Notice of privacy practices

The sections below describe the ways Priority Health uses or shares your PHI without your written authorization. Your PHI is not shared with anyone who does not have a "need to know" to perform one of the tasks below.

Treatment. Priority Health may use or share your PHI to those who are treating you to arrange and oversee your medical care. For example, we may share information about your prescription drugs to your provider to better understand how to give you medical care.

Payment. Priority Health may use your PHI or share it to third parties to collect premiums, establish eligibility or pay for your medical care. For example, we may use your PHI when we receive a claim for payment. Your claim tells us what services you received and may include a diagnosis. We may also share your PHI to another health plan company if you are covered under more than one health plan.

Health care operations. Priority Health may use or share your PHI to third parties in order to assist in Priority Health's everyday work activities, such as looking at the quality of your care, carrying out utilization review and conducting disease management programs. For example, your PHI, along with other Priority Health members' PHI, may be used by Priority Health's staff to review the quality of care given by health care providers. Priority Health may also use or share your PHI for underwriting, enrollment and other activities related to creating, renewing or replacing a health plan. Priority Health may not, however, use or share genetic information to decide whether we will give you coverage and the price of that coverage

Please note that we do not destroy your PHI when you end your coverage with us. It may be necessary to use or share your PHI for the purposes described above even after your coverage ends. Privacy policies and procedures will remain in place to protect against incorrect use or sharing of your PHI.

To you and your personal representative. We may share your PHI to you or your personal representative, who is someone that has the legal right to act on your behalf.

To others involved in your care. We may, in certain cases, share your PHI to a member of your family, a relative, a close friend or any other person you identify if they are involved in your health care or payment for health care. For example, we may discuss a claim decision with you in the presence of a friend or a relative, unless you object.

If you are not able to tell us your preference, we will share your PHI if we believe it is in your best interest. For example, we may share your PHI when you are unconscious. We may also share your PHI when needed to reduce a serious threat to health or safety.

This also applies to the Organized Health Care Arrangement (OHCA) between Priority Health and Corewell Health. Priority Health will share your PHI with Corewell Health for treatment, payment and health care operations purposes. Priority Health reserves the legal right for the organization or any individual to change participation in the OCHA between Priority Health and Corewell Health.

Priority Health is allowed or required to share your PHI in other ways that usually contribute to the public good, such as public health and research. Priority Health may also use or share your PHI:Priority Health is allowed or required to share your PHI in other ways that usually contribute to the public good, such as public health and research. Priority Health may also use or share your PHI:

• When required by law.
  • For law enforcement purposes.
  • When necessary for judicial or administrative proceedings, such as court proceedings.
  • For compliance with workers' compensation requirements, as authorized by applicable law.
  • For various government functions, such as health oversight agencies for activities authorized by law, the Armed Forces for active personnel, to Intelligence Agencies for national security and the Department of State for foreign services reasons, such as security clearance.
  • As necessary for a coroner, medical examiner, law enforcement official or funeral director to carry out their legal duties with respect to a deceased individual or to cadaveric organ, eye or tissue donation and transplant organizations.

• For matters of public interest.
  • Reporting adult abuse, neglect or domestic violence.
  • To prevent a serious threat to an individual or a community's health and safety.
  • Reporting to organ procurement and tissue donation organizations.
  • For public health and safety activities, including disease control and vital statistic reporting, child abuse reporting and Food and Drug Administration (FDA) oversight.
  • For research purposes, as long as applicable research privacy standards are met.
  • To make a collection of de-identified information, which is PHI that cannot be traced back to you.
  • From time to time, we engage with third parties, called business associates, to provide various services for us. Whenever a third party involves the use or sharing of your PHI, we will have a written contract with that third party designed to protect the privacy of your PHI. For example, we may share your PHI with business associates who process claims or conduct disease management programs on our behalf.

This section of the Notice of Privacy Practices applies only to group health plans.

Priority Health may share your PHI with the sponsor of your group health plan, usually your employer, about whether you are enrolled or disenrolled in the group health plan. Priority Health may also share summary health information with the sponsor, which is a summary of the amount, type and history of claims paid under the sponsor's group health plan with most identifying information, such as your name, age and address, except for zip code, removed. The sponsor may use this information to obtain premium bids for health plan coverage or to decide whether to modify, amend or end the plan. If the sponsor of your group health plan takes appropriate steps to comply with federal privacy regulations, Priority Health may also share your PHI with the sponsor for the sponsor's administration of the group health plan.

Priority Health may not use or share your PHI without your written authorization, except as described in this Notice. You may give us written authorization to use your PHI or to share it with anyone for any purpose. If you give us written authorization, you may take back (revoke) the written authorization at any time by notifying Priority Health's Compliance department in writing. If you revoke your written authorization, we will no longer use or share your PHI for the reasons covered by your written authorization, but it will not affect any use or sharing of your PHI permitted by the written authorization while it was in effect. We also must obtain your written authorization to sell your PHI to a third party or, in most cases, to use or share your PHI to send you communications about products and services. We do not need your written authorization, however, to send you communications about treatment alternatives, treatment reminders and health related products or services, as long as the products or services are associated with your coverage or are offered by us.

