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HIPAA Policy

Notice of Privacy Practice

This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

The Mission of the Prentke Romich Company is:

PRC also is an employer and provider of health benefits. Through these activities PRC collects, uses, and discloses personal health information to carry out its mission. This information is private and confidential. There are policies and procedures in place to protect the information against unlawful use and disclosure. The notice also provides you with other important information, including how to contact us with questions about this notice or our privacy practices.

What is this notice?

This notice describes information we collect, how we use that information, and when and to whom we may disclose it.

What is "personal health information"?

Personal health information or "PHI" (also called "protected health information"), is current, past or future information created or received by PRC through its health care providers, health plans and contractors. It relates to the physical or mental condition of a patient or plan member, the provision of health care to that person, or payment for the provision of health care to that person. The term PHI does not generally include publicly available information, or information available or reported in a summarized or grouped manner.

What types of personal health information does PRC collect?

PRC collects PHI through interactions with your health care providers. It can be obtained through applications, interviews, surveys, and other forms. PHI may be obtained in writing, in person, by telephone, and electronically. The information we collect varies depending on who collects it and why, but generally includes information about your relationship and transactions with our affiliates, our agents, and us.

Examples include:

How does PRC protect personal health information internally?

Access to PHI is restricted to only those employees who need it to provide services, products, or benefits to our patients, employees, health plan members, and their dependents. We maintain physical, technical, and procedural safeguards to protect PHI against unauthorized use and disclosure. We have a Privacy Officer who is responsible for developing, educating PRC personnel about, and overseeing the implementation and enforcement of policies and procedures designed to safeguard PHI against inappropriate use and disclosure consistent with the applicable law.

What personal health information does PRC and other health care providers, employers and health plans use or disclose to third parties, and for what purposes?

When necessary for a patient's care or treatment, the operation of an Employee Plan or for other related activities, we use PHI internally and disclose it to health care providers (doctors, dentists, psychologists, pharmacies, hospitals, and other caregivers), insurers, third party administrators, plan sponsors, and other payors (employers, health care provider organizations, and others who may be responsible for paying for or administering your health benefits); vendors, consultants, government authorities; and their respective agents. They are required by law to keep PHI confidential. PRC maintains a Minimum Necessary Disclosure Policy, which limits the disclosure of PHI to the minimum amount necessary to accomplish the stated purpose. Some examples of what we do with the information we collect and the reasons it might be disclosed to third parties are described below.

Treatment, Payment, and Health Care Operations

We may use or disclose PHI with or without your consent to provide health care services or administer our health benefits plans. Examples of these uses and disclosures include:

Other Activities Permitted or Required by Law

We may use or disclose PHI for other important activities permitted or required by law, with or without your authorization. These include:

Our use and disclosure of PHI must comply not only with federal privacy regulations but also with applicable Ohio law. Ohio law provides different and sometimes more stringent protections to PHI than federal regulations. Examples of these protections include: (i) special protections for sensitive information, such as information about HIV/AIDS, treatment for psychiatric conditions or substance abuse problems, and certain genetic information; (ii) a bar against redisclosure of PHI collected by third party administrators of health plans for certain purposes; and (iii) a prohibition against making changes to medical records that would conceal or alter prior entries (even if inaccurate).

Why is it important that personal health information be used and disclosed as described above?

The activities described above are necessary to effectively provide equipment to customers and to operate, employee benefits and health plans.

What does a person need to do to request other disclosures of personal health information?

Many patients and health plan members ask us to disclose PHI to people in ways not described above. For example, an adult person with a disability may want us to make her records available to a neighbor who is helping her resolve a question about her care or payment for that care. Contact information to authorize us to disclose your personal health information to a person or organization or for reasons other than those described in Section V above is attached.

If you fill out a form and later change your mind about the special authorization, you may send a letter to us at the address listed on the form to let us know that you would like to revoke the special authorization. In any communication with us, please provide your name, address, patient or member identification number or Social Security number, and a telephone number where we can reach you in case we need to contact you about your request.

What other rights does a person have with respect to personal health information, and how can the person exercise those rights?

