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HIPAA Privacy Policy

Effective Date: April 14, 2003

Latest Revision: January 1, 2020

 

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU MAY OBTAIN ACCESS TO THIS INFORMATION.

PLEASE REVIEW IT CAREFULLY

 

 

Use and Disclosure of Health Information

The Columbia University Health Plan ("the Health Plan") may use your health information, that is, information that constitutes protected health information as defined in the Privacy Rule of the Administrative Simplification provision of the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), for purposes of making or obtaining payment for your care and conducting health care operations. The Health Plan. has established a policy to guard against unnecessary disclosure of your health information. The Health Plan includes Aetna Columbia Dental Plan, Aetna HMO, Emblem Health, Empire Blue Cross, CIGNA Modified Indemnity, CIGNA International, CIGNA Plan B, Optum, Optum Rx, UnitedHealthcare Choice Plus, HDHP, Medicare Advantage and Healthcare Flexible Spending Accounts.

THE FOLLOWING IS A SUMMARY OF THE CIRCUMSTANCES UNDER WHICH AND PURPOSES FOR WHICH YOUR HEALTH INFORMATION MAY BE USED AND DISCLOSED:

To Make or Obtain Payment.

The Health Plan may use or disclose your health information 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 Health Plan may provide information regarding your coverage or health care treatment to other health plans to coordinate payment of benefits. 

To Conduct Health Care Operations.

The Health Plan may use or disclose health information for its own operations to facilitate the administration of the Health Plan and as necessary to provide coverage and services to all of the Health Plan's participants. Health care operations includes such activities as:

• Quality assessment and improvement activities.

• Activities designed to improve health or reduce health care costs.

• Clinical guideline and protocol development, case management and care coordination.

• Contacting health care providers and participants with information about treatment alternatives and other related functions.

• Health care professional competence or qualifications review and performance evaluation.

• Accreditation, certification, licensing or credentialing activities.

• Underwriting, premium rating or related functions to create, renew or replace health insurance or health benefits.

• Review and auditing, including compliance reviews, medical reviews, legal services and compliance programs.

• Business planning and development including cost management and planning related analyses and formulary development.

• Business management and general administrative activities of the Health Plan, including customer service and resolution of internal grievances. 

For example, the Health Plan may use your health information to conduct case management, quality improvement and utilization review, and provider credentialing activities or to engage in customer service and grievance resolution activities.

For Treatment Alternatives.

The Health Plan may use and disclose your health information to tell you about or recommend possible treatment options or alternatives that may be of interest to you.

For Distribution of Health-Related Benefits and Services.

The Health Plan may use or disclose your health information to provide to you information on health-related benefits and services that may be of interest to you.

To Individuals Involved in Your Care or Payment for Your Care.

The Health Plan may release medical information about you to a friend or family member who is involved in your medical care. The Health Plan may also give information to someone who helps pay for your care. In addition, the Health Plan may disclose medical information about you to an entity assisting in a disaster relief effort so that your family can be notified about your condition, status, and location. 

For Disclosure to the Plan Sponsor.

The Health Plan may disclose your health information to the plan sponsor for plan administration functions performed by the plan sponsor on behalf of the Health Plan. In addition, the Health Plan may provide summary health information to the plan sponsor so that the plan sponsor may solicit premium bids from health insurers or modify, amend or terminate the plan. The Health Plan also may disclose to the plan sponsor information on whether you are participating in the Health Plan.

When Legally Required.

The Health Plan will disclose your health information when it is required to do so by any federal, state or local law. 

To Conduct Health Oversight Activities.

The Health Plan may disclose your health information to a health oversight agency for authorized activities including audits, civil administrative or criminal investigations, inspections, licensure or disciplinary action. The Health Plan, however, may not disclose your health information if you are the subject of an investigation and the investigation does not arise out of or is not directly related to your receipt of health care or public benefits. 

In Connection With Judicial and Administrative Proceedings.

As permitted or required by state law, the Health Plan may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only when the Health Plan makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information.

For Law Enforcement Purposes.

As permitted or required by state law, the Health Plan may disclose your health information to a law enforcement official for certain law enforcement purposes, including, but not limited to, if the Health Plan has a suspicion that your death was the result of criminal conduct or in an emergency to report a crime. 

In the Event of a Serious Threat to Health or Safety.

The Health Plan may, consistent with applicable law and ethical standards of conduct, disclose your health information if the Health 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. 

For Specified Government Functions.  

In certain circumstances, federal regulations require the Health Plan to use or disclose your health information 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 Health Plan may release your health information to the extent necessary to comply with laws related to workers' compensation or similar programs.

In the Event of your Death

The Health Plan disclose PHI about you to a coroner or medical examiner to identify you or determine your cause of death.  The Health Plan may also disclose your PHI to a funeral director to permit him or her to carry out his or her duties.   

Other Restrictions on Use/Disclosure

In no event will we use or disclose PHI that is genetic information for underwriting purposes.  In addition to rating and pricing a group insurance policy, this means the Health Plans may not use genetic information (including that requested or collected in a health risk assessment or wellness program) for setting deductibles or other cost sharing mechanisms, determining premiums or other contribution amounts, or applying preexisting condition exclusions.

State law may further limit the permissible ways the Health Plan uses or discloses your PHI.  If an applicable state law imposes stricter restrictions on the Health Plan, we will comply with that state law.

