Senior Health Insurance Company of Pennsylvania (SHIP) Information Privacy Practices Notice
This Notice of Health Information Privacy Practices is applicable to the long term care insurance business of Senior Health Insurance Company of Pennsylvania ("SHIP"). This notice refers to SHIP by using the terms "us", "we" or "our".
Our goal at SHIP is to provide you with high-quality services. To do that, we collect personal information about you. But we realize that we have an important responsibility to protect the privacy and security of your non-public personal information. We are providing this notice to give you a better understanding of our privacy and security policies.
Our Pledge and Obligation: We are committed to protecting your personal health information (hereinafter referred to as "PHI") and non-public personal information (hereinafter referred to as "NPI"). This notice will tell you about the ways in which we may use and disclose your PHI/NPI for payment, health care operations, and other circumstances as either required or permitted by law. Except as outlined below, we will not use or disclose your PHI/NPI without your written authorization.
We are required by law to: safeguard your PHI/NPI, give you this Notice of our duties and privacy practices; and abide by the terms of this Notice as long as it remains in effect.
We reserve the right to change any of our privacy practices and the terms of this Notice, and to make the new Notice effective for all PHI/NPI maintained by us. In the event of a material change, a revised Notice will be sent to all of our policyholders.
Protected Health Information (PHI) PHI is at the heart of the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and is the basis for many of the protections and requirements under HIPAA. The Privacy Rule provides protections for patients by limiting the way that health entities, such as health insurers, hospitals, and physicians can use and/or disclose patient"s personal health information. The Privacy Rule protects all individually identifiable health information otherwise referred to as Protected Health Information (PHI). PHI is any health related information that is created, maintained, transferred or received by the covered entity. This information could be used to identify, or reasonably used to identify an individual.
Non-Public Personal Information (NPI) is any data or information considered to be personal in nature and not subject to public availability.
Information We Collect
We collect PHI/NPI about you from:
- Applications and other forms you complete;
- Your business dealings with us and other companies;
- Consumer reporting agencies;
- Other third parties, such as the Medical Information Bureau (MIB) and public record databases.
A consumer-reporting agency that gives us information about you may keep it and share it with others who use their services.
How We Treat Information
We also may share your PHI/NPI we get through consumer reporting agencies. You may stop such sharing by checking the "Restrict Information Sharing With Companies We Own or Control (Affiliates)" box on the attached form, and returning it to us. We may also share personal and financial information about you with outside companies we contract with to provide marketing services or financial products and services to you. You may stop such sharing by checking the "Restricted Information Sharing with Other Companies We Do Business with To Provide Marketing Services or Financial Products And Services" box on the attached form, and returning it to us.
If we obtain a report from a consumer reporting agency, then the agency preparing the report may retain it and share it with others who use their services as permitted by law.
Uses and Disclosures of Your Personal Health Information or Non-Public Personal Information
For Treatment: We do not make treatment decisions, but we may disclose information to those who do. For example, we may disclose information regarding your benefits to doctors, hospitals, long term care facilities, and other health care providers who take care of you.
For Claim Processing and Payment Related Purposes: We may make uses and disclosures of your PHI/NPI as necessary for benefit verification and claim processing purposes. For instance, we may use information regarding long term care services you receive from service providers such as nursing homes, assisted living facilities, and home health care agencies to process and pay claims.
Examples of our payment related purposes also include our collection of premium, coordinating reinsurance, and care coordination activities.
For Business Operations: We will use and disclose your PHI/NPI as necessary, and as permitted by law, for our health care operations which include underwriting, premium rating, customer service, reinsurance, compliance, fraud prevention and reporting, auditing, agent commission reconciliation, and other activities related to the issuance, renewal, replacement, or continuation of your long term care insurance coverage.
- Collection of Information: To properly underwrite and administer your insurance coverage, we collect health and non-health personal information such as your age, occupation, physical condition, and health history, including drug and alcohol usage. You are our most important source of information; however, with your authorization we may also collect or verify information by contacting information sources such as Consumer Reporting agencies (like the Medical Information Bureau); insurance companies to which you have applied for coverage; and medical professionals and facilities which have provided services to you.
- Business Associates: Certain services are performed through contracts with outside persons or organizations, such as underwriting support services, actuarial services, legal services, care coordination services, etc. At times it may be necessary for us to disclose your PHI/NPI to one or more of these outside persons or organizations who assist us with our health care operations. We obligate business associates by contract to appropriately safeguard the privacy of your information.