You have a right to ask us in writing to restrict use or disclosure of your PHI related to your treatment, related to your payment or related to routine health care facility operations. In addition, you may request PHI disclosure restrictions to family members, advocates or others involved in your care. We are not required to agree to such a restriction, but if we do agree, we will honor our agreement except in case of an emergency. Any restriction we agree to is not effective to prevent uses or disclosures of PHI (i) required by the Secretary of the Department of Health and Human Services to investigate or determine our compliance with federal privacy regulations adopted under the Health Insurance Portability and Accountability Act of 1996; (ii) for health facility directories (e.g., a roster of patients staying at a hospital); or (iii) for certain activities permitted or required by law (see Section V above).

You have a right to review and obtain a copy of existing PHI contained in (i) medical and billing records about you maintained by PRC; (ii) enrollment, payment, claims adjudication and case or medical management record systems maintained by or for the Employee Plans and (iii) records used by or for PRC to make decisions about you. You must make your request in writing and this right is limited to existing records that are maintained, collected, used or disseminated by PRC. It does not apply to information we compile in reasonable anticipation of, or for use in, civil, criminal or administrative actions or proceedings. We may charge a fee for any copies you request.

You have a right to request that we amend the records described above for as long as we maintain them. You must make the request in writing and give us a reason for the amendment. We may deny your request if: (i) we determine that we did not create the record, unless the originator of the PHI is no longer available to act on the requested amendment; or (ii) if we believe that the existing records are accurate and complete. Note that an amendment may take several forms, for example, we may add an explanatory statement to a record rather than change it.

You have a right to receive an accounting of disclosures made by PRC to any third party in the six years prior to the date on which the accounting is requested. This right does not apply to certain disclosures, including, but not limited to, disclosures made for the purposes of treatment, payment, or health care operations; disclosures made to you or to others involved in your care; disclosures made with your authorization; disclosures made for national security or intelligence purposes or to correctional institutions, or law enforcement purposes; or disclosures made prior to April 14, 2003. You must make any request for an accounting in writing. We may charge a fee to fill more than one request in any given year.

You have the right to request that we communicate with you about medical matters in a certain way or at a certain location. For example, you can ask that we only contact you at work or by mail. To request confidential communications, you must make your request in writing. We will not ask you the reason for your request. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

What does PRC plan to do with personal health information about patients, employees, and health plan members who are no longer affiliated with PRC?

PRC does not necessarily destroy PHI when individuals terminate their relationships with us. The information is necessary and used for many of the purposes described in Section V, even after the person stops receiving treatment or benefits through PRC, or terminates employment with us. In many cases, the information is subject to legal retention requirements.However, the policies and procedures that protect all PHI against inappropriate use and disclosure apply regardless of the status of any individual whose information is maintained.

How is this notice distributed and updated?

PRC posts this notice on our internet site at http://www.prentrom.com/hipaa and distributes this notice:

We reserve the right to change the terms of this notice. Any changes will be effective for all personal health information that we maintain.

What more do I need to know about my privacy rights?

PRC is required by law to maintain the privacy of personal health information and to provide individuals with notice of its legal duties and privacy practices with respect to that information. We are required to abide by the terms of the notice currently in effect.

What should I do if I want a paper copy of this notice, if I have questions about it, or if I think my privacy rights have been violated?

If you would like a paper copy of this notice, have questions about it, or believe its terms or any PRC privacy or confidentiality policy has been violated with respect to information about you, please let us know immediately. If you wish to file a complaint, you can write to us at the PRC Privacy Office listed below. You will not be penalized for filing a complaint.

PRC Privacy Officer
1022 Heyl Rd.
Wooster, OH 44691
800.262.1984

Please include your name, address, and a telephone number where we can contact you, and a brief description of your concern. If you prefer, you may lodge an anonymous complaint. You also may contact the Secretary of the Department of Health and Human Services at:

The U.S. Department of Health and Human Services
200 Independence Avenue, S.W.
Washington, D.C. 20201
202.619.0257
Toll Free: 877.696.6775

Please provide as much information as possible so that the complaint can be properly investigated. PRC will not retaliate against a person who files a complaint with us or with the Secretary of the Department of Health and Human Services.