NOTICE OF COMMUNITY HEALTH PARTNERSHIP, INC.
PARTNERSHIP HEALTH PLAN, INC.
AND CHP-LTS, INC.
PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
APPLICABILITY OF NOTICE. Community Health Partnership, Inc.; Partnership Health Plan, Inc. and CHP-LTS, Inc. (collectively, CHP) are committed to protecting the privacy of your protected health information (Health Information), as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Health Information includes identifying information, financial information, and information about your health and health care services that appear on enrollment, claims, or other records used to make decisions about your health care services.
Your privacy is protected under state and federal law, which require health plans to protect your Health Information and let you know how your Health Information may be used and released to others. There are some circumstances; such as coordinating and providing treatment, obtaining payment for care, and health care operations; under which CHP may use your Health Information without your written authorization. There are other circumstances, however, under which CHP must obtain your written authorization before using or disclosing your Health Information. This notice will go through these different circumstances and will explain what your privacy rights are under the law. When using or disclosing your Health Information, CHP will follow its established policies and procedures to guard against unnecessary disclosure of your Health Information.
USES AND/OR DISCLOSURES OF HEALTH INFORMATION FOR TREATMENT, PAYMENT AND HEALTH CARE OPERATIONS:
To Provide Treatment. CHP may use and/or disclose your Health Information to coordinate care within CHP and with others involved in your care; such as your attending physician, members of your CHP team, your family members, suppliers of medical equipment and other health care professionals who have agreed to assist CHP in coordinating care.
Example: Physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications.
To Obtain Payment. CHP may include your Health Information in invoices to collect payment for the care you may receive from CHP. CHP may use or disclose your Health Information to make payment to or collect from third parties.
Example: CHP may provide information regarding your coverage or health care treatment to other health plans to coordinate payment of benefits.
To Conduct Health Care Operations. CHP may use and disclose yourHealth Information for its own operations in order to facilitate the functions of CHP and as necessary to provide quality coverage and care to all of CHP’s members. Health care operations include activities such as:
- Quality assessment and improvement activities;
- Activities designed to improve health or reduce health care costs;
- Protocol development, case management, and care coordination;
- Contacting health care providers and members with information about treatment alternatives and other related functions that do not include treatment;
- Professional review and performance evaluations;
- Training programs including those in which students, trainees, or practitioners in health care learn under supervision;
- Training of non-health care professionals; and
- Accreditation, certification, licensing, or credentialing activities.
Example: CHP may use your Health Information to evaluate its staff performance, combine your Health Information with other CHP members’ in evaluating how to more effectively serve all CHP members, disclose your Health Information to CHP staff and contracted personnel for training purposes.
USES AND/OR DISCLOSURES OF YOUR HEALTH INFORMATION THAT DO NOT REQUIRE YOUR WRITTEN AUTHORIZATION
In the event a use and/or disclosure described below is prohibited or materially limited by any other applicable law, the more stringent law shall govern.
When Required by Law. CHP will disclose your Health Information when it is required to do so by any local, state, or federal law.
When There are Risks to Public Health. CHP may disclose your Health Information to local, state or federal public health agencies in order to:
- Prevent or control disease, injury or disability, report disease, injuries, vital events such as birth or death and the conduct of public health surveillance, investigations, and interventions.
- To report adverse events and product defects, to track products or enable product recalls and replacements, and to conduct post-marketing surveillance and compliance with requirements of the Food and Drug Administration.
- To notify a person who has been exposed to a communicable disease or who may be at risk of contracting or spreading a disease.
- To an employer about an individual who is a member of the workforce as legally required.
To Report Abuse, Neglect, or Domestic Violence. CHP is allowed to notify government authorities if CHP believes a member is the victim of abuse, neglect or domestic violence. CHP will notify you of any such report unless this notification would place you at risk of harm.
To Conduct Health Oversight Activities. CHP may disclose your Health Information to a health oversight agency for activities involving our organization including audits, civil administrative or criminal investigation, inspections, licensure, or disciplinary action. However, CHPmay not disclose your Health Information without your authorization if you are the subject of an investigation and your Health Information is not directly related to your receipt of health care or public benefits.
In Connection with Judicial and Administrative Proceedings. CHP may disclose your Health Information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal or in response to a subpoena, discovery request or other lawful process.
For Law Enforcement Purposes. CHP may disclose your Health Information to a law enforcement official if the disclosure is for one of the following law enforcement purposes: it is required by law; to identify or locate a suspect, fugitive, material witness or missing person; if you are suspected to be a victim of a crime; to notify next of kin; if the Health Information is evidence of criminal conduct occurring on CHP property.
To Coroners, Medical Examiners and Funeral Directors. CHP may disclose your Health Information to coroners and medical examiners for purposes of identifying a deceased person, determining acause of death or for other duties, authorized by law; and to funeral directors to carry out their duties with respect to your funeral arrangements.
For Organ, Eye or Tissue Donation. CHP may use or disclose your Health Information to organ procurement organizations or other entities engaged in the procurement, banking or transplantation of organs, eyes or tissue for the purpose of facilitating the donation and transplantation.
For Research Purposes. CHP may under very select circumstances, use your Health Information for research. Before CHP discloses any of your Health Information for such research purposes, the project will be subject to an extensive approval process.
To Prevent or Lessen a Serious Threat to Health or Safety. CHP may, consistent with applicable law and ethical standards of conduct, disclose your Health Information if CHP, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to the health and safety of the public.
