Notice of Privacy Practices
|University of Arkansas at Little Rock|
|Policy Name: Notice of Privacy Practices|
|Policy Number: 2___|
This notice of Privacy Practices describes how the University of Arkansas Health and Dental Plans may collect, use and disclose your protected health information, and your rights concerning your protected health information.
“Protected health information” (PHI) is information about you, including demographic information
collected from you, that can reasonably be used to identify you and that relates to your past,
present or future physical or mental health or condition, the provision of health care to you or the
payment for that care.
We are required to maintain the privacy of your protected health information and to provide you
this notice about our legal duties and privacy practices. We must follow the privacy practices
described in this notice while it is in effect. This notice takes effect April 14, 2003, and will
remain in effect until replaced, modified, or amended.
USES AND DISCLOSURES OF PROTECTED HEALTH INFORMATION
Uses and Disclosures for Payment and Health Care Operations. The University of Arkansas
Health and Dental Plans do not disclose Protected Health Information unless required by law.
However, we do use Protected Health Information for payment and for health care operations.
Payment: We will use your protected health information to administer your health benefits
policy or contract, which may involve the determination of eligibility; claims payment; utilization
review and care management; medical necessity review; coordination of care, benefits and other
services; and responding to complaints, appeals and external review requests. We may also use
protected health information for purposes of premium billing, and the determination of premium
rates and co-payments, deductibles, co-insurance and other cost sharing amounts.
Health Care Operations: We will use your protected health information to support other business
activities, including the following:
• Health claims analysis.
• Premium determination and administration of reinsurance.
• Risk management.
• Transfer of eligibility and plan information to business associates (for example, Pharmacy Benefit Management -PBM’s- for the management of pharmacy benefits).
• Other general administrative activities, including data and information systems management and customer service.
We will not disclose protected health information to any University of Arkansas employee unless
required by law. We will, however, provide minimal protected information necessary to allow
payroll to pay the monthly premium for your group health enrollment (for example, name,
identification number, and family coverage status).
Other Permitted or Required Uses and Disclosures of Protected Health Information.
The University of Arkansas Health and Dental Plans will not disclose Protected Health
Information unless required by law. We may disclose your protected health information in the
following additional situations without your authorization:
Others Involved in Your Healthcare: Unless you request Restriction or Confidential
Communication, we may disclose to your spouse (or your parent if you are a dependent child),
the Protected Health Information directly related to payment for health care services. Otherwise,
we will not disclose your Protected Health Information regarding health care to your spouse, your
family (except for parents of dependents covered under the plan), a relative, a close friend, or any
other person without your signed authorization explicitly directing us to do so. If you are present
for such a disclosure (whether in person or on a telephone call), we will either seek your verbal
agreement to the disclosure or provide you an opportunity to object to it. We may also make such
disclosures to the persons described above in situations where you are not present or you are
unable to agree or object to the disclosure, if we determine that the disclosure is in your best
interest. We may also disclose your protected health information to an authorized public or
private entity to assist in disaster relief efforts.
Unless our administrator (QualChoice/QCA or Delta Dental) is given an alternative address, your
explanation of benefits forms and other mailings containing protected health information will be
sent to the address on record for the subscriber of the health benefits plan. Separate mailings for
enrolled dependents of the subscriber will not be done, unless requested through the administrator
by Confidential Communications described in this notice. If available, this also pertains to the
claims information contained electronically and available via secured Internet access and
corresponding telephonic claims sites.
If you would not like us to share any information in any of the foregoing manners with any
particular individuals or organizations, please call the appropriate number listed on page 4 of this
REQUIRED BY LAW
We may use or disclose your protected health information to the extent we are required to do so
Public Health: We may disclose your protected health information to an authorized public health
authority for purposes of public health activities. The information may be disclosed for such
reasons as controlling disease, injury or disability. In addition, we may make disclosures to a
person or company required by the Food and Drug Administration to report adverse events,
product defects or problems, track products; to enable product recalls; to make repairs or
replacements, or to conduct post marketing surveillance, as required.
Abuse or Neglect. We may make disclosures to government authorities concerning abuse, neglect
or domestic violence.
Health Oversight: We may disclose your protected health information to a government agency
authorized to oversee the healthcare system or government programs, or its contractors (e.g., state
insurance department, U.S. Department of Labor) for activities authorized by law, such as audits,
examinations, investigations, inspections and licensure activity.
Legal Proceedings: We may disclose your protected health information in the course of any legal
proceeding, in response to an order of a court or administrative tribunal and, in certain cases, in
response to a subpoena, discovery request or other lawful process.
Law Enforcement: We may disclose your protected health information under limited\
circumstances to law enforcement officials. For example, disclosures may be made in response to
a warrant or subpoena or for the purpose of identifying or locating a suspect, witness or missing
persons or to provide information concerning victims of crimes.
Coroners, Funeral Directors and Organ Donation: We may disclose your protected health
information in certain instances to coroners, funeral directors and in connection with organ
Research: We may disclose your protected health information to researchers, provided that
certain established measures are taken to protect your privacy.
Threat to Health or Safety: We may disclose your protected health information to the extent
necessary to avert a serious and imminent threat to your health or safety or to the health or
safety of others.
Military Activity and National Security: We may disclose your protected health information to
Armed Forces personnel under certain circumstances and to authorized federal officials for the
conduct of national security and intelligence activities.
