21st Century Health & Benefits, Inc.
220 Lake Drive East, Suite 300
Cherry Hill, NJ 08002
Attn: Privacy Officer
C/O: Privacy Director
Telephone: 856.382.0321

This notice will tell you about the ways we may use and disclose medical information about you. It also describes our obligations and your rights regarding our use and disclosure of medical information. We are required by law to:

• Make sure medical information that identifies you is kept private;
• Give you this notice of our legal duties and privacy practices with respect to medical information about you; and
• Follow the terms of the notice that is currently in effect.

How We May Use and Disclose Medical Information About You:
The following categories describe different ways that we use and disclose medical information. For each category of uses or disclosures we explain what we mean and present some examples. Not every use or disclosure in a category will be listed. However, all of the ways we are permitted to use and disclose information will fall within one of these categories.

For Payment.

As the Plan Administrator for the employee benefits plan in which you may participate, we and our Business Associates may use and disclose medical information about you to determine eligibility for benefits under the plan; to facilitate payment for the treatment, goods and services you receive from health care providers; to determine benefit responsibility under the plans we serve; or to coordinate plan coverage. For example, we use medical information about you from your health care provider to help determine whether a particular treatment is experimental, investigational or medically necessary or to determine whether the Plan will cover a service or treatment. We may also share medical information with a utilization review or precertification service provider. Likewise, we may share medical information with another entity to assist with the adjudication or subrogation of health claims or with another health plan or insurance company to coordinate benefit payments. In addition, we may release medical information about you for workers' compensation or similar programs. We may also disclose medical information about you in our explanation of benefits forms that describe in general what services were performed, whether they were covered, and to what extent. These explanation of benefits forms are sent to the health care provider that billed the health care benefits plan for the services performed or goods purchased and they are sent to the enrollee in the employee benefits plan.

For Health Care Operations.

We may use and disclose medical information about you for other operations of the employee health care benefits plan in which you may participate. These uses and disclosures are necessary to run the plan. For example, we may use or disclose medical information in connection with:

• Conducting quality assessment and improvement activities
• Underwriting, premium rating and other activities relating to coverage under the plan
• Submitting claims for stop-loss (or excess loss) coverage
• Conducting or arranging for medical review, legal services, audit services and fraud and abuse detection programs
• Business planning and development such as cost management, business management and general plan administration activities and
• Pre-certification, case management, disability management or disease management entities.

Information may also be disclosed to another health plan for purposes of facilitating claims payments under that plan. In addition, medical information may be disclosed to the benefits or human resources staff of your employer, but only for purposes of administering benefits under the plan.

As Required By Law.

We will disclose medical information about you when required to do so by federal, state, or local laws, rules or regulations. For example, we may disclose medical information about you in response to a court or administrative order. We may also disclose medical information about you in response to a subpoena, discovery request or other lawful process. In addition, we may release medical information about you if asked to do so by a duly authorized law enforcement or regulatory official. Further, we may release medical information about you to authorized federal officials for intelligence, counterintelligence and other national security activities authorized by law.

If the privacy laws of a particular state are more stringent than the HIPAA Privacy Rule, we may be required to abide by the state law. For example, we may be required to follow the state privacy law on the disclosures of PHI for all covered enrollees and dependents related to specific conditions or of the disclosures of PHI of minors.

All other uses and disclosures of your medical information that are not related to Payment or Health Care Operations or as required by law will only be released upon your written authorization. You have the right to revoke your authorization at any time. To revoke your authorization you must submit a completed Notice of Revocation of Authorization form to 21st Century Health & Benefits Inc.'s Privacy Officer at the address listed at the beginning of this notice. Forms may be obtained from the Privacy Officer or your Human Resources Representative.

Your Rights Regarding Medical Information About You:
You have the following rights regarding medical information we maintain about you:

Right to Inspect and Copy.

You have the right to inspect and copy medical information that may be used to make decisions about your benefits under the employee health benefits plan in which you may participate. To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing to 21st Century Health & Benefits Inc.'s Privacy Officer at the address listed at the beginning of this notice. If you request a copy of the information, we may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to inspect and copy in certain very limited circumstances. If you are denied access to medical information, you may request that the denial be reviewed.

Right to Amend.

If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by or for the employee health benefits plan in which you may participate. To request an amendment, your request must be made in writing and submitted to 21st Century Health & Benefits Inc.'s Privacy Officer at the address listed at the beginning of this notice. In addition, you must provide a reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if you ask us to amend information that:

• Is not part of the medical information kept by or for the employee health benefits plan in which you may participate
• Was not created by us, unless the person or entity that created the information is no longer available to make the amendment
• Is not part of the information which you would be permitted to inspect and copy or
• Is accurate and complete

Right to an Accounting of Disclosures.

You have the right to request an "Accounting of Disclosures" where such disclosure was made for any purpose other than treatment, payment or health care operations. To request this list or accounting of disclosures, you must submit your request in writing to 21st Century Health & Benefits Inc.'s Privacy Officer at the address at the beginning of this notice. Your request must state a time period, which may not be longer than six years and may not include dates before April 14, 2003. The first list you request within a 12-month period will be free of charge. For additional lists, we may charge you for the costs of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.

Right to Request Restrictions.

You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations. You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment of your care, like a family member or friend. For example, you could ask that we not use or disclose information about a surgery you have had. We are not required to agree to your request. To request restrictions, you must make your request in writing to 21st Century Health & Benefits Inc.'s Privacy Officer at the address listed at the beginning of this notice. In your request, you must tell us (1) what information you want to limit; (2) whether you want to limit our use, disclosure or both; and (3) to whom you want the limits to apply, for example, disclosures to your spouse.

Right to Request Confidential Communications.

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing to 21st Century Health & Benefits Inc.'s Privacy Officer at the address listed at the beginning of this notice. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

Right to a Paper Copy of This Notice.

You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy of this notice. You may obtain a copy of this notice at our website, www.21stcenturyhealth.com. To obtain a paper copy of this notice, please contact 21st Century Health & Benefits Inc.'s Privacy Officer at the address and phone number listed at the beginning of this notice.

Changes to This Notice:
We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical information we already have about you as well as any information we receive in the future. We will post a copy of the current notice on our website. The notice will contain the effective date on the first page, in the top right-hand corner.

Complaints:
If you believe your privacy rights have been violated, you may file a complaint with us or with the Secretary of the Department of Health and Human Services. To file a complaint with us, contact 21st Century Health & Benefits Inc.'s Privacy Officer at the address and phone number listed at the beginning of this notice. All complaints must be submitted in writing. You will not be penalized for filing a complaint.

Other Uses of Medical Information:
Other uses and disclosures of medical information not covered by this notice or the laws that apply to us will be made only with your written permission. If you provide us permission to use or disclose medical information about you, you may revoke that permission, in writing at any time. If you revoke your permission, we will no longer use or disclose medical information about you for the reasons covered by your written authorization. You understand that we are unable to take back any disclosures we have already made with your permission, and that we are required to retain our records of the claims submissions we have received from you or from your health care providers.