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.
Health Alliance Plan
Alliance Health and Life Insurance Company
Your Protected Health Information (PHI)
PHI stands for the words Protected Health Information. PHI is health information that includes your name, member ID number or other items that can be used to identify you.
Important Information About Privacy...
Protecting the privacy of your personal and health information is important to HAP. We are required by law to maintain the privacy of your information and to provide you with notice of our legal duties and privacy practices. That is what this notice is for. It explains how we use information about you and when we can share that information with others. It also tells you about your rights with respect to your personal and health information and how you can use your rights. We are required to stand by the terms of this notice. If your information is subject to a breach (if it is used by or shared with someone who is not authorized to use or have your information), we are required to notify you in writing.
When we use the term "member information" or "information" in this notice, we are referring to the personal and health information about you that we collect when you fill out enrollment and other forms or when you obtain our services. We keep this information and use it to provide services to you and to operate HAP.
When we use the term "HAP", "we" or "us" in this notice, we are referring to Health Alliance Plan and its subsidiaries, including Alliance Health and Life Insurance Company.
How We Protect Your PHI
We protect your PHI whether it is written, spoken or in electronic form by requiring employees and others who handle your information to follow specific confidentiality and technology usage policies. When they begin working for HAP, all employees and contractors must sign that they have reviewed HAP's policies and that they will protect member information even after they leave HAP. An employee or contractor's use of protected information is limited to the minimum amount of information necessary to perform a legitimate job function. Employees and contractors also are required to comply with this privacy notice, and may not use or disclose your information except as described in this notice.
Using and Disclosing PHI
The following sections describe how HAP uses and your health information. We share your information only with those who have a "need to know" in order to perform the tasks listed below:
Treatment
We may share your member information with your doctors, hospitals or other providers to help them provide medical care to you. For example, if you are in the hospital, we may give them access to any medical records sent to us by your doctor.
We may use or share your member information with others to help manage your health care. For example, we might talk to your doctor to suggest a disease management or wellness program that could help improve your health.
Payment
We may use or share your member information to help us determine who is financially responsible for your medical bills.
Operations
We share your member information with affiliated companies as permitted by law, non-affiliated third parties with whom we contract to help us operate HAP, and with others who are involved in providing or paying for health care services for you. We may share your information with others who help us conduct our business operations. If we do so, we will require these persons or entities to protect the privacy and security of your information, and to return or destroy such information when it is no longer needed for our business operations.
Other Uses and Disclosures that are Permitted or Required
HAP may also use or release your health information:
- For certain types of public health or disaster relief efforts
- To give you information about alternative medical treatments and programs or about health related products and services that you may be interested in. For example, we might send you information about smoking cessation or weight loss programs.
- To give you reminders relating to your health such as a reminder to refill your prescription(s) or to schedule recommended health screenings.
- For research purposes. For example, a research organization may wish to compare outcomes of all patients that receive a particular drug and will need to review a series of medical records. In all cases where your specific authorization has not been obtained, your privacy will be protected by strict confidentiality requirements applied by an institutional review board or privacy board, which oversees the research, or by representations of the researchers that limit their use and disclosure.
- To report information to state and federal agencies that regulate us, such as the US Department of Health and Human Services and the Michigan Office of Financial and Insurance Services.
- When needed by the employer/plan sponsor to administer your health benefit plan
- For certain FDA investigations such as investigations of harmful events, product defects or for product recalls.
- For public health activities if we believe there is a serious health or safety threat.
- For health oversight activities authorized by law.
- For court proceedings and law enforcement purposes.
- To a government authority regarding abuse, neglect or domestic violence.
- To a coroner or medical examiner to identify a deceased person, determine a cause of death, or as authorized by law. We may also share member information with funeral directors as necessary to carry out their duties.
- to comply with workers' compensation laws.
- For procurement, banking or transplantation of organs, eyes or tissue.
- When permitted to be released to government agencies for protection of the president.
- For underwriting purposes, when allowed by law. We are not permitted to use or release genetic information about you for underwriting purposes.
If one of the above reasons does not apply, we must get your written permission to use or disclose your member information. We must get your written permission to share your information for marketing purpose or to sell your information. If you give us written permission and change your mind you may cancel your written permission at any time. Cancellation of your permission will not apply to any information we have already disclosed. We may ask you to complete a form when making a request. Once you give us authorization to release your member information, we cannot guarantee that the person to whom the information is provided will not disclose the information.
