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UNITED CONCORDIA COMPANIES, INC.
NOTICE OF PRIVACY POLICIES AND PRACTICES
PART I -- NOTICE OF PRIVACY PRACTICES (HIPAA)
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.
Our Legal Duty
United Concordia Companies, Inc., and its subsidiaries (
referred to as United Concordia) are committed to protecting your privacy
and are required by applicable federal and state laws to maintain the
privacy of your protected health information. “Protected health
information” is your individually identifiable health information,
including demographic information, collected from you or created or
received by a health care provider, a health plan, your employer,
or a health care clearinghouse that relates to: (i) your past,
present, or future physical or mental health or condition; (ii)
the provision of health care to you; or (iii) the past, present or
future payment for the provision of health care to you.
This notice describes our policies and practices for collecting,
handling, and protecting our members' protected health information. We are
required to give you this notice about our privacy practices, our legal
duties, and your rights concerning your protected health information. We
will inform you of these policies the first time you become a United Concordia
customer and will annually reaffirm our privacy policy for as long as you remain
a United Concordia customer. We must follow the privacy practices that are described
in this notice while it is in effect. This notice takes effect
04/13/2003, and will remain in effect until we replace it.
We will continually review our privacy policies and practices and monitor our
business practices to help ensure the security of our members' protected health
information. Due to changing circumstances, it may become necessary to revise
our privacy policies and practices and the terms of this notice at any time,
provided that such changes are permitted by applicable law. We reserve the right
to make the changes in our privacy practices and the new terms of our notice
effective for all protected health information that we maintain, including protected
health information we created or received before we made the changes. Before we make
a significant change in our privacy practices, we will change this notice and
notify all affected members in writing in advance of the change.
You may request a copy of our notice at any time. For more information about
our privacy practices, or for additional copies of this notice, please contact
us using the information listed at the end of this notice.
Uses and Disclosures of Protected Health Information
In order to administer our dental benefit programs effectively, we collect,
use and disclose protected health information for certain of our activities,
including payment and health care operations. The following is a description of
how we may use and/or disclose protected health information about you for payment
and health care operations:
Payment: We may use and disclose your
protected health information to pay claims for services provided to you by
dentists covered by your dental plan.
Health Care Operations: We may use and
disclose your protected health information to determine our premiums for
your dental plan, to conduct quality assessment and improvement
activities, to engage in care coordination or case management, to manage
our business and the like.
We may use and/or disclose your protected health
information for all activities that are included within the definition
of “payment” and “health care operations”
but we have not listed in this notice all of the activities included within
the definition of “payment” and “health care
operations”, so please refer to 45 C.F.R. - 164.501
for a complete list.
We also may use and disclose protected health information
to other covered entities, business associates, or other individuals
(as permitted by the HIPAA Privacy Rule) who assist us in
administering our programs and delivering health services to our members.
Business Associates: In connection
with our payment and health care operations activities, we contract
with individuals and entities (called “business associates”)
to perform various functions on our behalf or to provide certain types
of services (such as member service support, utilization management
or subrogation). To perform these functions or to provide the
services, business associates will receive, create,
maintain, use, or disclose protected health information, but
only after we require the business associates to agree in writing to
contract terms designed to appropriately safeguard your information.
Other Covered Entities: In addition,
we may use or disclose your protected health information to assist health
care providers in connection with their treatment or payment
activities, or to assist other covered entities in connection with
certain of their health care operations. For example,
we may disclose your protected health information to a health care provider
when needed by the provider to render treatment to you, and we
may disclose protected health information to another covered entity to conduct
health care operations in the areas of quality assurance and improvement
activities, or accreditation, certification, licensing
or credentialing.
Other Possible Uses and Disclosures of
Protected Health Information
In addition to uses and disclosures for payment and
health care operations, we may use and/or disclose your protected
health information for the following purposes.
To Plan Sponsors: We may disclose
your protected health information and the protected health information
of others enrolled in your group dental plan to the plan sponsor to
permit it to perform plan administration functions. Please see your
plan documents for a full explanation of the limited uses and disclosures
that the plan sponsor may make of your protected health information in
providing plan administration functions for your group dental plan.
Marketing: We may use your protected
health information to contact you with information about
dental-related benefits and services or about treatment alternatives
that may be of interest to you. We may disclose your protected
health information to a business associate to assist us in
these activities.
Others Involved in Your Health Care:
Unless you object, we may release protected health information about
you to a friend or family member who is involved in your dental care or
to someone who helps pay for your care. We may also disclose protected
health information about you to an organization assisting in a disaster
relief effort so that your family can be notified about your condition,
status or location.
