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.
Background:
The Health Insurance Portability and Accountability Act
of 1996 (HIPAA) requires health plans to notify plan
participants and beneficiaries about its policies and
practices to protect the confidentiality of their health
information. This document is intended to satisfy
HIPAA's notice requirement with respect to all health
information created, received, or maintained by the
Virginia United Methodist Pensions, Inc. group health
plan (the “Plan”), as sponsored by the Virginia United
Methodist Conference (the "Conference").
The Plan needs to create, receive, and maintain records
that contain health information about you to administer
the Plan and provide you with health care benefits.
This notice describes the Plan’s health information
privacy policy with respect to your:Medical,
Dental, Long Term Care, and/or Health Care Flexible
Spending Account (FSA) benefits. The notice tells you
the ways the Plan may use and disclose health
information about you, describes your rights, and the
obligations the Plan has regarding the use and
disclosure of your health information. However, it does
not address the health information policies or practices
of your health care providers.
Virginia United Methodist Pensions, Inc.’s Pledge
Regarding Health Information Privacy
The privacy policy and practices of the Plan protects
confidential health information that identifies you or
could be used to identify you and relates to a physical
or mental health condition or the payment of your health
care expenses. This individually identifiable health
information is known as “protected health information”
(PHI). Your PHI will not be used or disclosed without a
written authorization from you, except as described in
this notice or as otherwise permitted by federal and
state health information privacy laws.
Privacy Obligations of the Plan
The Plan is required by law to:
• make sure that health information that identifies
you is kept private;
• give you this notice of the Plan’s legal duties and
privacy practices with respect to health information
about you; and
• follow the terms of the notice that is currently in
effect.
How the Plan May Use and Disclose Health Information
About You
The following are the different ways the Plan may use
and disclose your PHI:
• For Treatment. The Plan may disclose your
PHI to a health care provider who renders treatment on
your behalf. For example, if you are unable to provide
your medical history as the result of an accident, the
Plan may advise an emergency room physician about the
types of prescription drugs you currently take.
• For Payment. The Plan may use and disclose
your PHI so claims for health care treatment, services,
and supplies you receive from health care providers may
be paid according to the Plan's terms. For example, the
Plan may receive and maintain information about surgery
you received to enable the Plan to process a hospital’s
claim for reimbursement of surgical expenses incurred on
your behalf.
• For Health Care Operations. The Plan may
use and disclose your PHI to enable it to operate or
operate more efficiently or make certain all of the
Plan’s participants receive their health benefits. For
example, the Plan may use your PHI for case management
or to perform population-based studies designed to
reduce health care costs. In addition, the Plan may use
or disclose your PHI to conduct compliance reviews,
audits, actuarial studies, and/or for fraud and abuse
detection. The Plan may also combine health information
about many Plan participants and disclose it to the
Conference in summary fashion so it can decide what
coverages the Plan should provide. The Plan may remove
information that identifies you from health information
disclosed to the Conference so it may be used without
the Conference learning who the specific participants
are.
• To the Conference. The Plan may disclose
your PHI to designated Conference personnel so they can
carry out their Plan-related administrative functions,
including the uses and disclosures described in this
notice. Such disclosures will be made only to the
Conference’s Benefits Administrator ("the Plan
Administrator") and/or the members of the Conference’s
Benefits Department. These individuals will protect the
privacy of your health information and ensure it is used
only as described in this notice or as permitted by
law. Unless authorized by you in writing, your health
information: (1) may not be disclosed by the Plan to any
other Conference employee or department and (2) will not
be used by the Conference for any employment-related
actions and decisions or in connection with any other
employee benefit plan sponsored by the Conference.
• To a Business Associate. Certain services
are provided to the Plan by third party administrators
known as "business associates." For example, the Plan
may input information about your health care treatment
into an electronic claims processing system maintained
by the Plan's business associate so your claim may be
paid. In so doing, the Plan will disclose your PHI to
its business associate so it can perform its claims
payment function. However, the Plan will require its
business associates, through contract, to appropriately
safeguard your health information.
• Treatment Alternatives. The Plan may use
and disclose your PHI to tell you about possible
treatment options or alternatives that may be of
interest to you.
• Health-Related Benefits and Services. The
Plan may use and disclose your PHI to tell you about
health-related benefits or services that may be of
interest to you.
• Individual Involved in Your Care or Payment of
Your Care. The Plan may disclose PHI to a close
friend or family member involved in or who helps pay for
your health care. The Plan may also advise a family
member or close friend about your condition, your
location (for example, that you are in the hospital), or
death.
• As Required by Law. The Plan will disclose
your PHI when required to do so by federal, state, or
local law, including those that require the reporting of
certain types of wounds or physical injuries.
Special Use and Disclosure Situations
The Plan may also use or disclose your PHI under the
following circumstances:
• Lawsuits and Disputes. If you become
involved in a lawsuit or other legal action, the Plan
may disclose your PHI in response to a court or
administrative order, a subpoena, warrant, discovery
request, or other lawful due process.
• Law Enforcement. The Plan may release your
PHI if asked to do so by a law enforcement official, for
example, to identify or locate a suspect, material
witness, or missing person or to report a crime, the
crime's location or victims, or the identity,
description, or location of the person who committed the
crime.
• Workers’ Compensation. The Plan may
disclose your PHI to the extent authorized by and to the
extent necessary to comply with workers' compensation
laws other similar programs.
• Military and Veterans. If you are or become
a member of the U.S. armed forces, the Plan may release
medical information about you as deemed necessary by
military command authorities.
