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NOTICE OF PRIVACY - COALITION AMERICA, INC.
As Required by the Privacy Regulations Created as a Result of the
Health Insurance Portability and Accountability Act of 1996 (HIPAA)
THIS NOTICE DESCRIBES HOW HEALTH
INFORMATION MAY BE USED AND DISCLOSED, AND
HOW YOU CAN GET ACCESS TO YOUR INDIVIDUALLY
IDENTIFIABLE HEALTH INFORMATION. PLEASE REVIEW
THIS NOTICE CAREFULLY.
A. OUR COMMITMENT TO YOUR PRIVACY
Coalition America is dedicated to maintaining the privacy
of your protected health information (PHI). In conducting our business,
we will create records regarding you and the treatment and services
we provide to you. We are required by law to maintain the confidentiality
of health information that identifies you. We also are required
by law to provide you with this notice of our legal duties and the
privacy practices that we maintain in Coalition America concerning
your PHI. By federal and state law, we must follow the terms of
the notice of privacy that we have in effect at the time.
We realize that these laws are complicated, but we must provide
you with the following important information:
- How we may use and disclose your PHI
- Your privacy rights in your PHI
- Our obligations concerning the use and disclosure of your PHI
The terms of this notice apply to all records containing your
PHI that are created or retained by Coalition America. We reserve
the right to revise or amend this Notice of Privacy. Any revision
or amendment to this notice will be effective for all of your records
that Coalition America has created or maintained in the past, and
for any of your records that we may create or maintain in the future.
Coalition America will post a copy of our current Notice in our
office in a visible location at all times, and you may request
a copy of our most current Notice at any time.
B. IF YOU HAVE QUESTIONS ABOUT THIS NOTICE, PLEASE CONTACT:
C. WE MAY USE AND DISCLOSE YOUR INDIVIDUALLY IDENTIFIABLE HEALTH
INFORMATION (PHI) IN THE FOLLOWING WAYS
The following categories describe the different ways in which we
may use and disclose your PHI.
1. Payment. Coalition America may use and disclose your PHI
in order to bill and collect payment for the services and items
received. For example, we may contact your health insurer to certify
that you are eligible for benefits (and for what range of benefits),
and we may provide your insurer with details regarding your treatment
to determine if your insurer will cover, or pay for, your treatment.
We also may use and disclose your PHI to obtain payment from third
parties that may be responsible for such costs, such as family members.
Also, we may use your PHI to bill you directly for services and
2. Health Care Operations. Coalition America may use and
disclose your PHI to operate our business. As examples of the ways
in which we may use and disclose your information for our operations,
Coalition America may use your PHI to evaluate the quality of care
you received from us, or to conduct cost-management and business
planning activities for Coalition America.
3. Appointment Reminders. Coalition America may use and disclose
your PHI to contact you and remind you of an appointment.
4. Treatment Options. Coalition America may use and disclose
your PHI to inform you of potential treatment options or alternatives.
5. Health-Related Benefits and Services. Coalition America
may use and disclose your PHI to inform you of health-related benefits
or services that may be of interest to you.
6. Release of Information to Family/Friends. Coalition America
may release your PHI to a friend or family member that is involved
in your care, or who assists in taking care of you. For example,
a parent or guardian may ask that a baby-sitter take their child
to the pediatrician's office for treatment of a cold. In this example,
the baby-sitter may have access to this child's medical information.
7. Disclosures Required By Law. Coalition America will use
and disclose your PHI when we are required to do so by federal,
state or local law.
