Privacy Notice

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.

This notice describes how the Trust may use and disclose medical information to perform payment and health care operations, and for other purposes that are permitted or required by Federal law under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).  If you reside in a state whose law provides privacy protections more stringent than those provided by HIPAA, we will maintain the privacy of your medical information as required by your stricter state law.

DEFINITIONS

Medical Information means information that is created or received by the plan and relates to past, present or future physical or mental health or condition of a plan participant, the provision of health care to a participant, or the past, present, or future payment for the provision of health care to a participant for which there is a reasonable basis to believe the information can be used to identify the participant.  Protected health information includes information of persons either living or deceased.

OUR PLEDGE REGARDING MEDICAL INFORMATION

We understand that medical information about you and your health is very important.  We are committed to protecting medical information about you.  We receive and create record of your personal health care claims reimbursed under the plan for plan administration purposes.  We will strive to protect this information as required by law.

This notice will inform you about the ways in which we may use and disclose medical information about you.  It also describes our obligations and your rights regarding the use and disclosure of your health information.  We are required by law to:

·        Make sure that medical information that identifies you is kept private.

·        Give you this notice of our legal duties and privacy practices with respect to medical
          information about you; and

·        Follow the terms of the notice that is currently in effect.

HOW WE WILL USE AND DISCLOSE MEDICAL INFORMATION WITH YOUR WRITTEN AUTHORIZATION

We will not use or disclose your medical information for any purpose unless you have signed a form authorizing the use or disclosure.  This authorization must specify who to release the information too, as well as, a specific description of the information that you want us to release.  You have the right to revoke that authorization in writing at any time.  However, any action that we have already taken from the previous authorization cannot be changed.

HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU WITHOUT A WRITTEN AUTHORIZATION

FOR PAYMENT:

We may make uses and disclosures of your medical information without your written authorization as necessary for payment purposes.  This would include how we determine eligibility and enrollment for plan benefits, benefit responsibility under the plan, or coordination of benefits under another group health plan.  For example, we may use information regarding your medical procedures and treatment to process and pay claims, to determine whether a service is medically necessary or to pre-authorize or certify services as covered under your health plan.  We may also share medical information with another entity to assist with the adjudication or subrogation of health claims or to another health plan to coordinate health care benefits.

HEALTH CARE OPERATIONS:

We may use and disclose your medical information without your written authorization as necessary for our health care operations.  We will be sure to limit any necessary disclosure to the minimum necessary to properly administer the plan.  For example, we may use medical information in connection with: conducting quality assessment and improvement activities; premium rating, submitting claims for stop loss (or excess loss) coverage; conducting or arranging for medical review, legal services, audit services, and fraud and abuse detection programs; business planning and development such as cost management; and general plan administrative activities.

OTHER USES AND DISCLOSURES:

• Information may be disclosed to your plan sponsor for general plan administration purposes.  If we choose to disclose your health information, your plan sponsor must certify that the information provided will be maintained and handled in a confidential manner as determined by law.
• We may disclose medical information about you when required by law to a government agency conducting audits, investigations, or civil or criminal proceedings.
• We may release your medical information for public health activities, such as required reporting of disease, injury, birth and death and for required public health investigations.
• We may release your medical information as required by law if we suspect child abuse or neglect or if we believe you to be a victim of abuse, neglect or domestic violence.
• We may disclose your medical information to a public health organization for the purpose of reporting adverse reactions to medications or problems with products or services, or to participate in product recalls.
• If you are an organ donor, we may release your medical information to organizations responsible for the arrangement of organ or tissue donation from you or a transplant to you.     
• If you are a member of the armed forces, we may disclose medical information about you as required by military command authorities.  We may also release medical information about foreign military personnel to the appropriate foreign military authority.  We may also disclose medical information to authorized federal officials for intelligence, counterintelligence, and other national security organizations authorized by law.
• We may disclose medical information if we are asked to do so by a law enforcement official in response to a court order, subpoena, warrant, summons or similar process.  We may also disclose medical information about a death or injury we believe may be the result of a crime, or in emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.
• We may release medical information to coroners and or medical examiners for identification purposes.  We may also disclose medical information about patients of the hospital to funeral directors as necessary to carry out their duties.
• We may release your medical information to workers compensation agencies if necessary for your benefit determination.

YOUR RIGHTS REGARDING MEDICAL INFORMATION ABOUT YOU

You have the right to inspect and or receive a copy of much of your medical information.  All requests must be made in writing and signed by you or your appointed representative.  Under very limited circumstances, your request for medical information may be denied.  If this happens, you will receive written notification.  If you are not satisfied with our decision, you have the option to appeal.  You will need to notify the contact at the end of this notice for the proper appeal proceedings.

YOUR RIGHT TO AMEND YOUR MEDICAL INFORMATION

You have the right to request that the medical information we maintain for you be amended or corrected if you feel that it is not accurate or incomplete.  We are not obligated to make all requested amendments but will give each request careful consideration.  All amendment requests must be in writing.  You must include an explanation or reason that supports your request for the amendment.  If the amendment request is part of a medical record that your provider has provided us with, you will need to contact the provider who wrote the record and request the change.  When the provider adjusts or corrects the record, you will need to send us a copy of the change for our records.  You will need to notify the contact at the end of this notice for the information on how to make an amendment to your medical information.

YOUR RIGHT TO AN ACCOUNTING OF THE DISCLOSURES OF YOUR MEDICAL INFORMATION

You have the right to receive an accounting of disclosures made by us of your medical information for any purpose other than treatment, payment, health care operations, or those made with your authorization.  These requests must be made in writing and signed by you or your appointed representative.  Your request must indicate a time period, which may not be longer than six years and may not include dates before April 14, 2003.  You can send your request to the contact at the end of this notice.

YOUR RIGHT TO RESTRICT THE USE AND DISCLOSURES OF YOUR MEDICAL INFORMATION. 

You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment or health care operations.  You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care, like a family member or friend.  Your request for restriction must describe in detail; what information you want to limit; whether you want to limit our use, disclosure or both; and to whom you want the limits to apply.    We are not required to agree to your restriction request but will attempt to accommodate your request within reason.  You can mail your request to the contact at the end of this notice.

YOUR RIGHT TO REQUEST CONFIDENTIAL COMMUNICATIONS 

You have the right to request that we communicate with you about medical matters by alternative means or at a different location. For example, if you would rather us contact you at work instead of home.  You must make this request in writing to the contact identified at the end of this notice.   We will accommodate all reasonable requests to the best of our ability.  Your request must specify how or where and by what means you wish to be contacted.

COMPLAINTS

If you believe that your group health plan has violated your privacy rights, you may file a complaint with the Secretary of the Department of Health and Human Services or at the contact named at the end of this notice.  Please send in writing, a complete description of the privacy violation and it will be handled very seriously and without any retaliation or penalty.

CHANGES TO THIS NOTICE

We reserve the right to make changes to this notice at any time.  We also reserve the right to make a new notice effective for all medical information maintained by us, including medical information, which was received by us before the effective date of the new notice.  If we do revise our privacy notice at any time, notification will be sent to you.

EFFECTIVE DATE

This notice will be in effect April 14, 2003.  You have the right to request a copy of this notice at any time.  Please contact us and we will mail it to you.

CONTACT INFORMATION

If you need to reach us for any of the reasons identified in this notice or if you have any further questions or concerns regarding this notice, you may contact:

                                                Administration Services, Inc.

                                                Attention: Privacy Officer

                                                PO Box 5434

                                                Spokane, WA.  99205

                                                (509) 328-0300