Notice of privacy practices

Affiliated entities covered by this notice

This notice applies to the privacy practices of the following affiliated covered entities that may share your  protected health information as needed for treatment, payment and health care operations:

          • Ascension Personalized Care

Our commitment regarding your protected health information

We understand the importance of your Protected Health Information (hereafter referred to as “PHI”) and follow strict policies (in accordance with state and federal privacy laws) to keep your PHI private. PHI is information  about you, including demographic data, that can reasonably be used to identify you and that relates to your past,  present or future physical or mental health, the provision of health care to you or the payment for that care. Our  policies cover protection of your PHI whether oral, written or electronic. 

In this notice, we explain how we protect the privacy of your PHI, and how we will allow it to be used and  given out (“disclosed”). We must follow the privacy practices described in this notice while it is in effect. This  notice takes effect November 1, 2021 and will remain in effect until we replace or modify it. 

We reserve the right to change our privacy practices and the terms of this notice at any time, provided that  applicable law permits such changes. These revised practices will apply to your PHI regardless of when it was  created or received. Before we make a material change to our privacy practices, we will provide a revised notice  to our participants. 

Where multiple state or federal laws protect the privacy of your PHI, we will follow the requirements  that provide greatest privacy protection. For example, when you authorize disclosure to a third party, state laws  require APC to condition the disclosure on the recipient’s promise to obtain your written permission to  disclose your PHI to someone else.

Our uses and disclosures of protected health information

We may use and disclose your PHI for the following purposes without your authorization:

∙ To you and your personal representative: We may disclose your PHI to you or to your personal  representative (someone who has the legal right to act for you). 

∙ For treatment: We may use and disclose your PHI to health care providers (examples include: doctors,  dentists, pharmacies, hospitals and other caregivers) who request it in connection with your treatment. For  example, we may disclose your PHI to health care providers in connection with disease and case management programs. 

∙ For Payment: We may use and disclose your PHI for our payment-related activities and those of health  care providers and other health plans, including:

         • Obtaining premium payments and determining eligibility for benefits

         • Paying claims for health care services that are covered by your health plan

         • Responding to inquiries, appeals and grievances

         • Coordinating benefits with other insurance you may have 

∙ For health care operations: We may use and disclose your PHI for our health care operations, including  for example:

         • Conducting quality assessment and improvement activities, including peer review. 

         • Performing outcome assessments and health claims analyses 

         • Preventing, detecting and investigating fraud and abuse 

         • Underwriting, rating and reinsurance activities (although we are prohibited from using or disclosing any  genetic information for 
           underwriting purposes) 

         • Coordinating case and disease management activities

         • Communicating with you about treatment alternatives or other health-related benefits and services 

         • Performing business management and other general administrative activities, including systems  management and customer service 

We may also disclose your PHI to other providers and health plans who have a relationship with you for certain  health care operations. For example, we may disclose your PHI for their quality assessment and improvement activities or for health care fraud and abuse detection. 

∙ To others involved in your care: We may, under certain circumstances, disclose to a member of your  family, a relative, a close friend or any other person you identify, the PHI directly relevant to that person’s  involvement in your health care or payment for health care. For example, we may discuss a claim decision  with you in the presence of a friend or relative, unless you object. 

∙ When required by law: We will use and disclose your PHI if we are required to do so by law. For  example, we will use and disclose your PHI in responding to court and administrative orders and subpoenas,  and to comply with workers’ compensation laws. We will disclose your PHI when required by the  Secretary of the Department of Health and Human Services and state regulatory authorities.

∙ For matters in the public interest: We may use or disclose your PHI without your written permission for  matters in the public interest, including for example: 

          • Public health and safety activities, including disease and vital statistic reporting, child abuse reporting, and Food and Drug
            Administration oversight 

          • Reporting adult abuse, neglect or domestic violence 

          • Reporting to organ procurement and tissue donation organizations 

          • Averting a serious threat to the health or safety of others 

∙ For research: We may use and disclose your PHI to perform select research activities, provided that  certain established measures to protect your privacy are in place. 

∙ To communicate with you about health-related products and services: We may use your PHI to  communicate with you about health-related products and services that we provide or are included in your  benefits plan. We may use your PHI to communicate with you about treatment alternatives that may be of  interest to you. These communications may include information about the health care providers in our networks, about  replacement of or enhancements to your health plan, and about health-related products or services that are  available only to our enrollees and add value to your benefits plan. 

