KEY BENEFIT ADMINISTRATORS
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Privacy and Advertising Notice
Effective 10/01/2011

Table of Contents

Our Commitment to Privacy
The Information We Collect
How We Use Information
Our Commitment to Data Security
How to Access or Correct Your Information
How to Contact Us
Plan Document Disclaimer
HIPAA PRIVACY

Our Commitment to Privacy

Your privacy is important to us. To better protect your privacy, we provide this notice explaining our online information practices.

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The Information We Collect

This notice applies to all information collected or submitted on this website. When you first register on the site, you will have a temporary password. We collect your e-mail address at this point so that we can send your permanent password to your registered e-mail address.  You may immediately change your password upon re-entering the site.  This is our way of collecting and verifying your e-mail address.  If you ever forget your user ID or password, just enter your e-mail address on the front page, and we will e-mail a new ID or password to you. You may change your e-mail address at any time you have securely entered the site.

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The Way We Use Information

To provide the services offered by this site, we correlate information you may provide with information provided by your Benefit Plan and/or applicable insurance companies (those providing you coverage and/or products). With the exception of partners used in providing this site, we do not share your information with outside parties. We use return e-mail addresses to answer the e-mail we receive. These addresses are not used for any other purpose and are not shared with outside parties, except as described herein.

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Our Commitment to Data Security

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put appropriate physical, electronic, and managerial procedures in place to safeguard and secure your information.  Please verify with all dependents who are be covered by your benefit plan (Spouse and Children over age 18) that you may view their benefit plan information as that information may include Protected Health Information under HIPAA which is defined below.  Do not view any such information unless you have first obtained that permission.  Viewing such information is your acknowledgement that you have received that permission.  If a dependent Spouse or Child over the age of 18 does not wish you to view their information they may contact the Web Master and access to their information will be blocked.

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How You Can Access or Correct Your Information

At any time, you may review your personally-identifiable information we collect online and maintain by visiting your account profile area which is located within this secure site. You may also contact our customer service department to request factual corrections to your information by calling the number on the home screen or selecting the Inquiry tab and then selecting the appropriate customer service department.

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How to Contact Us

Should you have other questions or concerns about these privacy policies, please contact us by calling the number on the home screen or contacting your health plan indicated on your Member Identification Card.

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Plan Document Disclaimer

Plan Document information, when provided, is a summary of the general benefit provisions of the Plan and is not intended to be used as an authorization for services to be provided.

In accordance with your Master Plan Document or Certificate, all specific Plan exclusions and limitations will be applied to any claim submitted for consideration at the time the claim is processed. In addition, payment of benefits will be coordinated with other coverage available to the Covered Person.

In the event of a discrepancy between the summaries provided within this site and actual Plan Documents and/or policies of insurance, the actual Plan and/or policies would govern.

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HIPAA PRIVACY

COMPLIANCE WITH HIPAA PRIVACY STANDARDS. Certain members of the Employer's workforce and EZ-Benefits.com workforce ("Workforce") perform services in connection with administration of the benefit program. In order to perform these services, it is necessary for these employees from time to time to have access to Protected Health Information (as defined below).

Under the Standards for Privacy of Individually Identifiable Health Information (45 CFR Part 164, the "Privacy Standards"), this Workforce is permitted to have such access.

  1. ·General.  Workforce shall not disclose Protected Health Information to any person unless each of the conditions set out in this HIPAA Privacy section is met. "Protected Health Information" shall have the same definition as set out in the Privacy Standards but generally shall mean individually identifiable health information about the past, present or future physical or mental health or condition of an individual, including information about treatment or payment for treatment. 

  2. ·Permitted Uses and Disclosures. Protected Health Information shall be disclosed for purposes of benefit plan administrative functions. The benefit plan's administrative functions shall include all payment and health care operations to include any technical support of this site. The terms "payment" and "health care operations" shall have the same definitions as set out in the Privacy Standards, but the term "payment" generally shall mean activities taken with respect to payment of premiums or contributions, or to determine or fulfill Plan responsibilities with respect to coverage, provision of benefits, or reimbursement for health care. "Health care operations" generally shall mean activities on behalf of the Plan that are related to quality assessment; evaluation, training or accreditation of health care providers; underwriting, premium rating and other functions related to obtaining or renewing an insurance contract, including stop-loss insurance; medical review; legal services or auditing functions; or business planning, management and general administrative activities. The term "technical support of this site" shall mean any activities to move data from one place to another, program the site, host the site and provide assistance in using the site. 

  3. ·Authorized Workforce. The benefit plan shall disclose Protected Health Information only to members of the Workforce, who are designated and are authorized to receive such Protected Health Information, and only to the extent and in the minimum amount necessary for these persons to perform duties with respect to the benefit plan.  

(a) Updates Required. This document will be promptly updated and communicated with respect to any changes in the Workforce who are authorized to receive Protected Health Information.

(b) Use and Disclosure Restricted. An authorized member of the Workforce who receives Protected Health Information shall use or disclose the Protected Health Information only to the extent necessary to perform his or her duties with respect to the Plan.

(c) Resolution of Issues of Noncompliance. In the event that any member of the Workforce uses or discloses Protected Health Information other than as permitted by the Privacy Standards, the incident shall be reported to the privacy official. The privacy official shall take appropriate action, including:

(i) Investigation of the incident to determine whether the breach occurred inadvertently, through negligence, or deliberately; whether there is a pattern of breaches; and the degree of harm caused by the breach;

(ii) Applying appropriate sanctions against the persons causing the breach, which, depending upon the nature of the breach may include, oral or written reprimand, additional training, or termination of employment;

iii) Mitigating any harm caused by the breach, to the extent practicable; and

(iv) Documentation of the incident and all actions taken to resolve the issue and mitigate any damages.

 

  1. ·Certification of Workforce. The Workforce must provide certification to the benefit plan that it agrees to:  

(a) Not use or further disclose the Protected Health Information other than as permitted as required by law;

(b) Ensure that any agent or subcontractor, to whom it provides Protected Health Information received from the Plan, agrees to the same restrictions and conditions that apply to the Workforce with respect to such information;

(c) Not use or disclose Protected Health Information for employment-related actions and decisions or in connection with any other benefit or employee benefit plan;

(d) Report to the Plan any use or disclosure of the Protected Health Information of which it becomes aware that is inconsistent with the uses or disclosures permitted or required by law;

(e) Make available Protected Health Information to individual Plan members in accordance with Section 164.524 of the Privacy Standards;

(f) Make available Protected Health Information for amendment by individual Plan members and incorporate any amendments to Protected Health Information in accordance with Section 164.526 of the Privacy Standards;

(g) Make available the Protected Health Information required to provide any accounting of disclosures to individual Plan members in accordance with Section 164.528 of the Privacy Standards;

(h) Make its internal practices, books and records relating to the use and disclosure of Protected Health Information received from the Plan available to the Department of Health and Human Services for purposes of determining compliance by the Plan with the Privacy Standards;

(i) If feasible, return or destroy all Protected Health Information retained when such information is no longer needed for the purpose of which disclosure was made, except that, if such return or destruction is not feasible, limit further uses and disclosures to those purposes that make the return or destruction of the information unfeasible; and

(j) Ensure the adequate separation between the Plan and Workforce, as required by Section 164.504(f)(2)(iii) of the Privacy Standards.

 

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