees routinely have access toprescription drugs, controlled substances and othermedical supplies. Many of these substances aregoverned and monitored by specific regulatoryorganizations and must be administered byphysician order only. It is extremely important thatthese items be handled properly and only byauthorized individuals to minimize risks toLifePoint and to patients. If you become aware ofthe diversion of drugs from the organization, youshould report the incident immediately.

Copyrights

LifePoint Hospitals employees may only makecopies of copyrighted materials pursuant to theorganization’s policy on such matters.

Diversity and Equal EmploymentOpportunity

Our employees provide us with a wide complementof talents that contribute greatly to our success.We are committed to providing an equalopportunity work environment where everyone istreated with fairness, dignity and respect. We willcomply with all laws, regulations and policiesrelated to non-discrimination in all of ourpersonnel actions. Such actions include hiring, staffreductions, transfers, terminations, evaluations,recruiting, compensation, corrective action,discipline and promotions.

No one may discriminate against any individualwith a disability with respect to any offer, term orcondition of employment. We will makereasonable accommodations to the known physicaland mental limitations of otherwise qualifiedindividuals with disabilities.

Harassment and WorkplaceViolence

Each LifePoint Hospitals employee has the right towork in an environment free of harassment. Wewill not tolerate harassment by anyone based onthe diverse characteristics or cultural backgroundsof those who work with us. Degrading orhumiliating jokes, slurs, intimidation or otherharassing conduct is not acceptable in ourworkplace.

Any form of sexual harassment is strictlyprohibited. This includes unwelcome sexualadvances or requests for sexual favors inconjunction with employment decisions. Moreover,verbal or physical conduct of a sexual nature thatinterferes with an individual’s work performance orcreates an intimidating, hostile or offensive workenvironment has no place at LifePoint Hospitals.

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Harassment also includes incidents of workplaceviolence. Workplace violence includes robbery andother commercial crimes, stalking cases, violencedirected at the employer, terrorism and hate crimescommitted by current or former employees. As partof our commitment to providing a safe workplacefor our employees and physicians, we prohibitpossession of firearms, other weapons, explosivedevices or other dangerous materials on LifePointpremises. Employees who observe or experienceany form of harassment or violence should reportthe incident to their supervisor, the HumanResources department, a member of management,their local ethics and compliance officer, thecorporate ethics line or the corporate ethics andcompliance officer.

Health and Safety

All LifePoint Hospitals facilities must comply withall government regulations and rules and withLifePoint policies or required facility practices thatpromote the protection of workplace health andsafety. Our policies have been developed to protectyou from potential workplace hazards. You shouldbecome familiar with and understand how thesepolicies apply to your specific job responsibilities,and seek advice from your supervisor or the safetyofficer whenever you have a question or concern. Itis important for you to advise your supervisor orthe safety officer of any serious workplace injury orany situation presenting a danger of injury so thattimely corrective action may be taken to resolvethe issue.

Hiring of Former and CurrentGovernment Employees

The recruitment and employment of former orcurrent U.S. government employees is subject tocomplex rules that change frequently and vary byemployee. Similar rules may also apply to currentor former state or local government employees orlegislators and members of their immediatefamilies.

If a former government employee or consultantwishes to become employed by (or a consultant to)LifePoint Hospitals, care should be exercised toensure that the requirements of conflict of interestlaws are not violated. Each situation should beconsidered on an individual basis and you shouldconsult with the Corporate Human Resources orCorporate Legal departments on issues related torecruitment and hiring of former or currentgovernment employees.

Workplace Conduct and Employment Practices cont.

Inside Information and SecuritiesTrading

In the course of your employment, you maybecome aware of non-public information aboutLifePoint Hospitals that may be material to aninvestor’s decision to buy or sell the organization’ssecurities. Non-public, material information mayinclude plans for mergers, marketing strategy,financial results or other business dealings. Youmay not discuss this type of information withanyone outside of the organization. Within theorganization, you should discuss this informationon a strictly “need to know” basis only with otherswho require this information to perform their jobs.

Securities law and LifePoint policy prohibitindividuals from trading in the marketablesecurities of a publicly held organization orinfluencing others to trade in such securities on thebasis of non-public, material information. Theserestrictions are meant to ensure that the generalpublic has complete and timely information onwhich to base investment decisions.

If you obtain access to non-public, materialinformation about the organization whileperforming your job, you may not use thatinformation to buy, sell or retain securities ofLifePoint or any other company. Even if you do notbuy or sell securities based on what you know,discussing the information with others such asfamily members, friends, vendors, suppliers andother outside acquaintances is prohibited until theinformation is considered to be public. Informationis considered to be public three days after ageneral release of the information to the media.

License and Certification Renewals

Employees and individuals retained as independentcontractors in positions that require professionallicenses, certifications or other credentials areresponsible for maintaining the current status oftheir credentials and shall comply at all times withfederal and state requirements applicable to theirrespective disciplines. To ensure compliance,LifePoint Hospitals may require evidence of theindividual having a current license or credentialstatus.