∙ To our business associates: From time to time, we engage third parties to provide various services for us.  Whenever an arrangement with such a third party involves the use or disclosure of your PHI, we will have a  written contract with that third party designed to protect the privacy of your PHI. For example, we may  share your information with business associates who process claims or conduct disease management  programs on our behalf. You may give us written authorization to use your PHI or to disclose it to anyone for any purpose. If you  give us an authorization, you may revoke it in writing at any time. Your revocation will not affect any use  or disclosure permitted by your authorization while it was in effect. Some uses and disclosures of your  PHI require a signed authorization: 

∙ For marketing communications: Uses and disclosures of your PHI for marketing communications will  not be made without a signed authorization except where permitted bylaw. 

∙ Sale of PHI: We will not sell your PHI. 

∙ Psychotherapy notes: To the extent (if any) that we maintain or receive psychotherapy notes about you, disclosure of these notes will not be made without a signed authorization except where permitted by law. 

Any other use or disclosure of your protected health information, except as described in this  Notice of Privacy Practices, will not be made without your signed authorization.

Disclosures you may request

You may instruct us, and give your written authorization, to disclose your PHI to another party for any purpose.  We require your authorization to be on our standard form. To obtain the form, call the customer service number  on the back of your membership card.

Individual rights

You have the following rights. To exercise these rights, you must make a written request on our standard  forms. To obtain the forms, call the customer service number on the back of your membership ID card.  

∙ Access: With certain exceptions, you have the right to look at or receive a copy of your PHI contained in  the group of records that are used by or for us to make decisions about you, including our enrollment,  payment, claims adjudication, and case or medical management notes. We reserve the right to charge a  reasonable cost-based fee for copying and postage. You may request that these materials be provided to you  in written form or, in certain circumstances, electronic form. If you request an alternative format, such as a  summary, we may charge a cost-based fee for preparing the summary. If we deny your request for access, we will tell you the basis for our decision and whether you have a right to further review. 

∙ Disclosure accounting: You have the right to an accounting of disclosures we, or our business associates,  have made of your PHI in the six years prior to the date of your request. We are not required to account for  disclosures we made before April 14, 2003, or disclosures to you, your personal representative or in accordance with your authorization or informal permission; for treatment, payment and health care operations activities;  as part of a limited data set; incidental to an allowable disclosure; or for national security or intelligence purposes; or to law enforcement or correctional institutions regarding persons in lawful custody. 

You are entitled to one free disclosure accounting every 12 months upon request. We reserve the right to  charge you a reasonable fee for each additional disclosure accounting you request during the same 12-month period. 

∙ Restriction requests: You have the right to request that we place restrictions on the way we use or  disclose your PHI for treatment, payment or health care operations. We are not required to agree to these  additional restrictions; but if we do, we will abide by them (except as needed for emergency treatment or as  required by law) unless we notify you that we are terminating our agreement. 

∙ Amendment: You have the right to request that we amend your PHI in the set of records we described  above under Access. If we deny your request, we will provide you with a written explanation. If you  disagree, you may have a statement of your disagreement placed in our records. If we accept your request to  amend the information, we will make reasonable efforts to inform others, including individuals you name,  of the amendment. 

∙ Confidential communication: We communicate decisions related to payment and benefits, which may  contain PHI, to the participant. Individual members who believe that this practice may endanger them may request that we communicate with them using a reasonable alternative means or location. For example, an  individual member may request that we send an Explanation of Benefits to a post office box instead of to  the participant’s address. To request confidential communications, call the customer service number on the back of your membership ID card. 

∙ Breach notification: In the event of a breach of your unsecured PHI, we will provide you with notification of such a breach as required by law or where we otherwise deem appropriate.

Questions and complaints

If you want more information about our privacy practices, or a written copy of this notice, please contact us at: 

Ascension Personalized Care

PO Box 1707

Troy, MI 48099

ATTN: Privacy Officer 

For your convenience, you may also obtain an electronic (downloadable) copy of this notice online at ascensionpersonalizedcare.com. 

If you are concerned that we may have violated your privacy rights, or you believe that we have inappropriately used or disclosed your PHI, call us at (833) 600-1311. 

You also may submit a written complaint to the U.S. Department of Health and Human Services. We will  provide you with their address to file your complaint upon request. We support your right to protect the privacy of your PHI. We will not retaliate in any way if you file a complaint with us or with the U.S. Department of  Health and Human Services.