Skills of Central PA, Inc.

Notice of Privacy Practices and Acknowledgment (Employees)

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 Skills of Central PA, Inc. Benefit Plan (the Benefit Plan) is required by the Health Insurance Portability and Accountability Act of 1996 and its regulations (the law) to maintain the privacy of individually identifiable information about your past, present, or future health or condition (including genetic information), the provision of health care to you, or payment for the health care. This information is considered “Protected Health Information” or “PHI.” The Benefit Plan is also required by the law to maintain the privacy of your PHI and to provide you with notice of its legal duties and privacy practices with respect to PHI. Except in specified circumstances, the Benefit Plan may use or disclose only the minimum necessary PHI to accomplish the purpose of the use or disclosure.

 

The Benefit Plan reserves the right to change the terms of this Notice and to make the new Notice provisions effective for all PHI that it maintains. You will be notified about the changes and the availability of a revised Notice or a revised Notice will be provided to you, at least 60 days prior to the date the new Notice becomes effective.

 

The Benefit Plan is required by law to inform you of (1) the Benefit Plan’s uses and disclosures of your PHI, (2) the Plan’s duties with respect to your PHI, (3) your right to file a complaint with the Benefit Plan and the Secretary of the US Department of Health and Human Services (DHSS) and (4) the person to contact for further information about the Benefit Plan’s privacy practices.

 

Effective Date of This Notice: October 3, 2016

 

How Skills of Central PA, Inc. Benefit Plan May Use or Disclose Your Health Information

The Benefit Plan will use and disclose your PHI as follows:

· At your request, the Benefit plan will give you access to your PHI so that you may look at or copy it. 

· The Benefit plan may be required by the Secretary of DHSS to disclose your PHI in connection with an investigation to determine the Benefit Plan’s compliance with privacy regulations.

· The Benefit Plan and any third party with which Skills of Central PA, Inc. has entered into a contractual relationship may use or disclose your PHI to carry out claims payment activities and healthcare operations. The Benefit Plan will also disclose your PHI to the Benefit Plan Sponsor related to claims payment activities and healthcare operations. The Benefit plan Sponsor has amended its plan documents to protect your PHI as required by law. For example, the Plan or a business associate may tell your physician whether you are eligible for coverage and the limits of your coverage.

· The Benefit Plan may disclose your PHI to the plan sponsor for obtaining premium bids or modifying, amending, or terminating the Benefit Plan, however, the Benefit Plan may disclose only summary health information for this purpose. “Summary Health Information” is information that summarizes claims history, claims expenses, or types of claims experience that is stripped of all individual identifiers other than a five-digit zip code.

· The Benefit Plan may disclose your PHI as required by law, including disclosures about victims of abuse, neglect, or domestic violence (but then must inform you, with certain exceptions, that the disclosure has been made), disclosures for law enforcement purposes, and disclosures for judicial or administrative proceedings.

· The Benefit Plan may disclose your PHI for public health activities for the purpose of preventing or controlling disease, injury, or disability.

· The Benefit Plan may disclose your PHI to a coroner, medical examiner, or a funeral director for the purpose of performing their duties as authorized by law,

· The Benefit Plan may use or disclose your PHI when it believes in good faith that the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public, but only to someone who can prevent or lessen the threat.

· The Benefit Plan may disclose your PHI when authorized by and to the extent necessary to comply with workers’ compensation or other similar programs established by law.

· Except as otherwise indicated in the Notice, the Benefit Plan will disclose your PHI only with your written authorization and subject to your right to revoke that authorization.

 

THE BENEFIT PLAN IS PROHIBITED FROM USING PHI THAT IS GENETIC INFORMATION FOR UNDERWTRITING PURPOSES. Genetic information includes information about your genetic tests, the genetic tests of your family members, the manifestation of a disease or disorder in your family or any request for or receipt of genetic services or participation in clinical research by you or a family member.

 

Duties of the Skills of Central PA, Inc. Benefit Plan with respect to Use and Disclosure of your PHI

The Benefit Plan will use and disclose, and request disclosure of, only the minimum amount of PHI about you as needed under the circumstances, taking into consideration any practical and technological limitations. This requirement does not apply when disclosing information to a provider for treatment, when disclosing information to you at your request, when disclosing information to the Secretary of the DHHS, or when disclosing information that is required by law or regulations. The Notice does not apply to information that does not identify you, or for which there is no reason to believe that it can be used to identify you.