LifePoint Hospitals will not allow any employee orindependent contractor to work without valid,current licenses or credentials.

Workplace Conduct and Employment Practices cont.

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Seeking Help

For help with an ethics or compliance issueor to report a possible violation of the Codeof Conduct, contact your supervisor, anothermember of local management, your localethics and compliance officer, the corporateethics and compliance officer, or thecorporate ethics line at: 1-877-508-LIFE(5433).

For assistance with coding questions, call:1-800-537-1666.

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Personal Use of LifePoint Hospitals’Resources

It is the responsibility of each LifePoint Hospitalsemployee and/or physician to preserve ourorganization’s assets including time, materials,supplies, equipment and information. Organizationassets are to be maintained for business-relatedpurposes. As a general rule, the personal use ofany LifePoint asset without the prior approval ofyour supervisor is prohibited.

The occasional use of items such as copyingfacilities or telephones, where the cost to LifePointis insignificant, is permissible. Any community orcharitable use of organization resources must beapproved in advance by your supervisor. Any use oforganization resources for personal financial gainunrelated to LifePoint business is prohibited.

Relationships Among LifePointHospitals Employees

In the normal day-to-day functions of anorganization like LifePoint Hospitals, there areissues that arise that relate to how people in theorganization deal with one another. It is impossibleto foresee all of these, and many do not requireexplicit treatment in a document like this. A few,however, routinely arise.

One involves gift giving among employees and/orphysicians for certain occasions. While we wish toavoid any strict rules, no one should ever feelcompelled to give a gift to anyone, and any giftsoffered or received should be appropriate to thecircumstances. A lavish gift to anyone in asupervisory role would clearly violate organizationpolicy.

Another situation that routinely arises is fund-raising or similar efforts. No one should ever bemade to feel compelled to participate in any fund-raising or charitable efforts.

Relationships With Subcontractors,Suppliers and EducationalInstitutions

We must manage our subcontractor and supplierrelationships in a fair and reasonable manner,consistent with all applicable laws and goodbusiness practices. We promote competitiveprocurement to the maximum extent practicable.Our selection of subcontractors, suppliers andvendors will be made on the basis of objectivecriteria including quality, technical excellence, price,delivery, adherence to schedules, service andmaintenance of adequate sources of supply.

Our purchasing decisions will be made on thesupplier’s ability to meet our needs and not onpersonal relationships and friendships. We willalways employ the highest ethical standards inbusiness practices in source selection, negotiation,determination of contract awards and theadministration of all purchasing activities. We willnot communicate to a third party confidentialinformation given to us by our suppliers unlessdirected in writing to do so by the supplier. We willnot disclose contract pricing and information toany outside parties. (The subject of businesscourtesies, which might be offered bysubcontractors or suppliers, is discussed later inthis Code.)

All hospitals having a relationship with aneducational institution must have a writtenagreement that defines both parties’ roles and thehospital’s retention of the responsibility for thequality of patient care.

Workplace Conduct and Employment Practices cont.

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Research

We follow high ethical standards and all legalrequirements in any research conducted by ourphysicians and professional staff. We do nottolerate intentional research misconduct. Researchmisconduct includes making up, changing orcopying results from other studies withoutperforming the research.

All patients asked to participate in a researchproject are given a full explanation of alternativeservices that might prove beneficial to them. Theyare also fully informed of potential discomfortsand are given a full explanation of the risks,expected benefits and alternatives. The patientsare fully informed of the procedures to befollowed, especially those that are experimental innature. Refusal of a patient to participate in aresearch study will not compromise their access toservices.

All personnel applying for or performing researchof any type are responsible for maintaining thehighest ethical standards in any written or oralcommunications regarding their research projects,as well as following appropriate legal and researchguidelines. As in all accounting and financial recordkeeping, our policy is to submit only true, accurateand complete costs related to research grants.

Substance Abuse and MentalAcuity

To protect the interests of our employees,physicians and patients, we are committed to analcohol- and drug-free work environment. Allemployees and physicians must report for workfree of the influence of alcohol and illegal drugs.Reporting to work under the influence of any

illegal drug or alcohol, having an illegal drug inyour system, or using, possessing or selling illegaldrugs while on LifePoint Hospitals’ work time orproperty may result in immediate termination. Wemay use drug testing as a means of enforcing thispolicy.

It is also recognized that individuals may be takingprescription drugs that could impair judgment orother skills required in job performance. If youhave questions about the effect of such medicationon your performance, consult with your supervisor.

Workplace Conduct and Employment Practices cont.

Common Ground

If you are faced with an ethical orcompliance issue:

Consider the facts and how the situationaffects stakeholders.

Observe the policies, procedures, laws andregulations outlined in the Code of Conduct.Also consider your own values. What appliesto this situation?