Research, Death: We may use or
disclose our protected health information for research purposes in
limited circumstances. We may disclose the protected health information
of a deceased person to a coroner, medical examiner, or funeral
director.
Public Health and Safety: We may
disclose your protected health information to the extent necessary to
avert a serious and imminent threat to your health or safety or
the health or safety of others. We may disclose your protected
health information to a government agency authorized to oversee the
healthcare system or government programs or its contractors,
and to public health authorities for public health purposes. We
may disclose your protected health information to appropriate authorities
if we reasonably believe that you are a possible victim of abuse,
neglect, domestic violence or other crimes.
Required by Law: We may use or disclose
your protected health information when we are required to do so by law.
For example, we must disclose your protected health to the U.S.
Department of Health and Human Services upon request for purposes of
determining whether we are in compliance with federal privacy laws.
We may disclose your protected health information when authorized by
workers' compensation or similar programs which provide benefits for
work-related injuries or illness.
Process and Proceedings: We may disclose
your protected health information in response to a court or administrative
order, subpoena, discovery request, or other lawful process,
under certain circumstances. Under limited circumstances, such as a
court order, warrant, or grand jury subpoena, we may disclose
your protected health information to law enforcement officials.
Law Enforcement: We may disclose
limited information to a law enforcement official concerning the protected
health information of a suspect, fugitive, material witness,
crime victim or missing person. We may disclose the protected health
information of an inmate or other person in lawful custody to a law
enforcement official or correctional institution under certain circumstances.
We may disclose protected health information where necessary to assist
law enforcement officials to capture an individual who has admitted to
participation in a crime or has escaped from lawful custody.
Military and National Security: We
may disclose to Military authorities the protected health information
of Armed Forces personnel under certain circumstances. We may
disclose to authorized federal officials protected health information
required for lawful intelligence, counterintelligence, and
other national security activities.
To You and on Your Authorization:
We must disclose your protected health information to you, as
described in the Individual Rights section of this notice, below.
You may give us written permission to use your protected health information
or to disclose it to anyone for any purpose. If you give us permission,
you may change your mind at any time. Your decision to revoke
your prior authorization will not affect any use or disclosures made
while it was in effect. Without your written permission, we may
not use or disclose your protected health information for any reason except
those described in this notice.
Individual Rights
Right to Inspect and Copy: You have the
right to inspect and copy protected health information that may be used to make
decisions about your care. This includes dental records. To inspect and
copy protected health information, you must submit your request in writing.
If you request a copy of the information, we may charge a fee for the costs
of copying, mailing or other costs associated with your request. We may
deny your request to inspect and copy in certain limited circumstances.
If you are denied access to protected health information, you may request
a review of that decision. Another health care professional will review your
request and the denial. The person conducting the review will not be the
person who denied your request. We will comply with the outcome of the
review.
Disclosure Accounting: You have the right to
receive a list of instances in which we or our business associates disclosed
your protected health information for purposes other than treatment,
payment, health care operations and certain other activities. We
will provide you with the date on which we made the disclosure, the
name of the person or entity to which we disclosed your protected health
information, a description of the protected health information we
disclosed, the reason for the disclosure, and certain other
information. If you request this list more than once in a 12-month
period, we may charge you a reasonable, cost-based fee for
responding to these additional requests.
Restriction Requests: You have the right
to request that we place additional restrictions on our use or disclosure of
your protected health information. We are not required to agree to
these additional restrictions, but if we do, we will abide by our
agreement (except in an emergency). To request restrictions,
you must make your request in writing. In your request, you must
tell us: (a) what information you want to limit; (b)
whether you want to limit our use, disclosure or both; and (c)
to whom you want the limits to apply, for example, disclosures to
your spouse.
Confidential Communication: You have
the right to request that we communicate with you about protected health
information in a certain way or at a certain location. For example,
you can ask that we only contact you at home or only by mail. To request
confidential communications, you must make your request in writing.
Your request must specify how or where you wish to be contacted. We
will accommodate all reasonable requests as long as it permits us to collect
premiums and pay claims under your dental plan.
Amendment: You have the right to request
that we amend your protected health information. Your request must be in
writing, and it must explain why the information should be amended. We
may deny your request if we did not create the information you want amended
or for certain other reasons. If we deny your request, we will
provide you a written explanation. You may respond with a statement of
disagreement to be included in the information you wanted amended.