 

Duty of the Skills of Central PA, Inc. Benefit Plan to Notify you in the Event of a Breach

In the event that the Benefit Plan’s PHI is unsecured based on standards set by the DHHS, the Benefit Plan will notify you within 60 days of the date of discovery of any breach of your PHI or the date that there is reason to believe that there has been a breach of your PHI. A breach does not include a disclosure where there is a low probability that the PHI has been compromised. The Benefit Plan will determine this based on the following factors: (1) the nature and extent of the PHI involved including the possibility of re-identification; (2) the unauthorized person who used the PHI or to whom the disclosure was made; (3) whether the PHI was actually acquired or viewed; and (4) the extent to which the risk to the PHI was mitigated. The notice will include the circumstances of the breach, the date of the breach, the date of discovery of the breach, the type of information involved, steps you should take to protect yourself, steps that the Benefit Plan is taking to mitigate the harm and protect against future breaches.

 

Your Rights

The law provides you with the following rights with respect to your PHI that the Benefit Plan and its business associates or subcontractors maintain:

· Right to Request Restrictions – you have the right to request restrictions on our use and disclosure of your PHI. You may request that we limit disclosure of your PHI only for our payment or healthcare operations and to certain individuals. However, we are not required to agree to your request. We will accommodate reasonable requests to receive communications by alternative means or at alternative locations.

· Right to Inspect and Copy – You have the right to inspect and copy the PHI that the Benefit Plan maintains or receive an electronic copy of that information in the Benefit Plan maintains it in an electronic format. The requested information will be provided within 30 days if the information is maintained on site or within 60 days if it is maintained off site. We may request a 30-day extension of this time frame, but will notify you if we elect the extension and will provide you with the reason. If we deny you access to your PHI, we will provide you with a written denial, which will include the reason for the denial along with other relevant information.

· Right to Request Amendment – You have the right to request that we amend your PHI. We will respond within 60 days of receiving your request to amend. We may request an additional 30-day extension, but if we do this, we will explain our reasons. If we deny your request to amend, we will provide you with a written denial that clearly explains why your request was denied. You will then include your statement with the PHI that is the subject of your request.

· Right to Receive an Accounting – You have the right to receive a list of our disclosures of your PHI, except for those disclosures that are made in connection with claims payment or our health care operations. We will also not include and disclosures we have made to you or at your request, or any disclosures made prior to April 14, 2004. WE will provide you with the list within 60 days after we receive your request, except that we may request a 30-day extension. If you request more than one (1) accounting within a 12-month period, we will charge you a reasonable fee for each subsequent request.

 

In order to exercise any of these rights, you will be required to complete a form that we will provide to you upon request. All requests should be made to the individual shown at the end of this notice. 

 

Complaints

If you feel that your privacy rights as described in this Notice have been violated, you may complain to the Benefit Plan as described under Contact Information, below. You may also file a complaint with the Department of Health and Human Services, Office for Civil Rights, 150 South Independence Mall West, Suite 372, Philadelphia, PA 19106-3499. The Benefit Plan will not discriminate against you for filing a complaint. 

 

If you have questions about any part of this notice or if you want more information about the privacy practices at Skills of Central PA, Inc., please contact:

Andrew Bollinger                                                   Chris Coho

Privacy Officer                                                        Security Officer

341 Science Park Road, Suite 6                           341 Science Park Road, Suite 6

State College, PA 16803                                        State College, PA 16803

814-238-3245, ext. 1123                                       814-238-3245, ext. 1108

 

Notice of Privacy Practices Acknowledgement

Skills of Central PA, Inc.

341 Science Park Road, Suite 6

State College, PA 16803 

 

I hereby acknowledge that I received a copy of Skills of Central PA, Inc. Notice of Privacy Practices.

Printed Name of Employee:  

Employee Signature:    

Date:    

 

For Office Use Only

We attempted to obtain written acknowledgement of receipt of our Notice of Privacy Practices but acknowledgement could not be received because: 

[] Acknowledgement refused

Reasons for refusal:    

[] An emergency situation prevented us from obtaining acknowledgement

Emergency situation:    

[] Other (please specify):