D. USE AND DISCLOSURE OF YOUR PHI IN CERTAIN SPECIAL
The following categories describe unique scenarios in which we may
use or disclose your identifiable health information:
1. Public Health Risks. Coalition America may disclose your
PHI to public health authorities that are authorized by law to collect
information for the purpose of:
- maintaining vital records, such as births and deaths
- reporting child abuse or neglect
- preventing or controlling disease, injury or disability
- notifying a person regarding potential exposure to a communicable
- notifying a person regarding a potential risk for spreading
or contracting a disease or condition
- reporting reactions to drugs or problems with products or devices
- notifying individuals if a product or device they may be using
has been recalled
- notifying appropriate government agency (ies) and authority
(ies) regarding the potential abuse or neglect of an adult patient
(including domestic violence); however, we will only disclose
this information if the patient agrees or we are required or authorized
by law to disclose this information
- notifying your employer under limited circumstances related
primarily to workplace injury or illness or medical surveillance
2. Health Oversight Activities. Coalition America may disclose
your PHI to a health oversight agency for activities authorized
by law. Oversight activities can include, for example, investigations,
inspections, audits, surveys, licensure and disciplinary actions;
civil, administrative, and criminal procedures or actions; or other
activities necessary for the government to monitor government programs,
compliance with civil rights laws and the health care system in
3. Lawsuits and Similar Proceedings. Coalition America may
use and disclose your PHI in response to a court or administrative
order, if you are involved in a lawsuit or similar proceeding.
We also may disclose your PHI in response to a discovery request,
subpoena, or other lawful process by another party involved in the
dispute, but only if we have made an effort to inform you of the
request or to obtain an order protecting the information the party
4. Law Enforcement. We may release PHI if asked to do so
by a law enforcement official:
- Regarding a crime victim in certain situations, if we are unable
to obtain the person's agreement
- Concerning a death we believe has resulted from criminal conduct
- Regarding criminal conduct at our offices
- In response to a warrant, summons, court order, subpoena or
similar legal process
- To identify/locate a suspect, material witness, fugitive or
- In an emergency, to report a crime (including the location or
victim(s) of the crime, or the description, identity or location
of the perpetrator)
5. Serious Threats to Health or Safety. Coalition America
may use and disclose your PHI when necessary to reduce or prevent
a serious threat to your health and safety or the health and safety
of another individual or the public. Under these circumstances,
we will only make disclosures to a person or organization able to
help prevent the threat.
6. Military. Coalition America may disclose your PHI if you
are a member of U.S. or foreign military forces (including veterans)
and if required by the appropriate authorities.
7. National Security. Coalition America may disclose your
PHI to federal officials for intelligence and national security
activities authorized by law. We also may disclose your PHI to federal
officials in order to protect the President, other officials or
foreign heads of state, or to conduct investigations.
8. Inmates. Coalition America may disclose your PHI to correctional
institutions or law enforcement officials if you are an inmate or
under the custody of a law enforcement official. Disclosure for
these purposes would be necessary: (a) for the institution to provide
health care services to you, (b) for the safety and security of
the institution, and/or (c) to protect your health and safety or
the health and safety of other individuals.
9. Workers' Compensation. Coalition America may release your
PHI for workers' compensation and similar programs.
E. YOUR RIGHTS REGARDING YOUR PHI
You have the following rights regarding the PHI that we maintain
1. Confidential Communications. You have the right to request
that Coalition America communicate with you about your health and
related issues in a particular manner or at a certain location.
In order to request a type of confidential communication, you must
make a written request to Coalition America
specifying the requested method of contact, or the location where
you wish to be contacted. Coalition America will accommodate
reasonable requests. You do not need to
give a reason for your request.
2. Requesting Restrictions. You have the right to request
a restriction in our use or disclosure of your PHI for treatment,
payment or health care operations. Additionally, you have the right
to request that we restrict our disclosure of your PHI to only certain
individuals involved in your care or the payment for your care,
such as family members and friends. We are not required to agree
to your request; however, if we do agree, we are bound by our
agreement except when otherwise required by law, in emergencies,
or when the information is necessary to treat you. In order to request
a restriction in our use or disclosure of your PHI, you must make
your request in writing to Coalition America.
Your request must describe in a clear and concise fashion:
- the information you wish restricted
- whether you are requesting to limit Coalition America use, disclosure
or both and
- to whom you want the limits to apply
3. Inspection and Copies. You have the right to inspect
and obtain a copy of the PHI that may be used to make decisions
about you, including patient medical records and billing records,
but not including psychotherapy notes. You must submit your request
in writing to Coalition America in order to inspect
and/or obtain a copy of your PHI.
