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Northern Arizona Healthcare Cafeteria Benefits
Plan (“the Plan”)
NOTICE OF PRIVACY PRACTICES
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION
ABOUT YOU MAY BE USED AND DISCLOSED BY THE PLAN AND HOW YOU CAN GET ACCESS
TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Northern Arizona Healthcare Cafeteria Health Plan (“the Plan”) is
committed to protecting the confidentiality of your medical information,
and we are required by law to do so. This notice describes how we handle
your medical information, our responsibility to protect its
confidentiality, and the rights you have concerning your medical
information.
How Do We Handle Your Medical Information?
This notice describes the different ways that we may use your
medical information within the Plan and how we may disclose or give it to
others. We will give you examples so that you can understand what happens
with your medical information as we administer your health benefits.
Communications with Insurance Companies: The Plan provides medical
benefits to you through a BlueCross BlueShield of Arizona (“BCBSAZ”),
which administers the Plan. The Plan may communicate with BCBSAZ to assist
you in resolving claims or coverage issues. The Plan also may communicate
with BCBSAZ regarding the company’s administration of the Plan. You
should review the Notice of Privacy Practices of BCBSAZ to see how BCBSAZ
will handle your health information.
Treatment: We may use or disclose your medical information to help
others with your medical treatment, such as hospitals, doctors, and other
health care providers.
Family Members and Other People Involved in Your Care: We may
disclose your medical information to a family member or a close friend who
is helping with your care or with payment for your care. For example, if
your spouse calls us to get information about a claim for your care, we
may talk with your spouse to assist you in resolving a problem. If you
do not want us to discuss your medical information with your family
members or others involved in your care, please contact the Benefits
Analyst in the Human Resources department.
Payment: We use and disclose your medical information to review
bills and pay claims if necessary. We may also share your medical
information with other companies to help us with health claims,
coordination with health insurance companies, or utilization review. We
may communicate with insurance companies to help you resolve problems
about payment of claims.
Plan Operations: We may use or disclose your medical information to
assist us with running the Plan. We may use your medical information to do
medical necessity review; coordination of care, benefits and other
services; program analysis and reporting; audit, accounting or legal
services; risk management; detection and investigation of fraud and other
unlawful conduct; underwriting and ratemaking; resolution of third party
liability; administration of reinsurance and excess or stop loss insurance
and coordination with these insurers; data and information systems
management; and other business management and planning activities. For
example, we may use your medical information to generate data about how we
can serve you better.
Required by Law: Federal, state, or local laws may require us to
disclose a member’s medical information. For example, we may be required
to release information for a workers’ compensation claim.
Lawsuits and Disputes: We must disclose your medical information if
it is legally required. For example, if you are involved in a lawsuit and
the court orders use to release your information, we do so. Legal requests
include subpoenas, discovery requests, search warrants, and other court or
legal orders.
Public Safety: We may disclose medical information for public
safety purposes in limited circumstances. We may give medical information
to law enforcement officials in response to a search warrant or a grand
jury subpoena. We also may disclose medical information to assist law
enforcement officials or others for such purposes as identifying or
locating a person, to prevent a serious threat to health or safety, or for
other reasons.
Health Oversight Activities: We may disclose medical information to
a government agency that oversees the Plan, such as the United States
Department of Labor. Government agencies need medical information to
monitor our compliance with state and federal laws.
Military, Veterans, National Security and Other Government Purposes:
We may disclose information about members of the armed forces, as required
by military command authorities or to the Department of Veterans Affairs.
If requested to do so, we may provide information to federal officials for
intelligence and national security purposes or for presidential Protective
Services.
Information with Additional Protection: Certain types of medical
information have additional protection under state or federal law. For
instance, communicable disease and HIV/AIDS, drug and alcohol abuse
treatment, psychotherapy notes, and genetic testing information is treated
differently than other types of medical information. In certain
circumstances, we would be required to get your permission before
disclosure of this special information.
Northern Arizona Healthcare: NAH is the sponsor of the Plan. Only
designated NAH employees in the Human Resources department will have
access to medical information to perform functions to assist in
administering the Plan.
Other Uses of Your Medical Information: If we wish to use or
disclose your medical information for a purpose that is not discussed in
this notice, we will seek your permission (called an authorization). If
you give your permission to us, you may take back that permission any
time, unless we have already relied on your permission to use or disclose
the information.
What Are Your Rights Regarding Your Medical
Information?
Right to Request a Copy of Your Medical Information: You
have the right to look at your medical information that the Plan holds and
to get a copy of that information. To see your medical information, submit
a written request to the Benefits Analyst. If you request a copy of your
information, we will charge you for our costs to copy the information. We
will tell you in advance what this copying will cost.
Right to Request an Amendment of Your Medical Information: If you
examine your medical information and believe that some of the information
is wrong or incomplete, you may ask us to amend that information. To make
a request to amend your medical information, submit a written request to
the Benefits Analyst, and tell us in detail why you believe your medical
information is wrong or incomplete.