Measure your alternatives for resolving thesituation.

Make a decision about the best course ofaction.

Organize your thoughts and ask yourselfonce more: Is this the right thing to do? Domy actions support our Code of Conduct?

Notify management in a timely manner.

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Antitrust

Antitrust laws are designed to create a levelplaying field in the marketplace and to promotefair competition. These laws could be violated bydiscussing LifePoint Hospitals’ business with acompetitor, such as how our prices are set,disclosing the terms of supplier relationships,allocating markets among competitors or agreeingwith a competitor to refuse to deal with a supplier.Our competitors are other health systems andfacilities in markets where we operate.

At trade association meetings, be alert to potentialsituations where it may not be appropriate for youto participate in discussions regarding prohibitedsubjects with our competitors. Prohibited subjectsinclude any aspect of pricing, our services in themarket, key costs such as labor costs, andmarketing plans. If a competitor raises a prohibitedsubject, end the conversation immediately.Document your refusal to participate in theconversation by requesting that your objection bereflected in the meeting minutes and notify theCorporate Legal department of the incident.

In general, avoid discussing sensitive topics withcompetitors or suppliers unless you are proceedingwith the advice of the Corporate Legaldepartment.

You must also not provide any information inresponse to oral or written inquiry concerning anantitrust matter without first consulting theCorporate Legal department.

Gathering Information AboutCompetitors

It is not unusual to obtain information about otherorganizations, including our competitors, throughlegal and ethical means such as public documents,public presentations, journal and magazine articles,and other published and spoken information.However, it is not acceptable for you to obtainproprietary or confidential information about acompetitor through illegal means. It is also notacceptable to seek proprietary or confidentialinformation when doing so would require anyoneto violate a contractual agreement, such as aconfidentiality agreement with a prior employer.

Marketing and Advertising

We may use marketing and advertising activities toeducate the public, provide information to thecommunity, increase awareness of our services andrecruit employees. We will present only truthful,fully informative and non-deceptive information inthese materials and announcements. All marketingmaterials will appropriately reflect the level ofservices available.

Marketing Practices

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It is our policy to comply with all environmentallaws and regulations as they relate to LifePointHospitals’ operations. We will act to preserve ournatural resources to the fullest extent reasonablypossible. We will comply with all environmentallaws and operate each of our facilities with thenecessary permits, approvals and controls. We willdiligently employ proper procedures with respectto handling and disposal of hazardous andbiohazardous waste, including medical waste.

In helping LifePoint comply with these laws andregulations, you must understand how job dutiesmay impact the environment, adhere to allrequirements for the proper handling of hazardousmaterials, and immediately alert your supervisor ofany situation regarding the discharge of ahazardous substance, improper disposal of medicalwaste or any situation that may be potentiallydamaging to the environment.

Environmental Compliance

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General

Nothing in this part of the Code of Conduct shouldbe considered in any way as an encouragement tomake, solicit or receive any type of entertainmentor gift. For clarity purposes, note that theselimitations govern activities with those outside ofLifePoint Hospitals. This section does not pertain toactions between the organization and itsemployees nor actions among LifePoint employeesthemselves.

Receiving Business Courtesies

We recognize that there will be times when youmay wish to accept, from a current or potentialbusiness associate, an invitation to attend a socialevent in order to further develop your businessrelationship. These events must not includeexpenses paid for any travel costs (other than in avehicle owned privately or by the host company) orovernight lodging. The cost associated with such anevent must be reasonable and appropriate. As ageneral guideline, this means that the cost will notexceed $100.00 per person.

Sometimes a business associate will extend trainingand educational opportunities that include traveland overnight accommodations to you at no costto you or LifePoint Hospitals. Similarly, there aresome circumstances in which you are invited to anevent at a vendor’s expense to receive informationabout new products or services. Prior to acceptingany such invitation, you must receive approval todo so consistent with the corporate policy on thissubject.

As a LifePoint employee, you may accept gifts witha total value of $50.00 or less in any one year fromany individual or organization who has a businessrelationship with LifePoint. For purposes of thisparagraph, physicians practicing in LifePoint’s

hospitals are considered to have such arelationship. Perishable or consumable gifts givento a department or group are not subject to anyspecific limitation. You may never accept cash orfinancial instruments (e.g., checks, stocks). Finally,under no circumstances may you solicit a gift.

Extending Business Courtesies toNon-referral Sources

No portion of this section applies to any individualwho makes, or is in a position to make, referrals toa LifePoint hospital.

There may be times when you wish to extend to acurrent or potential business associate (other thansomeone who may be in a position to make apatient referral) an invitation to attend a socialevent in order to further develop your businessrelationship. The purpose of the entertainmentmust never be to induce any favorable businessaction. During these events, topics of a businessnature must be discussed and the host must bepresent. These events must not include expensespaid for any travel costs (other than in a vehicleowned privately or by the host entity) or overnightlodging. The cost associated with such an eventmust be reasonable and appropriate. As a generalguideline, this means that the cost will not exceed$100.00 per person.

