STRATeBEN has adopted a policy that protects the privacy and confidentiality of protected health information (PHI) whenever it is used by company representatives. The private and confidential use of such information will be the responsibility of all individuals with job duties requiring access to PHI in the course of their jobs.

PROTECTED HEALTH INFORMATION DEFINED.

PHI refers to individually identifiable health information received by the company’s group health plans or received by a health care provider, health plan, or health care clearinghouse that relates to the past or present health of an individual or to payment of health care claims. PHI information includes medical conditions, health status, claims experience, medical histories, physical examinations, genetic information, and evidence of disability.

HIPAA COMPLIANCE OFFICER.

The company has designated the Vice President of Account Management as the HIPAA compliance officer (HCO), and any questions or issues regarding PHI should be presented to the HCO for resolution. The HCO is also charged with the responsibility for:

• Issuing procedural guidelines for access for PHI.
• Developing a matrix for personnel who will need access to PHI.
• Developing guidelines for describing how and when PHI will be maintained, used, transferred, or transmitted. 

ACTIVITIES NECESSITATING THE USE OF PHI.

STRATeBEN, Inc. performs analysis, reporting, enrollment, and changes in enrollment; provides assistance in claims, problem resolution, and explanation of benefits issues; and assists in coordination of benefits with other service providers. Some or all of these activities may require the use or transmission of PHI. Thus, all information related to these processes will be maintained in confidence, and employees will not disclose PHI from these processes for employment-related actions, except as provided by administrative procedures approved by the HCO. General rules follow:

Disclosures that do not qualify as PHI-protected disclosures include:

• Disclosure of PHI to the individual to whom the PHI belongs.
• Requests by providers for treatment or payment. Disclosures requested to be made to authorized parties by the individual PHI holder.
• Disclosures to government agencies for reporting or enforcement purposes.
• Disclosures to workers’ compensation providers and those authorized by the workers’ compensation providers.
• Information regarding whether an individual is covered by a plan for claims processing purposes may be disclosed.
• Information external to the health plan is not considered PHI if the information is being furnished for claims processing purposes involving workers’ compensation or short- or long-term disability and medical information received to verify Americans with Disabilities Act (ADA) or Family and Medical Leave Act (FMLA) status.

RECORDS RETENTION.

Records and disclosures of PHI will be maintained for a period of six years as required by federal law, unless a state law requires a longer retention period. Records that have been maintained for the maximum interval will be destroyed in a manner to ensure that such data are not compromised in the future in accordance with the company record destruction policy.

CHANGES TO POLICY.

We may make changes to this policy as necessary. Questions or comments regarding this Policy should be directed to Us by clicking on the “Contact Us” tab.