The Health and Hospital Corporation of Marion County Health Plan (the Health Plan) strongly values protecting the confidentiality and security of health information that the Health Plan collects about you. This notice will tell you how the Health Plan may use and disclose your protected health information. Protected health information means any health information about you that identifies you or for which there is a reasonable basis to believe the information can be used to identify you.

This notice will also tell you about your rights and our duties with respect to your protected medical information. In addition, this notice of privacy practices will tell you how to complain to us if you believe the Health Plan has violated your privacy rights.

The self-insured health plan is operated and managed by a third party administrator, who is responsible for protecting the privacy and confidentiality of your health information. No health plan records are kept at Health and Hospital Corporation.

The Health Plan May Collect and Use Your Protected Health Information in the Following Ways and for the Following Purposes.

The Health Plan collects most protected health information directly from you. The protected health information that you provide the Health Plan when applying for the Health Plan generally includes all the information the Health Plan needs. However, if the Health Plan needs to verify certain information or needs additional information, we may obtain that information from third parties such as adult family members, employers, other insurers, consumer reporting agencies, physicians, hospitals, and other medical personnel. The information the Health Plan collects generally relates to your employment, health, avocations, and/or other personal habits or characteristics as well as transactions with the Health Plan.

The Health Plan uses your protected health information with respect to the Health Plan’s insurance plan and other related business relationships. These business purposes include evaluating requests for insurance, other products or services, evaluating benefit claims, administering products and services, and processing transactions requested by you. To the extent these exist or come into existence, the Health Plan may use your protected health information to offer you other products or services provided by the Health Plan.

The Health Plan May Disclose Your Protected Health Information in the Following Ways and for the Following Purposes.

Treatment.

The Health Plan may disclose your protected health information to provide, coordinate or manage your health care and related services offered by the Health Plan and other health care providers. The Health Plan may disclose medical information about you to doctors, nurses, hospitals, and other health facilities that become involved in your care. The Health Plan may consult with other health care providers concerning you and as part of the consultation, share your protected health information with them. Similarly, the Health Plan may refer you to another health care provider and as part of that referral, share medical information about you with that provider. For example, the Health Plan may conclude you need to receive services from a physician with a particular specialty. When the Health Plan refers you to that physician, the Health Plan will contact that physician’s office and provide medical information about you to them so they have information they need.

Payment.

The Health Plan may use and disclose your protected health information in order to pay for the treatment, services, and items you may receive. This can include billing you, another insurance company, or a third-party payor. For example, the Health Plan may need to contact your health care provider to verify that you received certain treatment(s) and for what range of benefits you qualify. Also, the Health Plan may request details regarding your treatment(s) to determine if your benefits will cover, or pay for, your treatment(s). The Health Plan may work with government programs, such as Medicare or Medicaid, and provide them with information about your medical condition to determine if that program covers you. The Health Plan may also disclose your protected health information to obtain payment from third parties that may be responsible for certain costs.

Health Care Operations.

The Health Plan may disclose medical information about you for its own business operations. The Health Plan may use and disclose your protected health information to evaluate and maintain quality health care services for you. The Health Plan may also use your protected health information to study ways to more efficiently manage our organization and provide more costefficient services to you and all of the Health Plan’s members. For example, the Health Plan may disclose your protected health information to the Health Plan’s sponsor, Health and Hospital Corporation of Marion County, or to outside auditing organizations to evaluate the services provided and ensure compliance with the highest industry standards.

Disclosures Required by Law.

Under certain circumstances, the Health Plan will be required by law to disclose your protected health information to local, state, and federal authorities and organizations. For example, the Health Plan may receive subpoenas or court orders requesting or mandating the release of your protected health information for various administrative, judicial or public health related reasons. These disclosures include, but are not limited to, court proceedings, law enforcement investigations, disease reporting and prevention programs, child abuse and neglect initiatives, and emergency or disaster relief efforts. Although required to disclose your protected health information under these scenarios, the Health Plan will do everything it can do minimize the risk of unauthorized disclosures of your protected health information. The Health Plan will only disclose the minimum necessary information to comply with the request.

Individuals Involved in Your Care.

The Health Plan may disclose to a family member, other relative, a close personal friend, or any other person identified and authorized by you, your protected health information that is directly relevant to that person’s involvement with your care or payment related to your care. The Health Plan also may use or disclose medical information about you to notify those authorized persons of your location, general condition, or death. If there is a family member, other relative, or close personal friend that you do not want the Health Plan to disclose medical information about you to, send your written request to the Health Plan’s contact listed below.