Right to Get a List of Certain Disclosures of Your Medical Information:
You have the right to request a list of some of the disclosures we make of
your medical information. If you would like to receive such a list, submit
a written request to the Benefits Analyst. We will provide the first list
to you free, but we may charge you for any additional lists you request
during the same year. We will tell you in advance what this list will
cost.
Right to Request Confidential Communications: If you want to
communicate with us in a way that you believe is more confidential, please
inform the Benefits Analyst. We will make every effort to assist you.
Right to Request Special Treatment for Your Medical Information: We
handle your medical information in the ways we described in this notice.
You have the right to ask us not to handle your medical information in a
certain way (unless we are required by law to do it). We are not required
to agree to your request, but if we do agree, we will comply with that
agreement. If you want to request special treatment in the way we handle
your medical information, submit your request in writing to the Benefits
Analyst and describe your request in detail.
Right to a Paper Copy: If you received this notice electronically,
you have the right to a paper copy at any time. You may download a paper
copy of the notice from our Web site, or you may obtain a paper copy of
the notice in the Human Resources department.
Will we change this Notice?
From time to time, we may change our practices concerning how we handle
member medical information, or how we will implement the rights we list
above. We reserve the right to change this notice and to make the
provisions in our new notice effective for all medical information we
maintain. If we change these practices, we will publish a revised notice.
You can get a copy of our current notice at any time from our Web site, or
from the Human Resources department.
What if you have problems or concerns?
Please tell us about any problems or concerns you have with your privacy
rights or how the Plan handles your medical information. If you have a
concern, please contact the Privacy Officer. If for some reason we cannot
resolve your concern, you may also file a complaint with the federal
government. We will not penalize you or retaliate against you in any way
for filing a complaint with the federal government.
Do you have any questions?
If you have any questions about this notice, please call the Benefits
Analyst at (928) 773-2050
or write to the Benefit Analyst at Northern Arizona Healthcare, 1200 N.
Beaver Street, Flagstaff,
AZ 86001.
NOTICE OF PRIVACY
PRACTICES
Summary of Material Modification
DATE: April 9, 2003
RE: Amendment to Plan Description: Effective April 14, 2003
This amendment to the Northern Arizona Healthcare Cafeteria Health Plan
(“the Plan”) reflects our strict rules on when the Plan, or the insurance
companies through which the Plan provides employee health benefits (“the
insurance companies”), can give your medical information to Northern
Arizona Healthcare (“NAH”), the Sponsor of the Plan. It also reflects
NAH’s commitment to protect any medical information it receives about you
from the Plan or the insurance companies.
Please review it carefully keep this Summary of Material Modification with
your copy of the Summary Plan Description.
1. Restrictions on Disclosure of Medical Information to NAH
NAH exchanges enrollment and eligibility information with the Plan and
insurance companies, so that the Plan and insurance companies know who is
covered for health benefits. In addition, the Plan and insurance companies
may provide medical information to NAH so that NAH can perform
administration functions for the Plan, such as helping employees deal with
their claims, or administering the self-insurance portion of the employee
health benefits.
2. NAH Obligations Regarding Protecting Medical Information
If the Plan or the insurance companies give your medical information to
NAH, NAH agrees to protect your medical information in the following ways:
• NAH will not use or disclose the medical information it receives from
the Plan or the insurance companies for employment-related decisions or in
connection with any other benefit it offers.
• NAH will use medical information it receives from the Plan or the
insurance companies only to perform Plan administration functions or as
required by law.
• NAH will report to the Plan if it makes any other use or disclosure of
medical information it receives from the Plan or the insurance companies.
• If NAH has any of your medical information to perform Plan
administration functions, NAH will make that information available to you
on request. To ask to see that information, submit a written request to
the Benefits Analyst.
• If you believe any of your medical information held by NAH is erroneous
or incomplete, you may ask NAH to amend that information. To ask NAH to
amend your information, submit a written request to the Benefits Analyst.
• You can ask NAH for a list of disclosures it made for purposes other
than Plan administration functions. To ask for this list, submit a written
request to the Benefits Analyst.
• NAH will make available its internal practices, books, and records
concerning how it uses or discloses the medical information it receives
from the Plan or from insurance companies, to the U.S. Department of
Health and Human Services to determine NAH’s compliance with regulations
concerning the privacy of medical information.
• NAH agrees to return all medical information it receives from the Plan
or the insurance companies, or to destroy that information, when NAH no
longer needs medical information for the Plan administration functions. If
NAH cannot return or destroy that information, it will continue to protect
it.
• NAH will ensure that any agent or subcontractor it uses to perform Plan
administration functions agrees to these same restrictions and conditions.
• Only designated NAH employees in the Human Resources department will
have access to medical information to perform Plan administration
functions. If these employees use or disclose medical information for
purposes other than Plan administration functions, they will be subject to
disciplinary action and sanctions. NAH will promptly report any
noncompliance to the Plan, and will cooperate with the Plan to correct the
problem, to impose appropriate disciplinary action, and to mitigate any
effect of the problem on the member.
Do you have any questions?
If you have any questions about this notice, please call the Benefits
Analyst at (928) 773-2050
or write to the Benefit Analyst at Northern Arizona Healthcare, 1200 N.
Beaver Street, Flagstaff,
AZ 86001.
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