- Family and Friends Involved in Your Care: We may from time to time disclose your PHI/NPI to certain family members, friends, and others who are involved in your care or in the payment of your care in order to not hinder that person's involvement. If you are unavailable, incapacitated, or facing an emergency medical situation and we determine that a limited disclosure may be in your best interest, we may share limited PHI/NPI with such individuals without your written authorization. If you have designated a person to help prevent the unintentional lapse of your coverage, we will inform that person prior to terminating the policy for nonpayment of premium. We may also disclose limited PHI/NPI to a public or private entity that is authorized to assist in disaster relief efforts in order for that entity to locate a family member or other persons that may be involved in some aspect of caring for you. You have the right to stop or limit these disclosures by contacting us at the address shown at the end of this notice.
Other Uses and Disclosures for Public Health, Government Oversight, or Similar Activities
We are permitted or required by law to make certain other uses and disclosures of your PHI/NPI without your authorization.
- We may release your PHI/NPI for any purpose allowed by law;
- We may release your PHI/NPI to law enforcement officials as allowed by law to report wounds and injuries and crimes;
- We may release your PHI/NPI for public health activities, such as permitted reporting of disease, injury, death, and for required public health investigations;
- We may release your PHI/NPI as required by law if we believe you to be a victim of abuse, neglect, or domestic violence;
- Unless otherwise permitted by law or your written authorization, we will only disclose enrollment, disenrollment and summary health information with your employer for administrative purposes, such as payroll deduction of the employee portion of the premium;
- We may release your PHI/NPI if required by law to a government oversight agency conducting audits, investigations (such as investigations into consumer complaints), or civil or criminal proceedings;
- We may release your PHI/NPI if required to do so by a court or administrative ordered subpoena or discovery request;
- We may release your PHI/NPI to non-affiliated organizations or persons such as, other insurance institutions, agents, insurance support organizations, or law enforcement and governmental authority as necessary to prevent criminal activity, fraud, material misrepresentation or material non-disclosure in connection with your coverage or application for coverage; and
- We may release your PHI/NPI to and affiliates in conjunction with health care operation purposes.
Other Information Sharing
Even if you choose to exercise your right to "opt out", some of the information we collect may still be shared within and outside of SHIP, as permitted by law. For example, we may share your information to underwrite or service your policy, process transactions, or comply with legal requirements. Unless you choose to "opt out" we may also disclose information to persons who perform marketing services on our behalf, including insurance agents, to other service providers, or to other financial institutions with whom we have joint marketing agreements. We will not share medical information for marketing purposes.
Notice regarding certain state laws
Certain states impose additional restrictions on our collection and disclosure of PHI/NPI and also may grant you the right to review, obtain a copy of, or request that we correct certain personal information contained in our insurance files. Those states currently include: AZ, CA, CT, GA, IL, MA, ME, MN, MT, NV, NJ, NC, OH, OR, VA, and VT.
Rights That You Have
Your rights are explained below. Any written requests to exercise those rights should be directed to the address provided at the end of this notice.
- Right to Access. You have the right to copy and/or inspect much of the PHI/NPI that we retain on your behalf. All requests must be made in writing and signed by you or your representative. We may charge a reasonable fee for copies and postage and, in certain cases, may deny your request.
- Right to Confidential Communications. You have the right to request that we send communications of PHI/NPI to you by alternative means or to alternative locations, if all or part of that information could endanger you. For example, you may ask that we contact you at work, rather than at home. We will try to accommodate reasonable requests.
- Right to Amend. You have the right to request in writing that PHI/NPI that we maintain about you be amended or corrected. We are not obligated to make all requested amendments but will give each request careful consideration. All amendment requests, in order to be considered by us, must be in writing, signed by you or your representative, and must state the reasons for the amendment/correction request. If an amendment or correction you request is made by us, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary.
- Right to an Accounting of Disclosures. You have the right to receive an accounting of certain disclosures made by us of your PHI/NPI after April 14, 2003. Requests must be made in writing and signed by you or your representative. The first accounting in any 12-month period is free; you may be charged a reasonable fee for each subsequent accounting you request within the same 12-month period.
- Right to Request Restrictions. You have the right to request restrictions on certain of our uses and disclosures of your PHI/NPI for payment, or health care operations by notifying us of your request for a restriction in writing. Your request must describe in detail the restriction you are requesting. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate and we retain the right to terminate an agreed-to restriction if we believe such termination is appropriate. In the event of a termination by us, we will notify you of such termination. You also have the right to terminate in writing any agreed-to restriction by sending such termination notice to us at the address given below.