Inmates and Persons in Custody.

The Health Plan may disclose protected health information about you to a correctional institution or law enforcement official having custody of you. The Health Plan will make the disclosure only if the disclosure is necessary: (a) to provide health care to you; (b) for the health and safety of others; or, (c) for the safety and security of the correctional institution.

Workers Compensation.

The Health Plan may disclose protected health information about you to the extent necessary to comply with workers’ compensation and similar laws that provide benefits for work-related injuries or illness.

How the Health Plan Will Contact You.

Unless you tell the Health Plan otherwise in writing, the Health Plan may contact you by telephone or mail at your home or your office. The Health Plan may leave messages for you on an answering machine or a voice mail system. You have the right to request that the Health Plan communicates your protected health information only in a certain way or at a certain location. If reasonable, the Health Plan will accommodate your request. Send your written request for confidential communications to the Health Plan’s contact listed below. Your request must state specifically how and/or where you wish to be contacted.

Right to Request Restrictions.

Under certain circumstances, you have the right to request that the Health Plan restrict the uses or disclosures of your protected health information. For example, you could ask that the Health Plan not disclose your protected health information to a specific family member. To request a restriction, send your written request to the Health Plan’s contact listed below. You should explain: (a) what information you want to limit; (b) whether you want to limit use or disclosure or both; and, (c) to whom you want the limits to apply.

The Health Plan is not required to agree to any requested restriction. However, if the Health Plan does agree, the Health Plan will follow that restriction unless the information is needed to provide emergency treatment. The restriction will remain in effect until you submit a written termination.

Right to Inspect, Copy and Amend.

With a few limited exceptions, you have the right to inspect and obtain a copy of your protected health information. To request inspection or copies, send your written request to the Health Plan’s contact listed below. Your request should state specifically what protected health information you want to inspect or copy. If your request is granted, the Health Plan may charge a fee for the costs of copying and mailing. If the Health Plan denies your request, the Health Plan will explain the denial in writing and inform you of any additional rights you may have.

With some exceptions, you also have the right to ask the Health Plan to amend your protected health information records. You have this right for as long as the Health Plan maintains your protected health information. To request an amendment, send your written request to the Health Plan’s contact listed below. Your request must state the amendment or changes(s) desired and provide a detailed reason for the amendment. If your request is granted, the Health Plan will make the appropriate changes and inform others, as needed or required. If the Health Plan denies your request, the Health Plan will explain the denial in writing and inform you of any additional rights you may have.

Right to an Accounting of Disclosures.

You have the right to receive an accounting of disclosures of your protected health information made by the Health Plan. The accounting may be for up to six (6) years prior to the date on which you request the accounting but not before April 14, 2003. Federal law does not provide for an accounting of certain disclosures, including those made for treatment, payment, operations, correctional institutions, law enforcement, national security, or intelligence purposes.

To request an accounting of disclosures, send your written request to the Health Plan’s contact listed below. Your request must state a beginning and ending date for the time period in question.

The Health Plan’s Rights and Obligations Regarding the Notice of Privacy Practices.

Federal law requires the Health Plan to maintain the privacy of your protected health information and to provide you with this Notice of Privacy Practices with respect to your protected health information. The Health Plan is required to comply with the terms of the notice currently in effect. While the Health Plan reserves the right to change its Notice of Privacy Practices, federal law requires it to notify you of any and all changes to that notice. A copy of our current Notice of Privacy Practices will be posted and made available on the Health Plan’s website at www.hhcorp.org and at the Health Plan sponsor’s headquarters at Health and Hospital Corporation of Marion County, 3838 N. Rural Street, Indianapolis, IN 46205. You may obtain a copy of the current Notice of Privacy Practices by sending your written request to the Health Plan’s contact listed below.

Complaints.

You may complain to the Health Plan and to the United States Secretary of Health and Human Services if you believe the Health Plan has violated rights your privacy rights. To file a complaint with the Health Plan, send your written complaint to the Health Plan’s contact listed below. Your complaint must contain a detailed explanation of the reason(s) for your complaint.

To file a complaint with the United States Secretary of Health and Human Services, send your complaint to: Office for Civil Rights, U.S. Department of Health and Human Services, 200 Independence Avenue SW, Washington, D.C. 20201.

You cannot be penalized for filing a complaint.

Contact Information.

To contact the Health Plan for any reason, please send written correspondence to: HIPAA Privacy Officer, Health and Hospital Corporation of Marion County, 3838 N. Rural Street, Indianapolis, IN 46205.

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