Privacy Notice (“Notice”)

This Notice is intended to comply with the Gramm-Leach-Bliley Act (GLBA) and the Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy and Security Rules (as amended by the Health Information and Technology for Economic and Clinical Health Act of 2009 (HITECH)) and DESCRIBES HOW PERSONAL, MEDICAL AND/OR FINANCIAL INFORMATION WE MAINTAIN ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY. NO RESPONSE IS REQUIRED.

I. Our Privacy Obligations

This Notice describes the privacy practices of CHCS Services Inc. (“we” or “us” or “our”) as a wholly owned subsidiary of Capgemini America, Inc..

to the extent that (i) we maintain individual health information, known as protected health information, that includes virtually all individually identifiable health information (with the exception of life, disability or any other plans) — whether received in writing, in an electronic medium, or as an oral communication, or consumers’ nonpublic personal, financial or personally identifiable information (“Information”); and (ii) we provide services to you under the terms of you or your groups application or agreement for services. This Notice does not apply to Information from which identifying information has been removed.

A. How We Protect Information

We are required to protect the confidentiality of Information. Our employees may access Information only when there is an appropriate reason to do so, such as to administer or offer our products or services to you and are required to comply with our established policies. We endeavor to maintain physical, electronic and procedural safeguards designed to protect Information in compliance with applicable laws.

B. How We Collect Information

Our access to Information often results directly from you when applying for our services. If we need to verify Information or need additional Information, we may obtain Information from third parties such as adult family members, employers, other insurers, consumer reporting agencies, physicians, hospitals and other medical personnel. Information collected may relate to your finances, employment, health, avocations or other personal characteristics as well as transactions with us or with others. Any information collected is used solely for the purpose of providing services to you.

C. How We Use Information

We may generally collect and use Information without your permission (known as authorization) when performing or running our services for you, as necessary for the conduct of general business management, payment or administration activities, or where disclosure is required by law or in response to a court or administrative order, subpoena, discovery request, or other lawful process or other purposes as set forth below in more detail.

II. Uses and Disclosures of Protected Health Information

The privacy rules generally allow the use and disclose to others of Protected Health Information without your permission for purposes of health care Treatment, Payment activities, and Health Care Operations. Some examples of this use and disclose are as follows:

1. Payment. We may use and disclose Protected Health Information to obtain payment of premiums/fees, provide reimbursements and to make eligibility determinations and review services for medical necessity or appropriateness, utilization management activities, claims management, and billing; as well as “behind the scenes” plan functions such as risk adjustment, collection, or reinsurance.

2. Health Care Operations. We may use and disclose Protected Health Information to perform our services which may consist of to do business planning, provide customer service and conduct quality assessment and improvement activities as well as vendor evaluations, credentialing, training, accreditation activities, underwriting, premium rating, arranging for medical review and audit activities, and business planning and development.

3. Treatment. We may disclose Protected Health Information, such as your medical information, to a health care provider for coordinating, or managing health care or your medical treatment including coordination or management of care between a provider and a third party, and consultation and referrals between providers.

The amount of health information used or disclosed will be limited to the “Minimum Necessary” for these purposes, as defined.

III. Other Allowable Uses and Disclosures

In certain cases, your Protected Health Information can be disclosed without authorization to a family member, close friend, or other person you identify who is involved in your care or payment for your care. Information describing your location, general condition, or death may be provided to a similar person (or to a public or private entity authorized to assist in disaster relief efforts). You’ll generally be given the chance to agree or object to these disclosures (although exceptions may be made, for example if you’re not present or if you’re incapacitated). In addition, your health information may be disclosed without authorization to your legal representative.

The Plan also is allowed to use or disclose your health information without your written authorization, as follows

A. As Required by Law. Use or disclose Protected Health Information when required to do so by applicable international, federal, state or local law.

B. Business Associates. Disclose Protected Health Information to our business associates that perform functions or services on our behalf, if the information is necessary for such functions or services. All of our Business Associates are contractually obligated, to protect the privacy of such Information and are not allowed to use or disclose any Information other than as specified.

C. Prevention of Serious Threat; Public Health Activities. We may disclose, in good faith, Protected Health Information to (1) prevent or lessen a serious and imminent threat to public or personal health or safety, if made to someone reasonably able to prevent or lessen the threat; (2) report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (3) to report child or elder abuse or neglect to the government authority authorized by law to receive such reports; and (3) to alert to the Food and Drug Administration to collect or report adverse events or product defects.

D. Victims of Abuse, Neglect or Domestic Violence. We may disclose Protected Health Information if we reasonably believe you are a victim of abuse, neglect or domestic violence to the appropriate state agency as required or permitted by applicable state law.

E. Health Oversight Activities. We may disclose Your Protected Health Information to a government agency that oversees the health care system or ensures compliance with the rules of government health programs such as Medicare or Medicaid for which health information is relevant to beneficiary eligibility, and compliance with regulatory programs or civil rights laws.

F. Judicial and Administrative Proceedings. We may disclose Protected Health Information in the course of a judicial or administrative proceeding in response to a legal order or other lawful process.