If we accept your request to amend the information, we will make reasonable
efforts to inform others, including people you name, of the amendment and to
include the changes in any future disclosures of that information.
Right to a Paper Copy of This Notice: You
have the right to a paper copy of this notice, and you may ask us to give
you a copy of this notice at any time. You may obtain an electronic
copy of this notice at our website,
www.unitedconcordia.com.
Questions and Complaints
If you want more information about our privacy practices or have
questions or concerns, please
contact us using the information listed below.
If you are concerned that we may have violated your privacy rights, or
you disagree with a decision we made about access to your protected health
information or in response to a request you made to amend or restrict the
use or disclosure of your protected health information or to have us communicate
with you in confidence by alternative means or at an alternative location, you
may contact us using the contact information listed below. You also may submit
a written complaint to the U.S. Department of Health and Human Services.
We will provide you with the address to file your complaint with the U.S.
Department of Health and Human Services upon request.
We support your right to protect the privacy of your dental information.
We will not retaliate in any way if you choose to file a complaint with us or with
the U.S. Department of Health and Human Services.
Contact Office: United Concordia Privacy Department
Telephone: (866)215-2352
(Toll Free) Fax : (717)260-7494
Web:
www.unitedconcordia.com
Address: 4401 Deer Path Road, Harrisburg, PA 17110
PART II -- NOTICE OF PRIVACY
PRACTICES (GRAMM-LEACH-BLILEY)
Notice of Privacy Policy for Consumer Nonpublic
Personal Information
United Concordia values our customers and takes privacy seriously. In order
to administer our dental benefits programs effectively, we must collect, use
and disclose nonpublic personal information (NPPI). NPPI is information that
identifies an individual member of a United Concordia dental program. It may
include an individual's name, address, telephone number and social security
number, or it may relate to an individual's participation in the plan, his/her
dental condition, the provision of dental care services or the payment of
dental care services. NPPI does not include publicly available information,
or information available or reported in an aggregate form that does not
identify individual persons
We are committed to protecting the privacy and confidentiality of this
information. We will inform our customers of our policy on collecting,
using, sharing and securing NPPI the first time you become a customer and
annually reaffirm our privacy policy. We will continually review our
privacy policy, and monitor our business practices to help ensure the
security of member NPPI. Should a change to our privacy policy be required,
we will notify our customers in writing and in advance of the change.
Information we may collect on members
and their dependents:
The NPPI we collect varies, depending upon the products and services
requested. We collect NPPI from the following sources:
- Information we receive directly or indirectly from the member or
the member's group or administrator through applications, surveys
or other forms, in writing, in person, by telephone or electronically.
Information including, but not limited to name, address, social
security number, date of birth, marital status, dependent information,
employment information and medical or dental history.
- Information about a member's relationship and transactions with our
affiliates, our agents, others and us. This may include information on
dental claims, eligibility, payment, dental conditions, dental history,
utilization review, appeals and grievances.
Member information we may disclose
and the purpose:
We do not disclose any NPPI about members or former members
to anyone, except as permitted or required by law. Disclosures may be made
without prior authorization as permitted by law. We use NPPI internally,
share NPPI with our affiliates, and disclose NPPI to health care providers,
agents, other insurers, payors, vendors, consultants and government
authorities as necessary to administer dental care benefits policies or
contracts, to detect and/or prevent insurance fraud and to comply with
mandatory regulatory activities. We contractually require any person or
organization providing services or products on our behalf to protect the
confidentiality of our customers' and members' NPPI.
Safeguarding member NPPI:
We restrict access to NPPI about members and their
dependents to those employees, vendors, healthcare providers and agents
who need to know that information to provide products or services. We
maintain physical, electronic and procedural safeguards that comply
with state and federal regulations to guard member NPPI from unauthorized
access, use and disclosure.
Coverage may be underwritten or administered by one or more of the following
subsidiaries of United Concordia Companies, Inc.:
- United Concordia Dental Corporation of Alabama
- United Concordia Dental Plans of California, Inc.
- United Concordia Dental Plans of Florida, Inc.
- United Concordia Dental Plans, Inc.
- United Concordia Dental Plans of Kentucky, Inc.
- United Concordia Dental Plans of the Midwest, Inc.
- United Concordia Dental Plans of Pennsylvania, Inc.
- United Concordia Dental Plans of Texas, Inc.
- United Concordia Insurance Company
- United Concordia Insurance Company of New York
- United Concordia Life and Health Insurance Company
- United Concordia Services, Inc.
The following are other documents on United Concordia's main web
site related to United Concordia's privacy policies.
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