HIPAA Privacy Practices

   Henry Ford Health System Group Health Plans

Notice of Privacy Practices

Effective April 14, 2003

This Notice Describes How Protected Health Information About You May Be Used and Disclosed by the Company's Health Plans and How You Can Get Access To This Information.  Please Review It Carefully.

Our Commitment to Privacy

The Henry Ford Health System group health plan (the "Plan", "we" or "our") is required by law to give you this notice and follows the terms of the notice then in effect.  We must take reasonable steps to ensure the privacy of your personally identifiable health information and to inform you about:

·        The Plan's uses and disclosures of your protected health information.

·        Your privacy rights with respect to your protected health information.

·        The Plan's duties with respect to your protected health information.

·        Your right to file a complaint.

·        The office to contact for further information about the Plan's privacy policies.

The term "protected health information" means all individually identifiable health information transmitted or maintained by the Plan, regardless of form (oral, written or electronic).

How Your Protected Health Information May be Used or Disclosed

The Plan will use and disclose your protected health information to carry out treatment, payment and health care operations.  The following describes these uses and disclosures:

Treatment.  The Plan arranges for health care to be provided to you through insurance companies and others and may use protected health information to coordinate or manage your health care and related services.   For example, we may tell your specialist the name of your primary care physician.

Payment.  Protected health information is used and disclosed to make coverage determinations and payment decisions.  This includes decisions about your Plan benefits, eligibility for Plan benefits, payment for treatment and services, medical necessity and coordinating Plan coverage.  For example, your protected health information may be given to another company to assist with claims payment or benefit coordination.

Health Care Operations.  Protected health information about you may also be used as necessary to run the Plan.  For example, protected health information can be used for:

·                    Conducting quality assessment and improvement activities.

·                    Underwriting and premium rating, and other activities relating to Plan coverage.

·                    Submitting claims for stop-loss (or excess loss) insurance coverage.

·                    Conducting or arranging for medical review.

·                    Business services such as legal and audit services.

·                    Providing you with treatment alternatives and health-related benefits and services.

·                    Fraud and abuse detection programs.

·                    Business planning and development.

·                    General Plan administrative activities.

Disclosing Protected Health Information Under Special Circumstances

As Required By Law.  Protected health information will be disclosed when we are required to do so by federal, state or local law.  For example, protected health information may be disclosed when required by a subpoena or court order in a court or administrative proceeding.

To Avert Serious Threat to Health or Safety.  Protected health information may be used or disclosed when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person.  Any disclosure like this would only be to someone able to help prevent the threat.  Example:  Disclosure of protected health information in a proceeding regarding the licensure of a physician.

Disclosure to Health Plan Sponsor.  Information may be disclosed to another of our health plans to facilitate claims payments under that plan.  Protected health information may be disclosed to the Henry Ford Health System personnel, but solely for the purposes of administering benefits under the Plan.

Organ and Tissue Donation.  Protected health information may be released if you are an organ donor to organizations that handle organ procurement or organ, eye or tissue transplantation or to an organ donation bank, as necessary to facilitate organ or tissue donation and transplantation.

Workers' Compensation.  We may release protected health information about you for workers' compensation or similar programs.  These programs provide benefits for work-related injuries or illnesses.

Public Health Risks.  We may disclose protected health information about you for public health activities, such as disease control or reporting, health and vital statistics such as births and deaths or abuse or neglect reporting.

Health Oversight Activities.  We may disclose protected health information to a health oversight agency for activities authorized by law.  These oversight activities include, for example, audits, investigations, inspections, and licensure.  These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.

Law Enforcement.  We may release protected health information if asked to do so by a law enforcement official.

Coroners, Medical Examiners and Funeral Directors.  We may release protected health information to a coroner or medical examiner.  This may be necessary, for example, to identify a deceased person or determine the cause of death.  We may also release protected health information about patients of the hospital to funeral directors as necessary to carry out their duties.

National Security and Intelligence Activities.  We may release protected health information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.

Inmates.  If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release protected health information about you to the correctional institution or law enforcement official. 

Other Uses of Protected Health Information

Other uses or disclosures of protected health 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 protected health 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 protected health information about you for the reasons covered by your written authorization.  We are unable to take back any disclosures we have already made with your permission.  We are required to retain certain records for business purposes.

Your Rights To Your Own Protected Health Information

You have the following rights regarding protected health information we obtain about you:

Right to Inspect and Copy.  You have the right to inspect and copy protected health information that may be used to make decisions about your Plan benefits.  To inspect and copy protected health information that may be used to make decisions about you, you must submit your request in writing to our Privacy Officer.  If you request a copy of the information, we may charge a fee for the cost 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 protected health information, you may request that the denial be reviewed.

Right to Amend.  If you feel that protected health 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 Plan.  To request an amendment, your request must be made in writing and submitted to our Privacy Officer.  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 protected health information kept by or for the Plan; 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 the Privacy Officer.  Your request must state a time period that may not be longer than six years and not include dates before April 14, 2003.  Your request should indicate in what form you want the list (for example, paper or electronic).  The first list you request within a 12 month period will be free.  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 protected health information we use or disclose about you for treatment, payment or health care operations.  However, we are not required to agree to your request, and you should not expect that we will do so as a result of the additional burden it would impose on Plan operations.

To request restrictions, you must make your request in writing to the Privacy Officer.  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.

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 the Privacy Officer.  We are not required to agree to all requests, but will try to accommodate 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.  To obtain a paper copy of this notice, please make a request, in writing, to the Privacy Officer.  You may also obtain a copy of this notice at http://henry.hfhs.org, click on HR Connect, Benefits, Privacy Practices.

Changes to This Notice

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 protected health 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 or believe that your privacy rights have been violated, you may file a complaint with the Plan or with the Secretary of the Department of Health and Human Services.  To file a complaint with the Plan, contact:

Privacy Officer, Group Health Plans

1 Ford Place, 4E

Detroit, MI 48202

(313) 874-7100

Ask_Ben1@hfhs.org

All complaints must be submitted in writing.  You will not be penalized for filing a complaint.