For Specified Government Functions. In certain circumstances, Federal regulations authorize CHP to use or disclose your Health Information to facilitate specified government functions relating to the military and veteran, national security and intelligence activities, protective services for the President and others, medical suitability determinations and inmates and law enforcement custody.
For Worker’s Compensation. CHP may release your Health Information for worker’s compensation or similar programs.
For Fundraising Activities. In the event that CHP engages in fundraising activities, we may use your Health Information to contact you in our efforts to raise money for CHP. If you do not wish to be contacted for fundraising efforts, you must notify the Compliance Officer in writing at Community Health Partnership, Inc.; Attn: Compliance Officer; 2240 EastRidge Center; Eau Claire, WI 54701.
To Communicate with You. CHP may contact you to provide appointment reminders or information about treatment alternatives or other health-related benefits and services that may be of interest to you.
To Persons Involved in Your Care or Payment for Your Care. CHP may disclose to family members, friends or any other individual you identify your Health Information directly relevant to that person’s involvement with your care and treatment plan. However, before CHP may disclosure your Health Information in this circumstance, CHP must first give you the opportunity to agree to or prohibit or restrict the disclosure. CHP’s notification to you and your agreement or objection to the disclosure is not required to be in writing. If you are unable to function or if there is an emergency, CHP staff will exercise their professional judgment to determine if family or friends should receive information about you.
USES AND/OR DISCLOSURES OF YOUR HEALTH INFORMATION THAT REQUIRE YOUR WRITTEN AUTHORIZATION
Other than is stated above, CHP will not disclose your Health Information other than with your written authorization. If you or your representative authorizes CHP to use or disclose your Health Information for specific stated purposes, you may revoke that authorization in writing at any time.
YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION
You have the following rights regarding your Health Information that CHP maintains:
Right to Request Restrictions. You have the right torequest restrictions on certain uses and/or disclosures of your Health Information, including uses and/or disclosures for treatment, payment, health care operations and disclosures to persons involved in your care, such as family or friends. CHP must agree to restrict the disclosure or use of Health Information if the following requirements are met: the disclosure is to a health plan for the purposes of carrying out payment or health care operations (not for treatment), and the Health Information pertains solely to a healthcare service or item for which you, personally, have paid the provider out of pocket and in full. If the preceding requirements are not met, CHP is not required to agree to your request.
Right to Receive Confidential Communications. You have the right to request that CHP communicate your Health Information with you in certain manners or in certain locations. For example, you may ask that CHP only conduct communications pertaining to your Health Informationwith you privately with no family members present.
Right to Inspect and Copy Your Health information. You have the right to inspect and copy your Health Information, including billing records, maintained in a designated record set by CHP. If you request a copy of your Health Information, CHP may charge a reasonable fee for copying and assembling costs associated with your request.
Right to Amend Health Information. You have the right to request Health Information contained in your CHP designated record set be amended if you believe that the Health Information isincorrect or incomplete. CHP may deny the request if it does not include a reason for the amendment, your records were not created by CHP, if the records you are requesting are not part of CHP’s designated record set, if the Health Information you wish to amend is not part of the information you are permitted to inspect and copy, or if, in the opinion of CHP, the records containing your Health Information are accurate and complete.
Right to an Accounting. You havethe right to request an accounting of disclosures of your Health Information made by CHP for certain purposes, including purposes authorized by law and certain research. The request should specify the time period for the accounting starting on or after April 14, 2003. Accounting requests may not be made for periods of time in excess of 6 (six) years. CHP willprovide the first accounting you request during any twelve(12)-month period without charge. Subsequent accounting requests within the same twelve (12)-month period may be subject to a reasonable cost-based fee. CHP will inform you in advance of the fee, if applicable.
Right to a Paper Copy of this Notice. You have a right to a separate paper copy of this notice at any time even if you have received this Notice previously.
How to Exercise Your Rights. To exercise any of your rights relating to your Health Information, please contact your CHP Team. Your CHP Team will give you a request form that once filled out, you will need to return to CHP’s Compliance Department at: Community Health Partnership, Inc.; Attn: Compliance Department; 2240 EastRidge Center; Eau Claire, WI 54701.
DUTIES OF CHP
CHP is required by law to maintain the privacy of your Health Information and to provide to you and your representative this Notice of its legal duties and privacy practices. CHP is required to abide by terms of this Notice. CHP reserves the right to change the terms of its Notice and to make the new Notice provisions effective for all Health Information that it maintains. If CHP changes its Notice, CHP will provide a copy of the revised Notice to you or your appointed representative within sixty (60) days of the change.
COMPLAINTS
You have the right to express complaints to CHP and to the Secretary of Health and Human Services if you believe that your privacy rights have been violated. Any complaints to CHP should be made in writing to CHP’S Privacy Officer/Compliance Officer. CHP encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.
EFFECTIVE DATE
This Notice is effective April 14, 2003.
CONTACT PERSON
CHP’s contact person for all issues regarding member privacy and your rights under the federal privacy standards is the Privacy Officer/Compliance Officer who can be reached by calling (715) 838-2900 or writing to Community Health Partnership, Inc.; 2240 EastRidge Center; Eau Claire, WI 54701.
In addition, CHP offers a Hotline which allows you to voice your concerns regarding a potential or actual privacy or compliance violation. This Hotline can be reached by calling (715) 858-7839. You will be able to access a voicemail requesting you to leave a message. The Privacy/Compliance Officer will respond to your concern.
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