Business Courtesies

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With regard to the $100.00 guideline, if youanticipate an event will exceed the $100.00guideline or if circumstances arise where anentertainment event was contemplated prior tothe event to meet the guideline but unforeseeablyexceeded it, corporate policy on this subject mustbe followed. LifePoint Hospitals will under nocircumstances sanction participation in anybusiness entertainment that might be consideredlavish.

Also, LifePoint’s hospitals may routinely sponsorevents with a legitimate business purpose.Provided that such events are for businesspurposes, reasonable and appropriate meals andentertainment may be offered. In addition,transportation and lodging can be offered.However, all elements of such events, includingthese courtesy elements, must be consistent withthe corporate policy on such events.

It is critical to avoid the appearance of improprietywhen giving gifts to individuals who do business orwho are seeking to do business with LifePointHospitals. We will never use gifts or otherincentives to improperly influence relationships orbusiness outcomes. Gifts to business associates whoare not government employees must not exceed$50.00 per year per recipient. You may never givecash or financial instuments (e.g., stocks, checks).The corporate policy on business courtesies mayfrom time to time provide modest flexibility inorder to permit appropriate recognition of theefforts of those who have spent meaningfulamounts of volunteer time on behalf of LifePointHospitals.

U.S. federal and state governments have strict rulesand laws regarding gifts, meals and other businesscourtesies for their employees. LifePoint’s policy isto not provide any gifts, entertainment, meals oranything else of value to any employee of theexecutive branch of the federal government,

except for minor refreshments in connection withbusiness discussions or promotional items with theLifePoint Hospitals or hospital logo valued at nomore than $10.00.

With regard to gifts, meals and other businesscourtesies involving any other category ofgovernment official or employee, you mustdetermine the particular rules applying to any suchperson and carefully follow them.

Extending Business Courtesies toPossible Referral Sources

Any entertainment or gift involving physicians orother persons who are in a position to referpatients to our health care facilities must beundertaken in accordance with corporate policies.We will comply with all federal laws, rules andregulations regarding these practices.

Business Courtesies cont.

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LifePoint Hospitals’ political participation is limitedby law. LifePoint’s funds or resources are not to beused to contribute to political campaigns or forgifts or payments to any political party or any oftheir affiliated organizations. Organizationresources include financial and non-financialdonations such as using work time and telephonesto solicit for a political cause or candidate or theloaning of LifePoint property for use in thepolitical campaign. The conduct of any politicalaction committee is to be consistent with relevantlaws and regulations.

It is important to separate personal and corporatepolitical activities in order to comply with theappropriate rules and regulations relating tolobbying or attempting to influence governmentofficials. You may, of course, participate in thepolitical process on your own time and at your own

expense. While you are doing so, it is importantnot to give the impression that you are speakingon behalf of or representing LifePoint Hospitals inthese activities. You cannot seek to be reimbursedby LifePoint for any personal contributions for suchpurposes.

At times, LifePoint may ask employees to makepersonal contact with government officials or towrite letters to present our position on specificissues. In addition, it is a part of the role of someLifePoint management to interface on a regularbasis with government officials. If you are makingthese communications on behalf of theorganization, be certain that you are familiar withany regulatory constraints and observe them.Guidance is always available from the CorporateGovernment Relations and Legal departments asnecessary.

Political Activities and Contributions

Program Structure

The corporate ethics and compliance program isintended to demonstrate, in the clearest possibleterms, the absolute commitment of LifePointHospitals to the highest standards of ethics andcompliance. That commitment permeates all levelsof the organization. There is an oversightcommittee of the board of directors, a corporateethics and compliance officer, a corporate ethicsand compliance committee consisting of seniormanagement and local ethics and complianceofficers. All of these individuals or groups areprepared to support you in meeting the standardsset forth in this Code.

Resources for Guidance andReporting Violations

To obtain guidance on an ethics or complianceissue or to report a suspected violation, you haveseveral options. We encourage the resolution ofissues at a local level whenever possible. It isexpected good practice, when you are comfortableand think it appropriate, to raise concerns firstwith your supervisor.

Another important resource who may be able toaddress issues arising out of this Code of Conduct isthe Human Resources Director. Human ResourcesDirectors are highly knowledgeable about many ofthe compliance risk areas described in this Code ofConduct that pertain to employment and theworkplace and are responsible for ensuringcompliance with various employment laws. If aconcern relates to specific details of an individual’swork situation, rather than larger issues oforganizational ethics and compliance, the HumanResources Director is the most appropriate personto contact.