G. Law Enforcement Officials. We may disclose Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order or other lawful process or to identify a suspect, fugitive, witness, or missing person.

H. Specialized Government Functions. We may disclose Protected Health Information to units of the government with special functions, such as any branch of the U.S. military or the U.S. Department of State about individuals who are Armed Forces personnel or foreign military personnel under appropriate military command.

I. Workers’ Compensation. We may release Protected Health Information for workers’ compensation or similar programs. These programs provide benefits for work-related injuries or illness without regard to fault, as authorized by and necessary to comply with such laws.

J. Research. We may use or disclose Protected Health Information, subject to approval by institutional or private privacy review boards, for purposes of research and subject to certain assurances and representations by researchers regarding necessity of using your health information and treatment of the information during a research project.

K. Decedents: Disclosures to a coroner or medical examiner to identify the deceased or determine cause of death; and to funeral directors to carry out their duties.

L. Organ, eye, or tissue donation: Disclosures to organ procurement organizations or other entities to facilitate organ, eye, or tissue donation and transplantation after death.

IV. Your Individual Rights

You have the following rights with respect to your Protected Health Information, subject to certain limitations, as discussed below. This section of the notice describes how you may exercise each individual right. See the contact information at the end of this notice for information on how to submit requests.

A. Right to Request Additional Restrictions. You may request restrictions on our use and disclosure of Protected Health Information for treatment, payment and health care operations, except for uses or disclosures required by law. While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction. If we do agree, a restriction may later be terminated by your written request, by agreement between you and us (including an oral agreement), or unilaterally by us for health information created or received after you’re notified that we have removed the restrictions. If you wish to request additional restrictions, your request must be in writing and must be specific regarding the limits you want to apply and to whom they should apply. You may obtain and submit such a request form from our Privacy Office as set forth below.

B. Right to Receive Confidential Communications. If you think that disclosure of Protected Health Information by the usual means could endanger you in some way, we accommodate any reasonable request for you to receive Your Protected Health Information by alternative means of communication or at alternative locations. Any such request must be in writing.

C. Right to Inspect and Copy Your Information. You may request access to or inspect and request copies of your Protected Health Information in a “Designated Record Set.” This may include medical and billing records maintained for a health care provider; enrollment, payment, claims adjudication, and case or medical management record systems maintained by a plan; or a group of records the Plan uses to make decisions about individuals. You do not have a right to inspect or obtain copies of psychotherapy notes or information compiled for civil, criminal, or administrative proceedings, in which case, we may deny you access to a portion of your records. Any such request must be in writing. We may also provide you with a summary or explanation of such Information instead of access to or copies thereof, subject to reasonable fees for copies or postage.

D. Right to Amend Your Records. You have the right to request that we amend Protected Health Information maintained in a “Designated Record Set.” We will comply with your request unless special circumstances apply, such as the Information is accurate and complete, was not created by us (unless the person or entity that created the information is no longer available), is not part of the Designated Record Set, or is not available for inspection (as described above). If your physician or other health care provider created the information that you desire to amend, you should contact the provider to amend the information. Any such request must be in writing.

E. Right to Receive an Accounting of Disclosures. Upon written request, you have the right to receive an accounting of certain disclosures of your Protected Health Information made by us during the six years prior to your request. This accounting will not include disclosures of information made: (i) for treatment, payment, and health care operations purposes; (ii) to you or pursuant to your authorization; and (iii) to correctional institutions or law enforcement officials; and (iv) other disclosures for which federal law does not require us to provide an accounting. If you request an accounting more than once during a twelve (12) month period, we may charge you per page to complete the requested accounting. You’ll be notified of the fee in advance and have the opportunity to change or revoke your request. The right to an accounting of disclosures to a health oversight agency or law enforcement official may be suspended at the request of the agency or official.

F. Right to Receive Paper Copy of this Notice. Upon request, you may obtain a paper copy of this Notice.

V. Right to Change Terms of this Notice.

We may change the terms of this Notice at any time. If we change this Notice, we may make the new notice terms effective for all of Your Information that we maintain, including any information we created or received prior to issuing the new notice. If we change this Notice. We will post any new notice on our Internet site at: www.chcsservices.com, you also may obtain any new notice by contacting the Privacy Officer.

VI. Complaints.

If you desire further information about your privacy rights, or are concerned that your privacy rights have been violated, you may contact use as set forth herein or the Secretary of the U.S. Department of Health and Human Services. Upon request, we will provide you with the correct address for the Secretary. We will not retaliate against you if you file a complaint with us or the Secretary. All complaints must be filed within 180 days of when you first knew or should have known of the alleged violation.

VII. Contact

For additional information. In addition to any other Privacy Notice we may provide, federal law establishes privacy standards and requires us to make this privacy policy readily available to you. You may have additional rights under applicable laws. For additional Information regarding our Privacy Policies, please write to us.

You may contact the Privacy Office at:

CHCS Services Inc.
Rebecca Tedjeske, Privacy Officer
411 North Baylen Street
Pensacola, FL 32501

E-mail: Privacy.ig@capgemini.com


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