• To Avert Serious Threat to Health or Safety.
The Plan may use and disclose your PHI when necessary to
prevent a serious threat to your health and safety, or
the health and safety of the public or another person.
• Public Health Risks. The Plan may disclose
health information about you for public health
activities. These activities include preventing or
controlling disease, injury or disability; reporting
births and deaths; reporting child abuse or neglect; or
reporting reactions to medication or problems with
medical products or to notify people of recalls of
products they have been using.
• Health Oversight Activities. The Plan may
disclose your PHI to a health oversight agency for
audits, investigations, inspections, and licensure
necessary for the government to monitor the health care
system and government programs.
• Research. Under certain circumstances, the
Plan may use and disclose your PHI for medical research
purposes.
• National Security, Intelligence Activities, &
Protective Services. The Plan may release your PHI
to authorized federal officials: (1) for intelligence,
counterintelligence, and other national security
activities authorized by law and (2) to enable them to
provide protection to the members of the U.S. government
or foreign heads of state, or to conduct special
investigations.
• Organ and Tissue Donation. If you are an
organ donor, the Plan may release medical information to
organizations that handle organ procurement or organ,
eye, or tissue transplantation or to an organ donation
bank to facilitate organ or tissue donation and
transplantation.
• Coroners, Medical Examiners, and Funerals
Directors. The Plan may release your PHI to a
coroner or medical examiner. This may be necessary, for
example, to identify a deceased person or to determine
the cause of death. The Plan may also release your PHI
to a funeral director, as necessary, to carry out
his/her duty.
Your Rights Regarding Health Information About You
Your rights regarding the health information the Plan
maintains about you are as follows:
• Right to Inspect and Copy. You have the
right to inspect and copy your PHI. This includes
information about your plan eligibility, claim and
appeal records, and billing records, but does not
include psychotherapy notes.
To inspect and copy health information maintained by the
Plan, submit your request in writing to the Plan
Administrator. The Plan may charge a fee for the cost
of copying and/or mailing your request. In limited
circumstances, the Plan may deny your request to inspect
and copy your PHI. Generally, if you are denied access
to health information, you may request a review of the
denial.
• Right to Amend. If you feel that health
information the Plan has about you is incorrect or
incomplete, you may ask the Plan to amend it. You have
the right to request an amendment for as long as the
information is kept by or for the Plan.
To request an amendment, send a detailed request in
writing to the Plan Administrator. You must provide the
reason(s) to support your request. The Plan may deny
your request if you ask the Plan to amend health
information that was: accurate and complete, not
created by the Plan; not part of the health information
kept by or for the Plan; or not information that you
would be permitted to inspect and copy.
• Right to An Accounting of Disclosures. You
have the right to request an “accounting of
disclosures.” This is a list of disclosures of your PHI
that the Plan has made to others, except for those
necessary to carry out health care treatment, payment,
or operations; disclosures made to you; or in certain
other situations.
To request an accounting of disclosures, submit your
request in writing to the Plan Administrator. Your
request must state a time period, which may not be
longer than six years prior to the date the accounting
was requested.
• Right to Request Restrictions. You have the
right to request a restriction on the health information
the Plan uses or disclosures about you for treatment,
payment, or health care operations. You also have the
right to request a limit on the health information the
Plan discloses about you to someone who is involved in
your care or the payment for your care, like a family
member or friend. For example, you could ask that the
Plan not use or disclose information about a surgery you
had.
To request restrictions, make your request in writing to
the Plan Administrator. You must advise us: (1) what
information you want to limit; (2) whether you want to
limit the Plan’s use, disclosure, or both; and (3) to
whom you want the limit(s) to apply.
Note:The Plan is not required to agree to your request.
• Right to Request Confidential Communications.
You have the right to request that the Plan communicate
with you about health matters in a certain way or at a
certain location. For example, you can ask that the
Plan send you explanation of benefits (EOB) forms about
your benefit claims to a specified address.
To request confidential communications, make your
request in writing to the Plan Administrator. The Plan
will make every attempt to accommodate all reasonable
requests. Your request must specify how or where you
wish to be contacted.
• Right to a Paper Copy of this Notice. You
have the right to a paper copy of this notice. You may
write to the Plan Administrator to request a written
copy of this notice at any time.
Changes to this Notice
The Plan reserves the right to change this notice at any
time and to make the revised or changed notice effective
for health information the Plan already has about you,
as well as any information the Plan receives in the
future. The Plan will post a copy of the current notice
in the Conference’s Benefits Office at all times.
Complaints
If you believe your privacy rights under this policy
have been violated, you may file a written complaint
with the Plan Administrator at the address listed
below. Alternatively, you may complain to the Secretary
of the U.S. Department of Health and Human Services,
generally, within 180 days of when the act or omission
complained of occurred.
Note:
You will not be penalized or retaliated against for
filing a complaint.
Other Uses and Disclosures of Health Information
Other uses and disclosures of health information not
covered by this notice or by the laws that apply to the
Plan will be made only with your written authorization.
If you authorize the Plan to use or disclose your PHI,
you may revoke the authorization, in writing, at any
time. If you revoke your authorization, the Plan will
no longer use or disclosure your PHI for the reasons
covered by your written authorization; however, the Plan
will not reverse any uses or disclosures already made in
reliance on your prior authorization.
Contact Information
If you have any questions about this notice, please
contact:
Virginia United Methodist Pensions, Inc.
10330 Staples Mill Road
Glen Allen, VA 23060
(800) 768-6040