At Texas Professional Healthcare Alliance, we take responsibility to protect the privacy of individually identifiable health information of our Members and our Members patients very seriously. We have and will continue to review and update our practices in relation to HIPAA Privacy Regulations by:
· On-going training for our leadership and subcontractors,
· Establishing safeguards for the protection of individually health identifiable information,
· Ensuring access to information only as permitted by law.
NOTICE OF PRIVACY PRACTICES

THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION MAY BE USED AND DISCLOSED
Effective: April 14, 2003

TPHA will protect the privacy of our Members and Members patients (herein after “Individual(s)”) health information. TPHA will explain how we may use information and when we can give out or "disclose" that information to others. Individuals have rights regarding their health information described in this notice.

The terms “information” or “health information” in this notice include any personal information that is created or received by a health care provider or health plan that relates to physical or mental health or condition, the provision of health care rendered, or the payment for such health care.

TPHA has the right to change our privacy practices. If we do, changes will be reflected here.

HOW WE USE OR DISCLOSE INFORMATION

We must use and disclose your health information to provide information:
§ Individuals or someone who has the legal right to act for them. (personal representative);
§ To the Secretary of the Department of Health and Human Services, if necessary, to ensure privacy is protected; and
§ Where required by law.
We have the right to use and disclose health information to pay for Individuals health care and operate our business. For example, we may use an individual’s health information:
§ For Payment of fees due us and to aid our Members in the processing of claims for health care services received.
§ For Health Care Operations. We may use or disclose health information as necessary to operate and manage our business and to help manage Individuals health care coverage.
§ To Provide Information on Health Related Programs or Products such as alternative medical treatments and programs or about health related products and services.
§ To Plan Sponsors. If individual’s coverage is through an employer group health plan, we may share summary health information and enrollment and disenrollment information with the plan sponsor. In addition, we may share other health information with the plan sponsor for plan administration if the plan sponsor agrees to special restriction on its use and disclosure of the information.
We may use or disclose health information for the following purposes under limited circumstances:
§ To Persons Involved With Individuals Care. We may use or disclose an Individuals health information to a person involved in Individuals care, such as a family member, when Individual is incapacitated or in an emergency, or when permitted by law.
§ For Public Health Activities such as reporting disease outbreaks.
§ For Health Oversight Activities such as governmental audits and fraud and abuse investigations.
§ For Judicial or Administrative Proceedings such as in response to a court order, search warrant or subpoena.
§ For Law Enforcement Purposes such as providing limited information to locate a missing person.
§ To Avoid a Serious Threat to Health or Safety by, for example, disclosing information to public health agencies.
§ For Specialized Government Functions such as military and veteran activities, national security and intelligence activities, and the protective services for the President and others.
§ To Provide Information Regarding Decedents. We may disclose information to a coroner or medical examiner to identify a deceased person, determine a cause of death, or as authorized by law. We may also disclose information to funeral directors as necessary to carry out their duties.
If a use or disclosure of health information is prohibited or materially limited by other applicable law, it is our intent to meet the requirements of the more stringent law. In some states, authorization may also be required for disclosure of health information. In many states, authorization may be required in order for us to disclose highly confidential health information, as described below. Once we receive authorization to release health information, we cannot guarantee that the person to whom the information is provided will not disclose the information. Individuals may take back or "revoke" written authorization, except if we have already acted based on authorization. To revoke an authorization, contact us at 713-344-2401.

HIGHLY CONFIDENTIAL INFORMATION
Federal and applicable state laws may require special privacy protections for highly confidential information. “Highly confidential information” may include confidential information under Federal law governing alcohol and drug abuse information as well as state laws that often protect the following types of information:
1. HIV/AIDS;
2. Mental health;
3. Genetic tests;
4. Alcohol and drug abuse;
5. Sexually transmitted diseases and reproductive health information; and
6. Child or adult abuse or neglect, including sexual assault.
The following are rights with respect to health information.
§ Individual has the right to ask to restrict uses or disclosures of information for treatment, payment, or health care operations. They have the right to ask to restrict disclosures to family members or to others who are involved in their health care or payment for health care. We may also have policies on dependent access that may authorize certain restrictions.
§ Individual has the right to ask to receive confidential communications of information in a different manner or at a different place (for example, by sending information to a P.O. box instead of your home address).
§ Individual has the right to see and obtain a copy of health information that may be used to make decisions about claims and case or medical management records. They may make a written request to inspect and copy their health information.
§ Individual has the right to ask to amend information we maintain about them if they believe the health information about them is wrong or incomplete. If we deny their request, they may have a statement of our disagreement added to their health information.
§ Individual has the right to receive an accounting of disclosures of information made by us during the six years prior to their request. This accounting will not include disclosures of information: (i) made prior to April 14, 2003; (ii) for treatment, payment, and health care operations purposes; (iii) to them or pursuant to their authorization; and (iv) to correctional institutions or law enforcement officials; and (v) other disclosures that federal law does not require us to provide an accounting.
§ Individual has the right to a paper copy of this notice. They may ask for a copy of this notice at any time. Even if they have agreed to receive this notice electronically, they are still entitled to a paper copy of this notice.

EXERCISING INDIVIDUALS RIGHTS
§ Contact Us. Any questions about this notice or should an individual want to exercise any of their rights, please call us at 713-344-2400.
§ Filing a Complaint. If Individual believes their privacy rights have been violated, they may file a complaint with us at the following address:

Texas Professional Healthcare Alliance, Inc.
President & CEO
PO Box 525
Santa Fe, Texas 77510

The Individual 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 individual filing a complaint.

FINANCIAL INFORMATION PRIVACY NOTICE
Effective April 14, 2003
We are committed to maintaining the confidentiality of personal financial information. For the purposes of this notice, “personal financial information” means information, other than health information, about an Individual that identifies the individual, not generally publicly available and is collected from the individual or is obtained in connection with providing health care coverage to the individual. We collect personal financial information about Individuals from the following sources:
§ Information we receive on applications or other forms, such as name, address, age and social security
§ Information about transactions with our affiliates, clients, others, such as premium payment history, financial hardship, poverty level status and the like.
We do not disclose personal financial information about Individuals to any third party, except as required or permitted by law. We restrict access to personal financial information to employees and service providers who are involved in administering health care coverage and providing services to Individual. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your personal financial information.