- Right to Revoke Your Authorization. If you have signed an authorization for uses and disclosures not related to payment or health care operations, you have the right to revoke that authorization in writing at any time, except to the extent that we have taken action in reliance of such authorization, or if other law provides us with the right to contest a claim under the policy or the policy itself. Note: your revocation will not prevent us from using collected information in conjunction with our fraud prevention program.
- Right to a Paper Copy of this Notice. You have the right to a paper copy of this notice. You may ask us to give you a copy of this notice at any time. Even if you have agreed to receive this notice electronically, you are still entitled to a paper copy.
Note: The rights granted to you do not extend to information about you relating to or in anticipation of claim or civil or criminal proceeding.
If you believe your privacy rights have been violated, you can file a complaint with us by sending your written complaint to our Complaint Coordinator at the address given below. You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services in Washington, D.C. in writing within 180 days of a violation of your rights. We will not retaliate against you for filing a complaint.
To file a complaint or to make a request as described in the section entitled "RIGHTS THAT YOU HAVE," please send your written request to:
Senior Health Insurance Company of Pennsylvania,
1289 West City Center Drive
Carmel, IN 46032
Requests should be directed to our Customer Service Department, and Complaints should be sent to the attention of the Privacy Officer. Please be sure to include the following information:
- your full name,
- date of birth,
- policy number, and
- the nature of your request or complaint.
A final word
SHIP is committed to the security and confidentiality of your PHI/NPI. We maintain reasonable physical, procedural and electronic security measures that meet applicable standards. In addition, our security practices include limiting access to this information only to those employees and business associates with appropriate authority and for intended business purposes only.
We typically will retain your personal information for a period of time after the end of a customer relationship. In some cases, we may be required to retain certain information for a certain amount of time by law or by industry standard. We maintain the same standards of privacy after the customer relationship has ended as we do for current customers.
Please note that if you provide personal information to other financial services providers not affiliated with us, for example, independent insurance agents or mortgage brokers, their use of such information may not be governed by this privacy notice. You should review the privacy notice of such third parties to understand how they collect, use and disclose such information.
For Further Information
If you have any questions regarding your rights, contents of this notice, would like to request additional information regarding our Notice of Health Information Privacy Practices or our general privacy policies, or would like to invoke your right to opt out of information sharing please write to us at the address shown above or contact our Customer Service Department toll-free at 1-877-SHIPLTC (1.877.744.7582).
Please note that if you have previously responded to a privacy notice from SHIP and instructed SHIP not to share your information, we will continue to honor your request until you notify us in writing. You do not need to take any further action in response to this notice. This notice applies to any individual who seeks to obtain or has obtained an insurance product or service from Senior Health Insurance Company of Pennsylvania (SHIP).
Senior Health Insurance Company of Pennsylvania (SHIP) Information Privacy Practices Notice
Important Privacy Choices for Consumers
You have the right to control whether we share some of your personal information.
Please read the following information before you make your choices below.
You have the following rights to restrict the sharing of personal and financial information with our affiliates (companies we own or control) and outside companies that we do business with. Nothing in this form prohibits the sharing of information necessary for us to follow the law, as permitted by law, or to give you the best service on your accounts with us. This includes sending you information about some other products or services.
Restrict Information Sharing With Companies We Own or Control (Affiliates): Unless you say "No" we may share personal and financial information with our affiliated companies.
(_) No, please do not share personal and financial information with your affiliated companies.
Restrict Information Sharing With Other Companies We Do Business with To Provide Marketing Services or Financial Products And Services: Unless you say "No" we may share personal and financial information about you with outside companies we contract with to provide marketing services or financial products and services to you.
(_) No, please do not share personal and financial information with outside companies you contract with to provide marketing services or financial products and services.
Time Sensitive Reply
You may make your privacy choice(s) at any time. Your choice(s) marked here will remain unless you state otherwise. However, if we do not hear from you we may share some of your information with affiliated companies and other companies with whom we have contracts to provide products and services.
Account or policy number(s):_____________________________ (to be filled out by consumer)
To exercise your choices do one of the following: (1) Fill out, sign and send back this form to us using the envelope provided (you may want to make a copy for your records); or (2) Call this toll-free number 1-877-SHIPLTC (1.877.744.7582).
YOU DO NOT NEED TO RETURN THIS FORM UNLESS YOU WISH TO CHANGE YOUR PRIVACY CHOICES.