Effective April 14, 2003
Revised February 7, 2005

Important Information About Privacy...
HAP works to protect the privacy of your personal and health information. We are required by law to maintain the privacy of your personal and health information and to provide individuals with notice of our legal duties and privacy practices. This notice explains how we use information about you and when we can share that information with others. It also informs you about your rights with respect to your personal and health information and how you can exercise those rights. We are required to abide by the terms of this notice.

When we use the term “member information” or “information” in this notice, we are referring to the personal and health information about you that we collect when you fill out enrollment and other forms or when you obtain our services. We maintain this information and use it to provide services to you and to operate HAP.

When we use the term “HAP”, “we” or “us” in this notice, we are referring to Health Alliance Plan and its subsidiaries, Alliance Health and Life Insurance Company and HAP Preferred.

Internally, we protect your oral, written and electronic information by requiring employees and others with access to such information to follow specific confidentiality and technology usage policies. When they begin working for HAP, all employees and contractors must sign an acknowledgement of HAP’s policies, affirming that member information will be protected, and that such protection continues even after the employee or contractor leaves HAP. An employee or contractor’s use of protected information is limited to the minimum amount of information necessary to perform a legitimate job function. Employees and contractors also are required to comply with this privacy notice, and may not use or disclose your information except as described in this notice.

Using and Disclosing Member Information for Treatment, Payment and Health Care Operations
HAP may use and share the member information we collect for treatment, payment and health care operations. For example, treatment, payment and health care operations include enrollment, underwriting, care management, quality improvement, billing, claims payment, customer services, quality assurance, utilization management, licensing, credentialing and accreditation. We share your member information with affiliated companies as permitted by law, non-affiliated third parties with whom we contract to help us operate HAP, and with others who are involved in providing or paying for health care services for you. The following ways we may use or share member information about you for treatment, payment or health care operations:

• We may use or share your member information to help us determine who is financially responsible for your medical bills.
   
• We may share your member information with your doctors or hospitals to help them provide medical care to you. For example, if you are in the hospital, we may give them access to any medical records sent to us by your doctor.
   
• We may use or share your member information with others to help manage your health care. For example, we might talk to your doctor to suggest a disease management or wellness program that could help improve your health.
   
• We may share your information with others who help us conduct our business operations.
   
• We may use or share your member information for certain types of public health or disaster relief efforts.
   
• We may use or share your member information to send you a reminder if you have an appointment with your doctor.
   
• We may use or share your information to give you information about alternative medical treatments and programs or about health related products and services that you may be interested in. For example, we might send you information about smoking cessation or weight loss programs.
   
• We may use or share your information with an employee benefit plan through which you receive health benefits. Except for enrollment information or summary health information and as otherwise required by law, we will not share your information with an employer or plan sponsor, unless the employer or plan sponsor has provided us with written assurances that the information will be kept confidential and will not be used for an improper purpose.
   
• We may use or share your member information in limited circumstances for research purposes. For example, a research organization may wish to compare outcomes of all patients that receive a particular drug and will need to review a series of medical records. In all cases where your specific authorization has not been obtained, your privacy will be protected by strict confidentiality requirements applied by an institutional review board or privacy board, which oversees the research, or by representations of the researchers that limit their use and disclosure.
   
• We may release your member information to a friend or family member who is authorized by law to act on your behalf. We may also give your member information to someone who helps pay for your care.

Using and Disclosing Member Information for Other Purposes
There are also state and federal laws that require us to release your member information to others in some of the following situations:

• We may report information to state and federal agencies that regulate us, such as the US Department of Health and Human Services and the Michigan Office of Financial and Insurance Services.
   
• We may share information for public health activities, such as for reporting disease, injury, birth and death, and for required public health investigations. For example, we may report information to the Food and Drug Administration if necessary to report adverse events, product defects or for product recalls.
   
• We may report information to public health agencies if we believe there is a serious health or safety threat.
   
• We may share information with a health oversight agency for certain oversight activities (for example, audits, inspections, licensure, and disciplinary actions.)
   
