NOTICE OF PRIVACY PRACTICES

NOTICE OF COMMUNITY HEALTH PARTNERSHIP, INC. (CHP)
PARTNERSHIP HEALTH PLAN, INC. (PHP)
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: This notice describes the privacy practices of Community Health Partnership, Inc., Partnership Health Plan, Inc., and CHP-LTS, Inc. (collectively CHP), who have designated themselves as affiliated covered entities for purposes of complying with the HIPAA privacy regulations.

USE AND DISCLOSURE OF HEALTH INFORMATION:

CHP may use your protected health information without your written authorization for purposes of providing you treatment, obtaining payment for your care, and conducting health care operations. CHP has established a policy to guard against unnecessary disclosure of your protected health information. Protected health information (PHI) includes identifying information, financial information, and information about your health and health care services.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSE FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED.

To Provide Treatment. CHP may use your protected health information to coordinate care within CHP and with others involved in your care, such as your attending physician, members of your CHP team and other health care professionals who have agreed to assist CHP in coordinating care. For example: Physicians involved in your care will need information about your symptoms in order to prescribe appropriate medications. CHP also may disclose your protected health care information to individuals outside of CHP involved in your care including family members, suppliers of medical equipment or other health care professionals that CHP uses in order to coordinate your care.

To Obtain Payment. CHP may include your protected health information in invoices to collect payment for the care you may receive from CHP. For example: CHP will be required by Medicaid and Medicare, if you are eligible, to provide information regarding your health care status in order to reimburse CHP, and CHP also may need to explain your need for CHP’s care and the services that will be provided to you. CHP may use or disclose your health information to make payment to or collect from third parties. For example, CHP may provide information regarding your coverage or health care treatment to other health plans to coordinate payment of benefits. CHP may also disclose financial information to family members or others that you designate upon enrollment to assist you with your finances.

To Conduct Health Care Operations. CHP may use and disclose protected health care information for its own operations in order to facilitate the function of CHP and as necessary to provide quality coverage and care to all of CHP’s members/clients. Health care operations include such activities 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/clients 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.
• Accreditation, certification, licensing, or credentialing activities.
• Review and auditing, including compliance review, medical reviews, legal services, and compliance programs. This includes disclosure and exchange of information between CHP and state and federal oversight agencies and their authorized representatives.
• Business planning and development including cost management and planning related analyses and formulary development. This includes the submission of data to federal and state government agencies.
• Business management and general administrative activities of CHP.
• Underwriting and other insurance-related activities.
• Conducting or arranging for legal services.
• Creating “de-identified” protected health information.

For example: CHP may use your protected health information to evaluate its staff performance, combine your health information with other CHP members/clients in evaluating how to more effectively serve all CHP members/clients, disclose your health information to CHP staff and contracted personnel for training purposes, use your health information to contact you as a reminder regarding a visit to you, or contact you or your family as part of general community information or health-related benefit and service mailings that may be of interest to you (unless you tell us you do not want to be contacted).

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED WITHOUT YOUR WRITTEN CONSENT OR AUTHORIZATION.

When Legally Required. CHP will disclose your protected health information when it is required to do so by any federal, state, or local law.

When There are Risks to Public Health. CHP may disclose your protected health information for public activities and purposes 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/client 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 protected health information to a health oversight agency for activities involving our organization including audits, civil administrative or criminal investigation, inspections, licensure, or disciplinary action. CHP, however, may not disclose your protected 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 protected health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only when consistent with state and federal law. The party requesting the documents must make reasonable efforts to notify you or an order is obtained to protect your health information.

For Law Enforcement Purposes. As permitted or required by State law, CHP may disclose your health information to a law enforcement official for certain law enforcement purposes, including, under certain limited circumstance, if you are a victim of a crime or in order to report a crime. In addition, CHP may disclose your PHI in response to a court order in order to identify or locate a suspect, fugitive, material witness, or missing person.

To Coroners and Medical Examiners. CHP may disclose your protected health information to coroners and medical examiners for purposes of determining your cause of death or for other duties, authorized by law.

To Funeral Directors. CHP may disclose your protected health information to funeral directors consistent with applicable law and, if necessary, to carry out their duties with respect to your funeral arrangements. If necessary to carry out their duties, CHP may disclose your health information prior to and in reasonable anticipation of your death.

For Organ, Eye or Tissue Donation. CHP may use or disclose your protected 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 protected health information for research. Before CHP discloses any of your protected health information for such research purposes, the project will be subject to an extensive approval process.

In the Event of a Serious Threat to Health or Safety. CHP may, consistent with applicable law and ethical standards of conduct, disclose your protected 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, the Federal regulations authorize CHP to use or disclose your protected 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 protected health information for worker’s compensation or similar programs.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION

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.

Unless you refuse or object, CHP may also use and disclose your protected health information with persons involved in your care or payment of your care and for fundraising purposes.

Persons Involved in Your Care of Payment for Your Care. CHP may disclose protected health information about you to family members, friends or someone else whom you identify as involved in your care or payment for your care in order to coordinate your care and treatment plan. 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. In addition, we may disclose your protected health information to organizations authorized to handle disaster relief efforts so that those who care for you can receive information about your location or health status.

Fundraising Activities. In the event that CHP engages in fundraising activities, we may use your protected 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, in writing, the Program Manager.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your protected health information that CHP maintains:

• Right to Request Restrictions: You may request restrictions on certain uses and disclosures of your protected health information. You have the right to request a limit on CHP’s disclosure of your protected health information to someone who is involved in your care or the payment of your care. However, CHP is not required to agree to your request. If you wish to make a request for restrictions, please contact the Program Manager or a member of your team at (715) 838-2900.
• Right to Receive Confidential Communications: You have the right to request that CHP communicate with you in a certain way. For example, you may ask that CHP only conduct communications pertaining to your protected health information with you privately with no other family members present. If you wish to receive confidential communications, please contact the Program Manager or a member of your team at (715) 838-2900. CHP will not request that you provide any reasons for your request and will attempt to honor your reasonable requests for confidential communications.
• Right to Inspect and Copy Your Health information: You have the right to inspect and copy your protected health information, including billing records maintained in a designated record set by CHP. A request to inspect and copy records containing your protected health information may be made to the Program Manager or Medical Records Department at (715) 838-2900. 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: If you or your representative believes that your health information records are incorrect or incomplete, you may request that CHP amend the records. That request may be made as long as the information is maintained by CHP. A request for an amendment of records must be made in writing to the Program Manager at Community Health Partnership, 2240 EastRidge Center, Eau Claire, WI 54701. CHP may deny the request if it is not in writing or does not include a reason for the amendment. The request also may be denied if your health information records were not created by CHP, if the records you are requesting are not part of CHP’s designated record set, if the protected health information you wish to amend is not part of the health information you or your representative 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 or your representative have the right to request an accounting of disclosures of your protected health information made by CHP for certain purposes, including purposes authorized by law and certain research The request for an accounting must be made in writing to the CHP Medical Records Department at 2240 EastRidge Center, Eau Claire, WI 54701. 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 six years. CHP would provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests 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 or your representative has a right to a separate paper copy of this notice at any time even if you or your representative has received this Notice previously. To obtain a separate paper copy, you may contact any member of your CHP Team or the CHP Medical Records Department at (715) 838-2900.

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 duties and privacy practices. CHP is required to abide by terms of this Notice as may be amended from time to time. 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 60 days of the change. You or your representative has the right to express complaints to CHP and to the Secretary of Health and Human Services if you or your representative believes that your privacy rights have been violated. Any complaints to CHP should be made in writing to the CHP 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/client 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, 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.