HIPAA Notice of Privacy Practices
Regarding protected health information for employee retiree medical, dental, vision, employee reimbursement account and employee assistance program health plans
This notice describes how medical information about you may be used and disclosed and how you can access this information. Not all situations will be described. We are required to follow the terms of the notice currently in effect.
This is your notice of privacy practices provided by Eastern Michigan University (EMU). This notice refers to EMU by using the terms "us," "we" or "our." EMU must collect information about you to provide you with health insurance. We know information we collect about you and your health is private. EMU is required to protect this information by federal and state law.
The Genetic Information Discrimination Act of 2008 (GINA) includes provisions related to genetic information affecting HIPAA nondiscrimination rules. Genetic information is defined as information about genetic tests of an individual or family members, information about the manifestation of a family member’s disease or disorder and an individual’s request for or receipt of genetic services.
Effective May 21, 2009, GINA mandates that a group health plan cannot:
- Adjust premiums or contribution amounts based on genetic information
- Request or require an individual or family member to undergo a genetic test
- Request, require or purchase genetic information prior to or in connection with enrollment in the plan
- Use genetic information for underwriting purposes
Group health plans may use the results of genetic tests for payment purposes explained below, as long as the minimum amount of information necessary is used
How EMU may use and Disclose Information without your Authorization
- For Payment: We may use or disclose information to pay for the health care services you receive. For example, EMU may receive and review health information contained on claims to reimburse providers for services rendered or to verify insurance enrollment and eligibility information with providers seeking to receive payment for healthcare services provided to you or your covered dependents.
- For Health Care Operations: We may use or disclose health information for our insurance operations or to manage our programs or activities. For example, we may use PHI to process transactions requested by you, review the quality of services you receive or audit the services for which our insurance carriers have been contracted to perform.
- Where Required by Law or for Law Enforcement: We will use and disclose information when required by law. Examples of such releases would be for law enforcement, subpoenas or other court orders, disaster relief, review of our activities by government agencies, to avert a serious threat to health or safety or in other kinds of emergencies.
- When Required for Public Health Activities: We will disclose information when required by federal, state or local law. Examples of such mandatory disclosures include notifying state or local health authorities about communicable diseases or providing information to a coroner or medical examiner to assist in identifying a deceased individual or to determine the cause of death
- For Health-Related Benefits or Services: We may use health information to provide you with information about benefits available to you under your current Insurance coverage and, in limited situations, about health-related products or services that may be of interest to you.
- When Requested as Part of a Regulatory or Legal Proceeding: If you or your estate may disclose health information about you in response to a court or administrative order. We may disclose protected health information to any governmental agency or regulator with whom you have filed a complaint or as part of a regulatory agency examination.
- For Government Programs: We may use and disclose information for public benefits under other government programs. For example, we may disclose information for the determination of benefits under Medicare.
- Disclosures to Family, Friends and Others : We may disclose information to your family or other person(s) who are involved in your medical care or payment for your medical care. You have the right to object to the sharing of this information.
- Other Uses of Health Information: For other situations, EMU will ask for your written authorization before using or disclosing information.
To revoke an authorization, you must submit a written revocation to Joline Davis (see contact information below.)
Your Privacy Rights
- To See and Get Copies of Your Records: You must make the request in writing and may be charged a fee for the copying.
- Right to Amend Your Records: You may ask EMU to change or update your records. You must make the request in writing and provide a reason for your request.
- Right to Get a List of Disclosures: You may request a list of disclosures made after April 14, 2003. You must make the request in writing. This list won't include the times that information was disclosed for payment or health care operations or releases required by law or for law enforcement. The list also will not include information provided directly to you or information that was sent with your authorization.
- Right to Request Limits on Uses or Disclosures: You may request that EMU limit how information is used or disclosed. You must make the request in writing and tell us what information you want to limit and to whom you want the limits to apply. EMU is not required to agree to the limitation. You can request, in writing, that the limitation be terminated or EMU may terminate the limitation with advance notice to you.
- Right to Request Confidential Communications: You may request that we share information with you in a certain way or place. For example, you may ask us to send information to your work address instead of your home. You must make this request in writing.
- Right to Revoke Authorization: If you are asked to sign an authorization to use or disclose information, you can cancel that authorization at any time. You must make the request in writing. This won't affect information already disclosed under the authorization.
- Right to File a Complaint: You have the right to file a complaint if you don't agree with how EMU has used or disclosed information about you.
- Right to Get a Paper Copy of this Notice: You have the right to ask for a paper copy of this notice at any time.
Communications about your Rights
You may contact EMU to ask to:
- Look at or copy your records
- Limit how information about you is used or disclosed
- Cancel your authorization
- Amend your records
- Ask for a list of the times EMU disclosed information about you
EMU may deny your request to look at, copy or amend your records. If that happens, you'll get a letter telling you why and how you can ask for a review of the denial. You'll also receive information about how to file a complaint with EMU or with the U.S. Department of Health and Human Services, Office of Civil Rights. If you wish to ask questions about this notice, exercise your rights under this notice, communicate with us about privacy issues or file a complaint, you can contact:
Brett I. Last
EMU HIPAA Privacy Officer
Eastern Michigan University
311 King Hall
Ypsilanti, Michigan 48197
734.487.3430 | Fax: 734.487.4389
You may file a complaint with the federal government at:
U.S. Office of Civil Rights
Medical Privacy, Complaint Division
U.S. Department of Health and Human Services
200 Independence Avenue, SW
Washington, DC 20201
866.627.7748 | TTY: 866.788.4989
[email protected]
Changes to This Notice: We reserve the right to revise this notice at any time. The revised notice will be effective for health information we already have about you as well as any information we may receive in the future. We are required to comply with whatever notice is currently in effect. We will communicate any changes to this notice.