Authorization to Use or Disclose Health Information

Other than as stated above, the Health Plan will not disclose your health information other than with your written authorization. This includes disclosures of PHI containing psychotherapy notes (except as necessary for the Health Plans’ treatment, payment and healthcare operating purposes), for many marketing purposes and for any sale of your PHI, each as defined under HIPAA regulations. If you authorize the Health Plan to use or disclose your health information, you may revoke that authorization in writing at any time.  Once we receive your written revocation, it will only be effective for future uses and disclosures.  It will not be effective for any information that may have been used or disclosed in reliance upon the written authorization and prior to receiving your written revocation.

Your Rights With Respect to Your Health Information

You have the following rights regarding your health information that the Health Plan maintains:

Right to Request Restrictions.

You may request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on the Health Plan's disclosure of your health information to someone involved in the payment of your care. However, the Health Plan is not required to agree to your request. If you wish to make a request for restrictions, please make your request in writing to the Privacy Officer.

Right to Receive Confidential Communications. 

You have the right to request that the Health Plan communicate with you in a certain way if you feel the disclosure of your health information could endanger you. For example, you may ask that the Health Plan only communicate with you at a certain telephone number or by email. If you wish to receive confidential communications, please make your request in writing to the Privacy Officer. The Health Plan will attempt to honor your reasonable requests for confidential communications.

Right to Inspect and Copy Your Health Information. 

You have the right to inspect and copy your health information. A request to inspect and copy records containing your health information must be made in writing to the Privacy Officer. If you request a copy of your health information, the Health Plan may charge a reasonable fee for copying, assembling costs and postage, if applicable, associated with your request.

Right to Amend Your Health Information.

If you believe that your health information records are inaccurate or incomplete, you may request that the Health Plan amend the records. That request may be made as long as the information is maintained by the Health Plan. A request for an amendment of records must be made in writing to the Privacy Officer. The Health Plan may deny the request if it does not include a reason to support the amendment. The request also may be denied if your health information records were not created by the Health Plan, if the health information you are requesting to amend is not part of the Health Plan's records, if the health information you wish to amend falls within an exception to the health information you are permitted to inspect and copy, or if the Health Plan determines the records containing your health information are accurate and complete.

Right to an Accounting.

You have the right to request a list of certain disclosures of your health information that the Health Plan is required to keep a record of under the Privacy Rule, such as disclosures for public purposes authorized by law or disclosures that are not in accordance with the Plan's privacy policies and applicable law. The request must be made in writing to the Privacy Officer. The request should specify the time period for which you are requesting the information, but may not be made for periods of time going back more than six (6) years. The accounting will not include (1) disclosures necessary for treatment, to determine proper payment of benefits or to operate the Health Plans, (2) disclosures we make to you, (3) disclosures permitted by your authorization, (4) disclosures to friends or family members made in your presence or because of an emergency, (5) disclosures for national security purposes or law enforcement, or (6) as part of a limited data set.  The Health Plan will provide the first accounting you request during any 12-month period without charge. Subsequent accounting requests may be subject to a reasonable cost-based fee. The Health Plan will inform you in advance of the fee, if applicable. 

Right to a Paper Copy of this Notice.

You have a right to request and receive a paper copy of this Notice at any time, even if you have received this Notice previously or agreed to receive the Notice electronically. To obtain a paper copy, please contact the Privacy Officer. The authorization form (Word) is available online as well.

Duties of the Health Plan

The Health Plan is required by law to maintain the privacy of your health information as set forth in this Notice and to provide to you this Notice of its duties and privacy practices. The Health Plan is required to abide by the terms of this Notice, which may be amended from time to time. The Health Plan reserves the right to change the terms of this Notice and to make the new Notice provisions effective for all health information that it maintains. If the Health Plan changes its policies and procedures, the Health Plan will revise the Notice and will provide a copy of the revised Notice to you within 60 days of the change. You have the right to express complaints to the Health Plan and to the Secretary of the Department of Health and Human Services if you believe that your privacy rights have been violated. Any complaints to the Health Plan should be made in writing to the Health Plan's Privacy Officer at the address below. Any complaints to the Department of Health and Human Services should be send to U.S. Department of Health and Human Services, 200 Independence Avenue, S.W., Washington, D.C. 20201.  The Health Plan encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.

Right to receive notification of breaches.    The Health Plan must notify you within 60 days of discovery of a breach.  A breach occurs if unsecured PHI is acquired, used or disclosed in a manner that is impermissible under the Privacy Rules, unless there is a low probability that the PHI has been compromised.

Contact Person / Privacy Officer

You may write to the Privacy Officer that the Health Plan has dedicated as its contact person for all issues regarding your privacy rights:

HIPAA Privacy Officer 

615 West 131st Street, MC 8703

Studebaker 4th Floor 

New York, NY 10027

(212) 851-7026

hrprivoff@columbla.edu

Additional Information About This Notice

No guarantee of employment  

This Notice does not create any right to employment for any individual, nor does it change Columbia University’s right to discharge any of its employees at any time, with or without cause.

No change to Health Plan benefits This Notice explains your privacy rights as a current or former participant in the Health Plan.  The Health Plan is bound by the terms of this Notice as it relates to the privacy of your PHI.  However, this Notice does not change any other rights or obligations you may have under the Health Plan.  You should refer to the Health Plan documents for additional information regarding your Health Plan benefits.