• We may provide information to a court or administrative agency (for example, pursuant to a court order, search warrant, subpoena or discovery request).
   
• We may report information for law enforcement purposes.
   
• We may report information to a government authority regarding abuse, neglect or domestic violence.
   
• We may share information with a coroner or medical examiner to identify a deceased person, determine a cause of death, or as authorized by law. We may also share member information with funeral directors as necessary to carry out their duties.
   
• We may use or share information for procurement, banking or transplantation of organs, eyes or tissue.
   
• We may share information relative to specialized government functions, such as military and veteran activities, national security and intelligence activities, and protective services for the President and others.
   
• We may report information on job-related injuries because of requirements of your state worker compensation laws.

If one of the above reasons does not apply, we must get your written permission to use or disclose your member information. If you give us written permission and change your mind you may revoke your written permission at any time. The revocation will not apply to any information we have already disclosed. Your request to exercise any of the above member rights must be in writing and be signed by you or your representative. We may ask you to complete a form when making a request. Once you give us authorization to release your member information, we cannot guarantee that the person to whom the information is provided will not disclose the information.

Your Member Rights
The following are your rights with respect to your member information. If you would like to exercise the following rights, please contact us as described below, under “Who to Contact”.

• You have the right to ask us to restrict how we use or disclose your member information for treatment, payment, or health care operations. You also have the right to ask us to restrict member information that we have been asked to give to family members or to others who are involved in your health care or payment for your health care. Please note that we are not required to agree to these restrictions.
   
• You have the right to ask to receive confidential communications of information. For example, if you believe that you would be harmed if we send your information to your current mailing address (for example in situations involving domestic disputes or violence), you can ask us to send the information by alternative means, for example, by fax or to an alternative address. We will try to accommodate reasonable requests.
   
• You have the right to inspect and obtain a copy of member information that we maintain about you. We may deny your request to inspect and copy your member information in certain, limited circumstances. For example, we may deny your request if review of the records could endanger you or another person. We may charge you a fee for copies. We will inform you in advance of the fee and provide you with an opportunity to withdraw or modify your request.
   
• You have the right to ask us to amend member information we maintain about you. We will require that the information be accurate. Please note that we are not required to agree to a request to amend.
   
• You have the right to receive an accounting of certain disclosures of your member information made by us during the six years prior to your request. Please note that we are not required to provide you with an accounting of all disclosures we make. For example, we are not required to provide you with an accounting of member information collected prior to April 14, 2003; information disclosed or used for treatment, payment, and health care operations purposes; or information disclosed to you or pursuant to your authorization.
   
  Your first accounting in any 12-month period is free. However, if you request an additional accounting within 12 months of receiving your free accounting, we may charge you a fee. We will inform you in advance of the fee and provide you with an opportunity to withdraw or modify your request.
   
• You have a right to receive a paper copy of this notice upon request at any time.

Your request to exercise any of the above member rights must be in writing and be signed by you or your representative. We may ask you to complete a form when making a request.

Changes to this Privacy Statement
We may from time-to-time change the contents of this notice and reserve the right to do so. If we do so the new notice will be effective for all the member information maintained by us. Once revised, we will provide the new notice to you by mail and post it on our website.

Who to Contact
If you have any questions about this notice or about how we use or share member information, you may contact the HAP Privacy Officer by mail at: 2850 West Grand Blvd, Detroit, MI 48202. You may also call us at (313) 872-8100 or 1-800-422-4641 or send us an e-mail by clicking “Contact HAP” at the top of the page on HAP’s website (www.hap.org).

Complaints
If you believe your privacy rights have been violated, you may file a complaint with us by contacting the Privacy Officer as noted above, or filing a grievance with the Client Services Department. You may also notify the Secretary of the U.S. Department of Health and Human Services of your complaint. We will not take any action against you for filing a complaint.

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©2006 Health Alliance Plan of Michigan

HGMA204

H2312_H2322_1 March 2, 2006