If it is uncomfortable or inappropriate to raise yourconcern with your supervisor or Human ResourcesDirector, another option is to discuss the situationwith another member of management at yourfacility or within LifePoint. You are always free tocontact the corporate ethics line at 1-877-508-LIFE(5433) or the corporate ethics and complianceofficer directly by email at ethicsandcompliance.officer@lifepointhospitals.com.

Confidentiality and Retaliation

LifePoint Hospitals will make every effort tomaintain, within the limits of the law, theconfidentiality of the identity of any individualwho reports possible misconduct. There will be noretribution for reporting a possible violation ingood faith. Any employee who deliberately makesa false accusation with the purpose of harming orretaliating against another employee will besubject to discipline.

The Corporate Ethics and Compliance Program

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Personal Obligation to Report

We are committed to ethical and legal conductthat is compliant with all relevant laws andregulations and to correcting wrongdoingwherever it may occur in the organization. Eachemployee has an individual responsibility forreporting any activity by any employee, physician,subcontractor or vendor that appears to violateapplicable laws, rules, regulations or this Code.

Internal Investigation of Reports

We are committed to investigate all reportedconcerns promptly and confidentially to the extentpossible. The corporate ethics and complianceofficer will coordinate any findings from theinvestigations and immediately recommendcorrective action or changes that need to be made.We expect all employees and physicians tocooperate with investigation efforts.

Corrective Action

Where an internal investigation substantiates areported violation, it is the policy of LifePointHospitals to initiate corrective action, including, asappropriate, making prompt restitution of anyoverpayment amounts, notifying the appropriategovernmental agency, instituting whateverdisciplinary action is necessary and implementingsystemic changes to prevent a similar violation fromrecurring in the future at any LifePoint facility.

The Corporate Ethics and Compliance Program cont.

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The Corporate Ethics and Compliance Program cont.

Discipline

All violators of the Code of Conduct will be subjectto disciplinary action. The precise discipline utilizedwill depend on the nature, severity and frequencyof the violation and may result in any of thefollowing disciplinary actions:

� verbal warning

� written warning

� written reprimand

� suspension

� termination

and

� restitution (if necessary).

Internal Audit and OtherMonitoring

LifePoint Hospitals is committed to the aggressivemonitoring of compliance with its policies. Much ofthis monitoring effort is provided by Internal Auditand the Compliance department, which routinelyconduct audits of issues that have regulatory orcompliance implications. The organization alsoroutinely seeks other means of ensuring anddemonstrating compliance with laws, regulationsand LifePoint policies.

Acknowledgment Process

LifePoint Hospitals requires all employees to sign anacknowledgment form confirming that they havereceived the Code of Conduct and understand thatit represents mandatory policies of LifePointHospitals. New employees will be required to signthis acknowledgment as a condition of employment.

Adherence to and support of LifePoint Hospitals’Code of Conduct and participation in relatedactivities and training will be considered in decisionsregarding hiring, promotion and compensation forall candidates, employees and physicians.

Notice to All EmployeesRegarding Fraud

The Deficit Reduction Act of 2005, signed intolaw by President Bush on February 8, 2006,contains specific requirements regarding entitiesthat receive more than $5 million annually fromMedicaid. The law, effective January 1, 2007,requires that entities covered by the law havespecific policies dealing with matters of fraudand abuse. In addition, employees are to beinformed about a federal law known as the FalseClaims Act, a civil anti-fraud statute providingthat any person who knowingly submits orcauses the submission of false claims forgovernment funds or property is liable fordamages and penalties. Entities that knowinglyviolate this law can be liable for triple damagesand a penalty from $5,500 to $11,000 per claim.

The False Claims Act contains provisions forindividuals who are known as “relators,” orwhistle blowers. The law provides certainprotection for employees who are retaliatedagainst by an employer because the employeefiled a whistle blower lawsuit. Individuals whohave questions regarding the specifics shouldrefer to LifePoint’s policies for additionalinformation.

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Jackson Purchase Medical Center Patient Care System

PATIENT CARE MODULE

NURSING STUDENT USER MANUAL

Updated 08/2010

2

SYSTEM CONFIDENTIALITY ISSUES Patient information, including orders and test results is confidential and made available only to personnel who need to have access to this information. Personal User ID’s are assigned to all Jackson Purchase Medical Center Patient Care Module (PCM) users. This User ID and password will provide appropriate access to system routines and patient information. Your User ID identifies you by name, and the activity performed under your User ID. NEVER use anyone else’s User ID or password and NEVER allow anyone to use yours. You are held accountable for any activity performed under your User ID and password. The password and confidentiality policy will be strictly enforced, as your User ID and password serves as your legal electronic signature. Use of another’s password is the same as forging their signature to your work. Always exit the system whenever you leave your workstation. This will prevent others from using the system with your personal password. If you feel someone knows and is using your password, notify the Information Systems Department immediately so your password can be changed. (NOTE: A copy of the confidentiality/security agreement is attached at the end of this manual). LOGGING ONTO THE SYSTEM:

1. Double click on the Meditech icon using the mouse. 2. Press the <ENTER> key once more. (If you get an option to choose #1 LIVE, or # 2

TEST, choose #1 LIVE). 3. Now you should be at the User Log On Screen and may enter your User ID that was

issued to you during orientation. Enter your user ID and press the <ENTER> key. 4. Enter your password, and press the <ENTER> key. Passwords will not be displayed for

security reasons. If an incorrect password is entered on three consecutive attempts, the system will lock the keyboard for 60 seconds. You must then wait for the system to unlock the keyboard or use another terminal on your unit.

