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WILLSCOT MOBILE MINI HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (HIPAA) PRIVACY NOTICE
Please carefully review this notice. It describes how medical information about you may be used and disclosed and how you can get access to this information.
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) imposes numerous requirements on the use and disclosure of individual health information by WillScot Mobile Mini health plans. This information, known as protected health information, includes almost all individually identifiable health information held by a plan — whether received in writing, in an electronic medium or as an oral communication. This notice describes the privacy practices of these plans: Aetna $1,500 Deductible Plan, Aetna $3,000 Deductible Plan and Metlife Dental Plans. The plans covered by this notice may share health information with each other to carry out treatment, payment or healthcare operations. These plans are collectively referred to as the Plan in this notice, unless specified otherwise.
THE PLAN’S DUTIES WITH RESPECT TO HEALTH INFORMATION ABOUT YOU
he Plan is required by law to maintain the privacy of your health information and to provide you with this notice of the Plan’s legal duties and privacy practices with respect to your health information. If you participate in an insured plan option, you will receive a notice directly from the Insurer. It’s important to note that these rules apply to the Plan, not WillScot Mobile Mini as an employer — that’s the way the HIPAA rules work. Different policies may apply to other WillScot Mobile Mini programs or to data unrelated to the Plan.
HOW THE PLAN MAY USE OR DISCLOSE YOUR HEALTH INFORMATION
The privacy rules generally allow the use and disclosure of your health information without your permission (known as an authorization) for purposes of healthcare treatment, payment activities and healthcare operations. Here are some examples of what that might entail:
• Treatmentincludesproviding,coordinating,ormanaginghealthcarebyoneormorehealthcareprovidersordoctors.Treatmentcanalso include coordination or management of care between a provider and a third party, and consultation and referrals between providers. For example, the Plan may share your health information with physicians who are treating you.
• PaymentincludesactivitiesbythisPlan,otherplans,orproviderstoobtainpremiums,makecoveragedeterminations,andprovide reimbursement for healthcare. This can include determining eligibility, reviewing services for medical necessity or appropriateness, engaging in utilization management activities, claims management, and billing; as well as performing “behind the scenes” plan functions, such as risk adjustment, collection or reinsurance. For example, the Plan may share information about your coverage or the expenses you have incurred with another health plan to coordinate payment of benefits.
• HealthcareoperationsincludeactivitiesbythisPlan(and,inlimitedcircumstances,byotherplansorproviders),suchaswellnessandrisk assessment programs, quality assessment and improvement activities, customer service and internal grievance resolution. Healthcare operations also include evaluating vendors; engaging in credentialing, training and accreditation activities; performing underwriting or premium rating; arranging for medical review and audit activities; and conducting business planning and development. For example, the Plan may use information about your claims to audit the third parties that approve payment for Plan benefits.
The amount of health information used, disclosed or requested will be limited and, when needed, restricted to the minimum necessary to accomplish the intended purposes, as defined under the HIPAA rules. If the Plan uses or discloses Personal Health Information (PHI) for underwriting purposes, the Plan will not use or disclose PHI that is your genetic information for such purposes.
HOW THE PLAN MAY SHARE YOUR HEALTH INFORMATION WITH WILLSCOT MOBILE MINI
The Plan, or its health insurer or Health Maintenance Organization (HMO), may disclose your health information without your written authorization to WillScot Mobile Mini for plan administration purposes. WillScot Mobile Mini may need your health information to administer benefits under the Plan. WillScot Mobile Mini agrees not to use or disclose your health information other than as permitted or required by the Plan documents and by law. HR Business Partner or Benefits Department are the only WillScot Mobile Mini employees who will have access to your health information for plan administration functions.
Here’s how additional information may be shared between the Plan and WillScot Mobile Mini, as allowed under the HIPAA rules:
• ThePlan,oritsinsurerorHMO,maydisclose“summaryhealthinformation”toWillScotMobileMini,ifrequested,forpurposesofobtaining premium bids to provide coverage under the Plan or for modifying, amending, or terminating the Plan. Summary health information is information that summarizes participants’ claims information, from which names and other identifying information have been removed.
• ThePlan,oritsinsurerorHMO,maydisclosetoWillScotMobileMiniinformationonwhetheranindividualisparticipatinginthePlanorhas enrolled or disenrolled in an insurance option or HMO offered by the Plan.
In addition, you should know that WillScot Mobile Mini cannot and will not use health information obtained from the Plan for any employment- related actions. However, health information collected by WillScot Mobile Mini from other sources — for example, under the Family and Medical Leave Act, Americans with Disabilities Act, or workers’ compensation programs — is not protected under HIPAA (although this type of information may be protected under other federal or state laws).
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