We will never sell your PHI or use or share it for marketing purposes without your written authorization.

We must receive your written authorization to share psychotherapy notes, except for certain treatment, payment or health care operations activities.

A parent, legal guardian or properly named patient advocate may represent you and provide or revoke written authorization to use or share your PHI if you are not able to. Court documents may be required to verify this authority.

The Health Insurance Portability and Accountability Act (HIPAA) generally does not preempt or override other laws that give people greater privacy protections. Therefore, if any state or federal privacy law requires us to provide you with more privacy protections, we are obligated to comply with that law in addition to HIPAA.

We have policies and procedures in place that protect the privacy of your PHI.

• Every employee receives training when they are hired and on an annual basis.
• Every employee must acknowledge that they understand they are required to keep member’s PHI private. They also learn about the actions the company will take if the privacy policies are not followed.
• Priority Health has strict control of access to electronic and paper information specific to members. Only those users authorized with a password have access to electronic information. Paper information is stored in secure locations. Access is only given to those who need it to manage care for members or for administrative purposes.

You have the following legal rights:

Legal right to inspect and copy. You have the legal right to look at and get a copy of your PHI that may be used to make decisions about your care and payment for your care as long as we maintain them. There are limited cases in which we may deny your request to inspect and copy these records. If you are denied access to your PHI, you may request that the denial be reviewed. If you request a copy of your PHI, we may charge a fee for the cost of copying, mailing and other costs regarding your request.

To inspect and copy your PHI, contact Priority Health’s Compliance department.

Legal right to correct your health and claims record. You have the legal right to request that Priority Health amend any of your PHI that we use to make decisions about you. Generally, Priority Health will not amend these records if we did not create them or we determine that they are accurate and complete. To request that we amend your PHI, you must write to Priority Health's Compliance department and include a reason to support the change.

Legal right to know an accounting of disclosures. You have the legal right to request an accounting of disclosures, which is a list of times we shared your PHI for 6 years prior to the date of your request. The accounting of disclosures will not include times when PHI was shared:

• To carry out treatment, payment or health care operations.
• To you or your personal representative.
• To anyone you have given written authorization.
• For national security or intelligence purposes.
• To correctional institutions or to law enforcement, as described in this Notice.
• As part of a limited data set, which is a collection of your PHI that does not directly identify you.

Your request should indicate in what way you want the list, such as on paper or electronically. The first list you request within 12 months will be free. We may charge you for the costs of providing additional lists. We will notify you of the cost and you can choose to withdraw or modify your request at that time before we charge you any fees.

Legal right to request restrictions. You have the legal right to request a limit on your PHI that we use or share. We are not required by law to agree to your request. If we do agree to your request for restriction, we will comply with it unless your PHI is needed to provide emergency treatment. To request restrictions, you must make your request in writing to Priority Health's Compliance department. In your request, you must tell us:

• What PHI you want to limit.
• Whether you want to limit our use, sharing or both.
• To whom you want the limits to apply.

Priority Health will notify you, either in writing or by phone, when we receive your request and of any restrictions to which we agree.

Legal right to request confidential communications. You may request that Priority Health communicate with you through other ways or a different location. For example, you might want us to send your PHI, such as Explanation of Benefits (EOB) and other claim information, to a different address. Priority Health will agree to your request if you clearly state in writing that communicating with you without using other ways or a different location could endanger you. Priority Health will accommodate your request if it is reasonable, specifies the other ways or different location and permits us to collect premiums and pay claims.

To request confidential communications, you must make your request in writing to Priority Health's Compliance department.

Legal right to a paper copy of this Notice. You have the legal right to a paper copy of Priority Health's current Notice of Privacy Practices upon request. To obtain a paper copy of this Notice, please call our Customer Service department. Otherwise, you may also print a copy of this Notice from our website.

If you believe your privacy rights have been broken, you may file a complaint with Priority Health and/or the Office for Civil Rights (OCR) at the U.S. Department of Health and Human Services (HHS). To file a complaint with Priority Health, please call or send a written explanation of the issue to Priority Health's privacy department. You will not be retaliated against for filing a complaint.

Priority Health has the following responsibilities:

• We are required by law to maintain the privacy and security of your PHI.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your PHI.
• We must follow the duties and privacy practices described in this Notice and give you a copy of it.
• We will not use or share your PHI other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

Priority Health has the right to change our privacy practices and the terms of this Notice at any time. Any changes to our Notice of Privacy Practices will be effective for all PHI that we maintain, including PHI regardless of when it was created or received. We will provide a copy of the new Notice, or information about the changes to our privacy practices and how to obtain the new Notice, in our next annual mailing to members who are then covered by one of our health plans. The new Notice will also be available upon request and posted on our website.

If you have questions about how your PHI may be used and shared and how to get access to this information, please contact Priority Health's Privacy department.

For any other questions or concerns, please contact Priority Health's Compliance department.

Priority Health Compliance department:
Priority Health Compliance department
1231 East Beltline NE
Grand Rapids, MI 49525
616.942.0954
800.942.0954

Priority Health Privacy department:

Priority Health
Chief Privacy Officer
100 Michigan Street NE
Grand Rapids, MI 49503
616.486.4113