Other Uses of Health Information
- We may release your member information to a friend, family member or other individual who is authorized by law to act on your behalf. For example, parents may obtain information about their children covered by HAP, even if the parent is not covered by HAP.
- We may use or share your information with an employee benefit plan through which you receive health benefits. Except for enrollment information or summary health information and as otherwise required by law, we will not share your information with an employer or plan sponsor unless the employer or plan sponsor has provided us with written assurances that the information will be kept confidential and will not be used for an improper purpose. Generally, information will only be shared when needed by the employer/plan sponsor to administer your health benefit plan.
- We may give a limited amount of information to someone who helps pay for your care. For example, if your spouse contacts us about a claim, we may tell him/her whether the claim has been paid.
- We may use your information so that we can contact you, either by phone or by mail, in order to conduct surveys, such as the annual member satisfaction survey.
- In certain extraordinary circumstances, such as a medical emergency, we may release your information as necessary to a friend or family member who is involved in your care, if we determine that the release of information is in your best interest. For example, if you have a medical emergency in a foreign country and are unable to contact us directly, we may speak with a friend or family member who is acting on your behalf.
Your Member Rights
The following are your rights with respect to your member information. If you would like to exercise the following rights, please contact us as described below, under "Who to Contact".
- You have the right to ask us to restrict how we use or disclose your member information for treatment, payment, or health care operations. You also have the right to ask us to restrict member information that we have been asked to give to family members or to others who are involved in your health care or payment for your health care. Please note that we are not required to agree to these restrictions.
- You have the right to ask to receive confidential communications of information. For example, if you believe that you would be harmed if we send your information to your current mailing address (for example in situations involving domestic disputes or violence), you can ask us to send the information by alternative means, for example, by fax or to an alternative address. We will try to accommodate reasonable requests.
- You have the right to inspect and obtain a copy of member information that we maintain about you. We may deny your request to inspect and copy your member information in certain, limited circumstances. For example, we may deny your request if review of the records could endanger you or another person. We may charge you a fee for copies. We will inform you in advance of the fee and provide you with an opportunity to withdraw or modify your request.
- You have the right to ask us to amend member information we maintain about you. We will require that the information you provide be accurate. We are unable to delete any part of a legal record, such as a claim submitted by your doctor. Please note that we are not required to agree to a request to amend.
- You have the right to receive an accounting of certain disclosures of your member information made by us during the six years prior to your request. Please note that we are not required to provide you with an accounting of all disclosures we make. For example, we are not required to provide you with an accounting of member information collected prior to April 14, 2003; information disclosed or used for treatment, payment, and health care operations purposes; or information disclosed to you or pursuant to your authorization.
Your first accounting in any 12-month period is free. However, if you request an additional accounting within 12 months of receiving your free accounting, we may charge you a fee. We will inform you in advance of the fee and provide you with an opportunity to withdraw or modify your request.
- You have a right to receive a paper copy of this notice upon request at any time.
Your request to exercise any of the above member rights must be in writing and be signed by you or your representative. We may ask you to complete a form when making a request.
Changes to this Privacy Statement
We may from time-to-time change the contents of this notice and reserve the right to do so. If we do so the new notice will be effective for all the member information maintained by us. Once revised, we will provide the new notice to you by mail and post it on our website.
Who to Contact
If you have any questions about this notice or about how we use or share member information, you may contact the HAP Privacy Officer by mail at:
Health Alliance Plan
Attn: Privacy Officer
2850 West Grand Blvd, Detroit, MI 48202
You may also call us at (313) 872-8100 or 1-800-422-4641 or send us an e-mail by clicking "Contact HAP" at the top of the page on HAP's website (www.hap.org).
Complaints
If you believe your privacy rights have been violated, you may file a complaint with us by contacting the Privacy Officer as noted above, or filing a grievance with the Client Services Department. You may also notify the Secretary of the U.S. Department of Health and Human Services of your complaint. We will not take any action against you for filing a complaint.
Original Effective Date: 4/13/2003
Revisions: 2/05; 11/07; 9/13
Reviewed: 11/08; 11/09; 10/11
