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Notice of Privacy Practices

THIS NOTICE DESCRIBES HOW PROTECTED HEALTH INFORMATION THAT IS ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.

Health Alliance Plan
Alliance Health and Life Insurance Company
HAP Empowered Health Plan, Inc.
Last Review: October 2015

Your Protected Health Information (PHI)

PHI stands for the words “Protected Health Information.” PHI is information about you, such as your name, demographic data and member ID number that can reasonably be used to identify you. This information relates to your past, present or future physical or mental health, the provision of health care to you or the payment for that care. Our policies cover protection of your PHI whether it’s oral, written or electronic.

Important information about privacy

Safeguarding the privacy of your PHI is important to HAP. We’re required by law to protect the privacy of your PHI and to provide you with notice of our legal duties and privacy practices. That’s what this notice is for. It explains how we use information about you and when we can share that information with others. It also tells you about your rights with respect to your PHI and how you can use your rights. We’re required to comply with the terms set out in this notice.

When we use the term "HAP," "we" or "us" in this notice, we’re referring to Health Alliance Plan and its subsidiaries, including Alliance Health and Life Insurance Company and HAP Empowered Health Plan, Inc.

How we protect your PHI

We protect your PHI, whether it’s written, spoken or in electronic form, by requiring employees and others who handle your information to follow specific confidentiality and technology usage policies. When they begin working for HAP, all employees and contractors must acknowledge that they have reviewed HAP's policies and that they will protect your PHI even after they leave HAP. An employee or contractor's use of protected information is limited to the minimum amount of information necessary to perform a legitimate job function. Employees and contractors are also required to comply with this privacy notice and may not use or disclose your information except as described in this notice.

Using and disclosing PHI

These next sections describe how HAP uses and shares your health information. Keep in mind that we share your information only with those who have a "need to know" in order to perform these tasks:

Treatment

We may share your PHI with your doctors, hospitals or other providers to help them provide medical care to you. For example, if you’re in the hospital, we may give them access to any medical records sent to us by your doctor.

We may use or share your PHI with others to help manage your health care. For example, we might talk to your doctor to suggest a disease management or wellness program that could help improve your health.

Payment

We may use or share your PHI to help us determine who is financially responsible for your medical bills. We may also use or share your PHI to conduct other payment activities, such as obtaining premium payments and determining eligibility for benefits and coordinating benefits with other insurance you may have.

Operations

We share your PHI with affiliated companies as permitted by law, non-affiliated third parties with whom we contract to help us operate HAP and with others who are involved in providing or paying for your health care services. We may also share your information with others who help us conduct our business operations. If we do so, we will require these persons or entities to protect the privacy and security of your information and to return or destroy such information when it’s no longer needed for our business operations.

Here are examples of business activities undertaken by HAP:

We may also disclose your PHI to other providers and health plans that have a relationship with you for certain health care operations. For example, we may disclose your PHI for their quality assessment and improvement activities or for health care fraud and abuse detection.

Other uses and disclosures that are permitted or required

HAP may also use or release your PHI:

We must obtain your written permission to use or disclose your PHI if one of these reasons doesn’t apply. If you give us written permission, then change your mind, you may cancel your written permission at any time. Cancellation of your permission will not apply to any information we’ve already disclosed. We may ask you to complete a form when you make a request.

Other uses and disclosures of PHI Organized Health Care Arrangement

HAP and its affiliates covered by this Notice of Privacy Practices participate together with the Henry Ford Health System and its listed affiliates in an organized health care arrangement to improve the quality and efficient delivery of your health care and to participate in applicable quality measure programs, such as HEDIS.

The entities that comprise the HFHS OHCA are:

The HFHS Organized Health Care Arrangement permits these separate legal entities, including HAP and its affiliates, to share PHI with each other as necessary to carry out permissible treatment, payment or health care operations relating to the organized health care arrangement unless otherwise limited by law, rule or regulation. This list of entities may be updated to apply to new entities in the future. You can access the most current list at hap.org/privacy or call us at (800) 422-4641 to ask for a list. When required we’ll provide you with appropriate notice of such purchase or affiliation in a revised Notice of Privacy Practices.

Your rights

These are your rights with respect to your member information. If you would like to exercise any of these rights, contact us as described below under "Who to Contact."

Your request to exercise any of these member rights must be in writing and it must be signed by you or your representative. We may ask you to complete a form when making a request.

Changes to this privacy statement

We reserve the right to make periodic changes to the contents of this notice. If we do make changes, the new notice will be effective for all PHI maintained by us. Once we make our revisions, we’ll provide the new notice to you by mail and post it on our website.

Who to contact

If you have any questions about this notice or about how we use or share member information, contact the HAP and HAP Empowered Health Plan Office of Compliance by mail at:

Health Alliance Plan
Attn: Office of Compliance
2850 West Grand Boulevard
Detroit, MI 48202

You may also call us at (800) 422-4641 (TTY: 711).

Complaints

If you believe your privacy rights have been violated, you may file a complaint with us by contacting the Office of Compliance or by filing a grievance with our Customer Service department. You may also notify the secretary of the U.S. Department of Health and Human Services of your complaint. We will not take any action against you for filing a complaint.

Original effective date: April 13, 2003

Revisions: February 2005, November 2007, September 2013, September 2014, March 2015, October 2015

Reviewed: November 2008, November 2009, October 2011