5. CHANGING YOUR PASSWORD: The first time you access the system, you will get a message at the bottom of your screen that says “One time password. Please choose a new one” Press enter, and a small box will appear asking you to enter a new password. Type in a new password (must be at least 7 characters in length and contain least one letter and one number) and press enter. You will then be asked to “Reenter to verify”. Enter the same password again and press enter. Your password has now been set. Press enter to go on into the system.

LOGGING OFF THE SYSTEM: 1. Press the {EXIT KEY} until you reach the main menu screen. Type “0” to exit, then press

<RETURN> key until all screens are closed and you are back to the computer desktop. 2. ALWAYS sign off the system to the desktop screen when finished charting. If you don't,

someone else may use the computer system with your personal password. REMEMBER! You are responsible for each keystroke associated with your password.

3

SPECIAL FUNCTION KEYS KEYBOARD REFERENCE FOR LAPTOPS & PC’s F1 BEGIN BLOCK F7 BEGIN F2 END BLOCK F8 END F3 FORMAT F 9 LOOKUP F4 GET F10 DELETE LINE (LINEFEED) F5 RECALL F11 EXIT F6 PREVIOUS FIELD F12 OK Pg Up PREV Right Ctrl - SPECIAL FUNCTION KEY ( ) Pg NEXT ESC ESCAPE Down SHIFT + F8 - ON-LINE DOCUMENTATION SHIFT + F12 – MAGIC KEY SPELL CHECK

1. Move your cursor to the beginning of the note you want to spell check. 2. Press Shift + F9. A SET SRCH box appears with several options. 3. Arrow down to the Spell Check option, and enter. 4. If you get a message box that says “DONE”, spell check found no errors. 5. If an error is found, a red pop up box will appear with several options (Ignore,

Change, Suggest, etc). Ignore means spell check will continue without changing the word. Change allows you to correct the word yourself. Suggest will give you possible correct spellings for your word.

4

PROCESS INTERVENTIONS

This routine is "multi-functional"; the user can perform many functions related to patient documentation here, as well as, link to other functions. After the patient's Plan of Care is created, it is important to document that the planned care is being carried out. Process interventions is the primary routine for this to be done.

THE PROCESS INTERVENTION SCREEN

Interventions are grouped under intervention headers, a dash (-) precedes each intervention. Indented under each intervention is its supplementary text. Listed to the right of each intervention are: (Sts) Status of the intervention (Directions) Directions (Frequency) (Lst Doc) Last date of documentation (Src) Source of the intervention (D) Duplicate (Is this intervention a duplicate?) I Comment (has a comment been entered—we do not use) Key Indicator is for Critical Pathways ONLY – (we do not use) (Prt) Protocol – whether protocol text is associated with this intervention

MOVING AROUND THE SCREEN

To Move Press from one intervention to the next <> and <> from one checked intervention to the next checked intervention <Shift> <> or <> to the first intervention <BEGIN> F<7> to the last intervention <END> F<8>

• The Verb Strip Across the top of the screen is a Verb Strip. The verb strip gives you working options for this screen.. To access the desired function, type in the two (2) letters that are highlighted.

5

DOCUMENT INTERVENTIONS “DI”

This is the routine used to document interventions that are performed. 3 ways to “document”. (1) Document a single intervention. (2) “Check off” the interventions you wish to document. (3) Enter multiple times/dates on the green date and time stamp screen.

Highlighting a single intervention: 1. Move the highlight bar to the intervention to be documented. 2. Type in DI where the cursor is flashing in the upper left hand corner. 3. A green screen appears showing date, time, and user. The number of interventions to

be documented along with the number of occurrences is seen at the bottom of the green screen. This is called the “date and time stamp”

4. The cursor is to the right of the “Time” box. To change the time, backspace out the current time and enter the new time (in military time format), then press Enter.

5. At the “OK” prompt, type in “Y” if all the information is correct in the green box. 6. If a documentation screen is attached to the intervention, you will be taken to the

screen to complete. 7. Answer the queries and <F12> to file when completed.