Coalition America, Inc. may charge a fee for the costs of copying,
mailing, labor and supplies associated with your request. Coalition
America may deny your request to inspect and/or copy in certain
limited circumstances; however, you may request a review of our
denial. Another licensed health care professional chosen by us will
4. Amendment. You may ask us to amend your health information
if you believe it is incorrect or incomplete, and you may request
an amendment for as long as the information is kept by or for Coalition
America. To request an amendment, your request must be made in writing
and submitted to Coalition America.
You must provide us with a reason that supports your
request for amendment. Coalition America will deny your request
if you fail to submit your request (and the reason supporting your
request) in writing. Also, we may deny your request if you ask us
to amend information that is in our opinion: (a) accurate and complete;
(b) not part of the PHI kept by or for Coalition America; (c) not
part of the PHI which you would be permitted to inspect and copy;
or (d) not created by Coalition America, unless the individual or
entity that created the information is not available to amend the
5. Accounting of Disclosures. All of our patients have the
right to request an accounting of disclosures. An accounting of
disclosures is a list of certain non-routine disclosures Coalition
America has made of your PHI for non-treatment or operations purposes.
Use of your PHI as part of the routine patient care in Coalition
America is not required to be documented. For example, the doctor
sharing information with the nurse; or the billing department using
your information to file your insurance claim. In order to obtain
an accounting of disclosures, you must submit your request in writing.
All requests for an accounting of disclosures must state a time
period, which may not be longer than six (6) years from the date
of disclosure and may not include dates before April 14, 2003. The
first list you request within a 12-month period is free of charge,
but Coalition America may charge you for additional lists within
the same 12-month period. Coalition America will notify you of the
costs involved with additional requests, and you may withdraw your
request before you incur any costs.
6. Right to a Paper Copy of This Notice. You are entitled
to receive a paper copy of our notice of privacy Coalition America.
You may ask us to give you a copy of this notice at any time. To
obtain a paper copy of this notice, contact Coalition America.
7. Right to File a Complaint. If you believe your privacy
rights have been violated, you may file a complaint with Coalition
America or with the Secretary of the Department of Health and Human
Services. To file a complaint with Coalition America, contact
Coalition America . All complaints
must be submitted in writing. You will not be penalized for filing
8. Right to Provide an Authorization for Other Uses and Disclosures.
Coalition America will obtain your written authorization for
uses and disclosures that are not identified by this notice or permitted
by applicable law. Any authorization you provide to us regarding
the use and disclosure of your PHI may be revoked at any time in
writing. After you revoke your authorization, we will no longer
use or disclose your PHI for the reasons described in the authorization.
Please note: we are required to retain records of your care.
Again, if you have any questions regarding this notice or our health
information privacy policies, please contact Coalition America
According to Arnall, Golden and Gregory, LLP
HIPAA imposes standard file formats for many healthcare transactions.
RepriceNow does not currently involve an exchange of healthcare
information under the ten HIPAA regulated EDI transactions. RepriceNow
involves the transmission of an EOB from a business associate (CAI)
to a health plan. The regulated transmission is between a health
plan and a healthcare provider. That the health plan later transmits
the EOB to a provider has no legal bearing on RepriceNow for purposes
of HIPAA's Transactions and Code Sets Rule, as CAI is not itself
transmitting the information to a provider on behalf of the plan.
Therefore, the health plans that submit information to the CAI database
via RepriceNow need not standardize the format of their submissions.
Further, CAI need not standardize RepriceNow's acceptance of client
data, nor the transmittal of a discount price and EOB back to the
client. The Transactions and Code Sets Rule does not include a standard
related to repricing and the transmission of an EOB from a business
associate to a health plan, making any compliance effort meaningless.
However, HIPAA's Privacy Rule and Proposed Security Rule would
apply to the protected health information used, disclosed and maintained
by CAI's RepriceNow product. CAI's clearinghouse functions will
cause CAI to be a covered entity for purposes of HIPAA. As such,
CAI must protect the health information that it uses, discloses
and maintains in accordance with the Privacy Rule and the Security
Rule (once finalized).