Correctional Institutions: If you are an inmate in a correctional facility, we may disclose your
protected health information to the correctional facility for certain purposes, including the
provision of health care to you or the health and safety of you or others.
Workers’ Compensation: We may disclose your protected health information to the extent
required by workers’ compensation laws.
Uses and Disclosures of Protected Health Information with an Authorization. Other uses and
disclosures of protected health information will be made only with your written authorization,
unless otherwise permitted or required by law. You may revoke this authorization, at any time, in
writing, except to the extent that we have taken an action in reliance on the use or disclosure
indicated in the authorization being revoked.
Many members ask us to disclose their protected health information to third parties for reasons not
described in this notice. For example, elderly members often ask us to make their records
available to caregivers. The administrator of the group Health and Dental Plans maintains this
information. To authorize us to disclose any of your protected health information to a person or
organization for reasons other than those described in this notice, please call the appropriate
number listed on page 4 of this document and you will be provided the appropriate authorization
and address to submit the form. You may revoke the authorization at any time by sending a letter
to the same address. Please include your name, address, member identification number and a
telephone number where we can reach you.
Right to Request Restrictions: You have the right to ask us to place restrictions on the way
we use or disclose your protected health information for treatment, payment or healthcare
operations or as described in the section of this notice entitled “Others Involved in Your
Healthcare.” However, we are not required to agree to these restrictions. If we do agree to a
restriction, we may not use or disclose your protected health information in violation of that
restriction, unless it is needed for an emergency. All requests for restrictions should be
submitted to the administrator of our group Health and/or Dental Plans.
Confidential Communications: We will accommodate reasonable requests to communicate
with you about your protected health information by alternative means or to alternative
locations. For example, if you are covered under a Health and/or Dental Plan as an adult
dependent (e.g., a spouse or a child attending college) and you want us to send
correspondence that contains protected health information to a different address from the
subscriber we can accommodate that request. We may ask you to make your confidential
communication request in writing. All requests for confidential communications should be
submitted to the administrator of our group Health and/or Dental Plans.
Access to Protected Health Information: You have the right to receive a copy of protected
health information about you that is contained in a “designated record set”, with some
specified exceptions. A “designated record set” means a group of records that are used by or
for us to make decisions about you, including enrollment, payment, claims adjudication and
case or medical management records. Any request to access protected health information
should be directed to the administrator of our group Health and/or Dental Plans. You may be
asked to request access to copies of your records in writing and to provide the specific
information needed to fulfill your request. We reserve the right to charge a reasonable fee for
the cost of producing and mailing the copies. More information on our fee structure is
available by contacting our group Health and Dental Plan administrators at the addresses
Amendment of Protected Health Information: You have the right to ask us to amend any
protected health information about you that is contained in a “designated record set” (see above).
All requests for amendment must be in writing to our group Health and/or Dental Plan
administrators. In certain cases, we may deny your request. For example, we may deny a request
if we did not create the information, as is often the case for medical information in our records.
All denials will be made in writing. You may respond by filing a written statement of
disagreement with us, and we would have the right to rebut that statement. If you believe
someone has received inaccurate protected health information from us, you should inform us at
the time of the request if you want him or her to be informed of the amendment.
Accounting of Certain Disclosures: You have the right to have us provide you an accounting of
times when we have disclosed your protected health information for any purpose other than the
following: (a) payment or health care operations; (b) as described in the section of this notice
entitled “Others Involved in Your Healthcare”; (c) disclosures that you or your personal
representative has authorized; or (d) certain other disclosures, such as disclosures for national
security purposes. All requests for an accounting must be in writing to the administrator of our
group Health and Dental Plans. We will require you to provide us the specific information we
need to fulfill your request. This accounting requirement applies for six years from the date of
the disclosure, beginning with disclosures occurring after April 14, 2003. If you request this
accounting more than once in a 12-month period, we may charge you a reasonable fee. More
information is available on our fee structure by contacting us at the address provided below.
Contact Information for Exercising Member Rights: You may exercise any of the rights
described above by contacting, in writing, the Privacy Official at the following addresses.
University of Arkansas Group Health & Dental Plans
University of Arkansas System Administration
Benefit and Risk Management Services
2404 North University Avenue
Little Rock, AR 72207
Group Health Plan Administrator
Customer Service Department
10825 Financial Centre Parkway, Suite 400
Little Rock, AR 72211
Group Dental Plan Administrator
Delta Dental Customer Service Department
North Little Rock, AR 72231
CHANGES TO PRIVACY PRACTICES
We may change the terms of our notice at any time. The new notice will be effective for all protected health information that we maintain. We redistribute a new Notice of Privacy Practices whenever we make a material change in our privacy practices described in our notice.
QUESTIONS AND COMPLAINTS
If you have any questions about this notice or would like an additional copy of the notice, please contact the University of Arkansas Group Health and Dental Plans Privacy Office at the above number or your campus Human Resources/Personnel Office.
If you are concerned that your privacy rights may have been violated, please follow the complaint procedures described in your plan documents or on our website. You also have the right to complain to the Secretary of Health and Human Services. We will not retaliate against you for filing a complaint. If you have any questions about the complaint process, including the address of the Secretary of Health and Human Services, contact the University of Arkansas Health and/or Dental Plans Privacy Offices at the above numbers or your campus Human Resources/Personnel Office.
Source: UA System Policy
Custodian: UA System Benefits & Risk Management