Check off method: This method is to be used only if all checked interventions have been performed at the same time or if the time is irrelevant, i.e. “Care Plan evaluate, “Age Appropriate Guidelines”, etc. 1. To check off the interventions to be documented. use <RIGHT CONTROL> key. 2. Type in “DI”. Follow instructions above regarding changing time/date, etc. if needed. 3. If more than one intervention is checked off, the screens will be brought up

consecutively to document on. Note in the upper right hand corner of the screen the number of interventions checked off. It’s a good idea to always look at this prior to documenting.

4. A yellow box appears at the end of all documenting stating “2 out of 2 done”, “1 out of 2 done”, etc.

Entering Multiple Dates/Times on Date/Time stamp screen: Can enter multiple times and dates. Example: For documentation of vital signs done: 8/21 @ 0700 8/21 @ 0800 8/21 @ 1415 8/21 @ 1430 8/21 @ 1445 8/21 @ 1500 If more than one date and time is entered on the date and time stamp, each screen for documentation will be brought up one after another. (Use the <F6> key to be able to get from the “OK?” prompt, back up to date or time.).

6

DOCUMENT NOW-“DN”

This function is used to document an intervention at the time it occurred and bypasses the date and time stamp. When entering DN on the Process Intervention screen, the screen attached to that intervention will pop up immediately without allowing to change the date or time of the intervention.

PATIENT NOTES – “PN”

This function allows the User to View, Enter, Amend, Edit, Undo, Print Notes ( all notes or by date) or View or Print Undone Notes Type in PN at the verb strip and press ENTER. A pop-up screen will appear with nine options: (1) View Existing Notes (2) Enter New Notes (3) Amend Existing Notes (4) Edit Original Notes (5) Undo Existing Notes (6) Print Notes by Date (7) Print ALL Notes (8) View Undone Notes (9) Print Undone Notes View Notes – Highlight the View existing notes category and right arrow in. This option provides you with 2 choices: ⇒ All types ⇒ No type Highlight the desired choice of note and right arrow in. This will bring you to a blue screen showing the category, note type, dates, times, user and first line of entered notes. To see a particular note, highlight the desired first line press the RT arrow key. The note will appear as it was typed. The Author, Note category, time occurred and recorded time will display. No editing is possible from this category.

Enter New Note – Highlight the Enter New Note function and <RIGHT ARROW> . Then <RIGHT ARROW> on NO TYPE or Intervention. A red screen will pop up with the option If you chose “NO TYPE”, select the note category of either NURSE or PHYSICIAN

ALERTS and <Right Arrow> If you chose “Intervention”, select the intervention you want to link the note to, then

choose the note category and <Right Arrow>. A screen will appear showing date, time, user ID and note category. To change the time of the note press F6, previous field, to move the cursor to the date, then press enter to move the cursor to the time. Using the delete line key (F10), erase the current time and enter the desired time. Keep in mind, the occurred time will be the new time and the recorded time is the actual time of the note. Add the text you wish to write.

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When you complete your note press <F12>. A red file box will appear, Type “Y” at the prompt and then press ENTER. Amend Existing Notes – In the Process Intervention Screen type in PN and then move the highlight bar to Amend Existing Notes and <RIGHT ARROW> . RT arrow in on ALL TYPES. A blue screen appears titled amend notes. It will display the note category, type, date, time, the initials of the person who wrote the note and the first line on the note. Highlight and <RIGHT ARROW> in on the note you wish to amend. Another green screen will appear at the top of the page containing the note to be amended and a blue screen appears at the bottom of the page. In the lower right hand corner of the green screen is printed <Esc>, <Exit> or <Enter> - Amend. This means to press one of these three keys to amend the note. This will bring the cursor into the blue screen and the user may begin typing what additions need to be made to the note. The green screen shows the date and time the note occurred and was recorded, user initials and name, and note category. The blue screen shows the date and time the addendum was made, and the user name and monogram. Once completed, press the <F12> FILE key. Type “Y” at the file prompt. You may exit out from this point. Edit Original Notes- In the Process Intervention Screen, type in PN and then move the highlight bar to Edit Original Notes and <RIGHT ARROW> . RT arrow in on ALL TYPES. A blue screen appears titled Edit Notes. It will display the note category, type, date, time, the initials of the person who wrote the note and the first line on the note. Highlight and <RIGHT ARROW> in on the note you wish to edit. Another green screen will appear at the top of the page containing the note to be edited and a blue screen appears at the bottom of the page. In the lower right hand corner of the green screen is printed <Esc>, <Exit> or <Enter> - Edit. This means to press one of these three keys to edit the note. This will bring the original note into the blue screen and changes can be made to the note. The green screen shows the date and time the note occurred and was recorded, user initials and name, and note category. The blue screen shows the date and time the edit was made, and the user name and monogram. Once completed, press the <F12> FILE key. Type “Y” at the file prompt. You may exit out from this point. Undo Existing Notes – In the Process Intervention Screen, type in PN and then move the highlight bar to Undo Existing Notes and <RIGHT ARROW> . RT arrow in on ALL TYPES. A blue screen appears titled Undo Notes. It will display the note category, type, date, time, the initials of the person who wrote the note and the

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first line on the note. Highlight and <RIGHT ARROW> in on the note you wish to undo. A green screen will appear containing the note to be undone. In the lower right hand corner of the green screen is printed <Esc>, <Exit> or <Enter> - Undo. This means to press one of these three keys to bring the cursor to “Reason for Undo”. Use the F9 Lookup and choose a reason and enter. Enter “Y” at the “Undo this Note?” prompt and enter. You may exit from this point.

