HIPAA Privacy Notice

The Plan may use and disclose your PHI as described below. The Plan is required to comply with any state or federal laws that impose stricter standards than the uses and disclosures described in this Notice. Your PHI may be stored and disclosed electronically.

For Purposes of Treatment: The Plan may use or disclose your PHI for treatment purposes. “Treatment” is the provision, coordination or management of health care and related services. It also includes, but is not limited to, consultations and referrals between one or more of your providers. For example, the Plan may disclose your PHI to a health care provider when needed by the provider to treat you.

To Make or Obtain Payment: The Plan may use or disclose your PHI to make payment to or collect payment from third parties, such as other health plans or providers, for the care you receive. For example, the Plan may provide information regarding your coverage or health care treatment to other health plans to coordinate payment of benefits. Further, the Plan may disclose your PHI when a provider requests information regarding your eligibility for coverage, or the Plan may use your PHI to determine if a treatment that you received was medically necessary.

To Conduct Health Care Operations: The Plan may use or disclose PHI for their own operations to facilitate the administration of the Plan and as necessary to provide coverage and services to all of the Plan’s participants. “Health care operations” includes quality assessment and improvement activities, activities designed to improve health or reduce health care costs; case management and care coordination; contacting participants with information about treatment alternatives and other related functions, and business management and general administrative activities of the Plan, including customer service and resolution of internal grievances. For example, the Plan may use PHI to conduct case management, quality improvement and utilization review, or to engage in customer service and grievance resolution activities. However, the Plan is prohibited from using or disclosing genetic information for underwriting purposes, such as determinations of eligibility or benefits, or for setting premium or contribution rates.

For Disclosure to the Company: In accordance with HIPAA requirements, the Plan may disclose your PHI to the Company as the plan sponsor of the Plan (“Plan Sponsor”) for plan administration functions performed by Plan Sponsor on behalf of the Plan. Unless authorized by you in writing, your PHI may not be used by the Company for any employment-related actions or decisions or in connection with any other employee benefit plan sponsored by the Company. In addition, the Plan may provide summary health information to the Plan Sponsor so that it may solicit premium bids from health insurers or modify, amend or terminate the Plan. The Plan also may disclose to the Plan Sponsor information on whether you are participating in the Plan.

Business Associates: The Plan contracts with individuals and entities (“Business Associates”) to perform various functions on the Plan’s behalf or to provide certain types of services. To perform these functions or to provide the services, the Plan’s Business Associates will receive, create, maintain, transmit, use, and/or disclose PHI, but only after the Plan requires the Business Associates to agree in writing to contract terms designed to appropriately safeguard the information. The Plan’s Business Associates include its third party administrator(s), which administer(s) many of the functions in connection with the operation of the Plan, and other companies which provide services or products which support the operation of the Plan.

When Legally Required: The Plan will use or disclose your PHI when it is required to do so by any federal, state or local law.

For Public Health Activities: The Plan may use and disclose your PHI for public health activities authorized by law, such as communicable disease reporting.

For Health Oversight Activities: The Plan may disclose your PHI to a government health oversight agency for authorized activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action, and similar activities.

To Report Abuse, Neglect, or Domestic Violence: As authorized by law, the Plan may disclose your PHI to a government authority if the Plan believes that you have been a victim of abuse, neglect, or domestic violence.

In Connection with Judicial and Administrative Proceedings: The Plan may disclose your PHI in response to a court or administrative order. The Plan also may disclose your PHI in response to a subpoena, discovery request, or other lawful process, but only if reasonable efforts have been made either to notify you about the request or to obtain an order protecting your PHI. If the Plan receives records from substance use disorder treatment programs subject to federal privacy restrictions, such records or testimony about their content cannot be used or disclosed in civil, criminal, administrative or legislative proceedings against you unless based on your written consent, or the Plan receives a court order entered after notice and an opportunity to be heard is provided to you or the holder of the record, as provided by federal privacy rules found at 42 CFR Part 2. A court order authorizing use or disclosure must be accompanied by a subpoena or other legal requirement compelling disclosure before the requested record is used or disclosed.

For Law Enforcement Purposes: As authorized by law, the Plan may disclose your PHI to a law enforcement official for certain law enforcement purposes.

To Coroners, Medical Examiners, and Funeral Directors: The Plan may disclose your PHI to coroners, medical examiners, and funeral directors, as authorized by law, prior to and in reasonable anticipation of death.

For Organ, Eye, or Tissue Donation: The Plan may use or disclose your PHI 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: The Plan may use or disclose your PHI for research if certain requirements are met, such as approval by an institutional review board.

In the Event of a Serious Threat to Health or Safety: The Plan may disclose your PHI if the Plan, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public or another person.

For Specified Government Functions: In certain circumstances, the Plan may use or disclose your PHI to facilitate specified government functions related to the military and veterans, national security and intelligence activities, protective services for the President and others, and correctional institutions and inmates.

For Workers’ Compensation: The Plan may release your PHI to the extent necessary to comply with laws related to workers’ compensation or similar programs.

Communication with Family/Disaster Notification: Unless you object, the Plan may disclose to your family members or others involved in your care or payment for your care, information relevant to their involvement in your care or payment for your care, or information necessary to inform them of your location and condition. The Plan also may release information to disaster relief agencies so they may assist in notifying those involved in your care of your location and general condition.