ALLERGY LINK – “AL” This function is an on-line method of viewing and editing a patient’s current allergies. Using this function the caregiver may add any new allergies and or view current allergies. On the Process Intervention screen, type in AL and <ENTER>. The blue “Enter/Edit Allergies” screen appears. Current allergies may be viewed or new allergies may be added F9 LOOK UP may be used on each category, (Medication, Food, Contrast Media and Other). Enter the type of reaction in the “Severity/Comment” column. To view an audit history of updates to the allergy screen, hold down the shift key and press the <RIGHT ARROW> key. A red message box will pop up : “Print MEDICATION Allergy History on:” This is set to default to the screen, just press <ENTER>. You will now be able to view the audit on screen and seen when updates have been made and by whom. Press <ENTER> until all pages are viewed. Press <F11> (Exit) to exit the blue allergy screen.

VIEW HISTORY – “VH” This function is an on-line method of looking at the history of a particular intervention. The user can view all documentation, changes, or edits, made to a particular intervention here. This function will also allow you to “edit” or “undo” information recorded via the Document Interventions Function. When “VH” is selected, a green screen appears with functions listed at the top: View Select Undo Edit Equipment Exit. The intervention number and description shows up along with the status, source and directions associated with the intervention. Under the heading “activity”, it shows when the intervention was created, each documentation of this intervention and by whom. VIEW: RT arrow in to see the results of the documentation. SELECT: Not used in our facility UNDO: Type in “U”, you’ll be prompted with the question, “Undo this documentation?” Answer “Y” or “N”. If “Y” a red box pops up asking for a reason to undo. Use the F9 Look-up and choose the appropriate reason. Undo’s should be used if you document on the wrong patient, wrong form , or make a duplicate entry . EDIT: Type in “E”, a red box appears asking for a reason for the edit. Do a F9 Look-up,

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choose the appropriate reason and <ENTER>. The screen attached to this intervention appears. Edits to the documentation can now be made. When editing is completed, file by pressing the F12 key; enter “Y” in the “File?” prompt. The “edited results” now appear in the activity column directly below the original documentation with the reason displayed in the right hand column. <RIGHT ARROW> to see. Edits should be used to correct wrong information documented on the correct patient or to complete interrupted documentation. You cannot “edit” an intervention that does not have a screen attached; you can only “undo” the documentation. Also, you can only edit documentation for up to 24 hours. After that time, a late entry must be made. EQUIPMENT:- Not used in our facility EXIT – May be used to exit out of screens in this function.

VIEW PROTOCOL – “VP” This function allows the user to view protocols that are associated with a particular intervention. If an intervention has a protocol attached an * will appear in the “Prt” column of that intervention. To view, highlight the intervention, and type in VP, <ENTER>. A red screen will appear with the attached protocol. Use the up and down arrow keys to move about in the documentation. When finished press the <ENTER>, <Esc.> or the <Exit> key. This is a view only screen.

SELECT INTERVENTIONS – “SI” This function allows you to choose which interventions you see on the process intervention screen, based on the status, the source of the intervention, and print priority. This can be used to reactivate an intervention that has been previously completed. On the Process Intervention screen, type in SI, <ENTER>. A blue screen pops up. At the sort prompt press Enter to accept the default, INT (intervention header). At the Include Status prompt put in all potential statuses for an intervention— A,C,X,D. Press F12 to file. Type in “Y” at the “File?” prompt. The rest of the fields on this page do not need to be changed or addressed. After filing, the Process Intervention Screen will pop back up. All status of interventions will be displayed.

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PATIENT CARE INQUIRY

(PCI) HOW PCI WORKS The Patient Care Inquiry module is made up of a series of different colored screens. They are in a summary-to-detail format. You move from one screen to the next with the arrow keys. Moving around in PCI: Right arrow in Left arrow out Up and Down arrows move the yellow highlight bar The Order of Screens in PCI: 1. Table of Contents - Red Screen 2. Summary Screen - Green Screen 3. History Screen - Blue Screen 4. Detail Screen - Yellow Screen PCI TERMS VERB STRIP: User options that are displayed across the top of the screen. To select one of these options, enter the highlighted letter of that term. ALLERGIES: Allows you to view the patient’s allergies. JUMP: Allows you to return to the previous screen you were viewing. TIME: Changes the time-frame. SELECT: Allows you to select a specific visit and view only data from that visit.