This notice describes how medical information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

If you have any questions about this notice, please contact the Compliance and Quality Improvement Manager at Managed Health Care Systems, Inc. 700 Ackerman Rd., Suite 580, Columbus, OH 43202 or 614-292-5703.

WHO IS COVERED BY THIS NOTICE
The terms of this Notice of Privacy Practices applies to each group health plan (including medical, dental, vision and health care flexible spending account plans, but not including the dependent care flexible spending account) that is one of The Ohio State University Faculty and Staff Health Plans, all of which together constitute an organized health care arrangement. The organization will share personal health information of members as necessary to carry out treatment, payment, and health care operations as permitted by law.

OUR PLEDGE REGARDING YOUR PERSONAL HEALTH INFORMATION
We are required by law to maintain the privacy of our members’ personal health information and to provide members with notice of our legal duties and privacy practices with respect to your personal health information. We are required to abide by the terms of this Notice so long as it remains in effect. We reserve the right to change the terms of this Notice of Privacy Practices as necessary and to make the new Notice effective for all personal health information maintained by us. Copies of revised notices will be mailed to all members then covered by The Ohio State University Faculty and Staff Health Plans and copies may be obtained by mailing a request to Compliance and Quality Improvement Manager, Managed Health Care Systems, Inc, 700 Ackerman Road, Suite 580, Columbus, OH 43202.

USES AND DISCLOSURES OF YOUR PERSONAL HEALTH INFORMATION

Your Authorization
Except as outlined below, we will not use or disclose your personal health information for any purpose unless you have signed a form authorizing the use or disclosure. You have the right to revoke that authorization in writing for all future uses or disclosures.

Disclosures for Treatment
We will make disclosures of your personal health information as necessary for your treatment. For instance, a doctor or health facility involved in your care may request certain parts of your personal health information that we hold in order to make decisions about your care.

Uses and Disclosures for Payment
We will make uses and disclosures of your personal health information as necessary for payment purposes. For instance, we may use information regarding your medical procedures to process and pay claims, to determine whether services are medically necessary or to otherwise pre-authorize or certify services as covered under your health benefits plan. We may also forward such information to another health plan that may also have an obligation to process and pay claims on your behalf.

Uses and Disclosures for Health Care Operations
We will use and disclose your personal health information as necessary, and as permitted by law, for our health care operations which include credentialing heath care providers, peer review, business management, accreditation and licensing, quality improvement and assurance, reinsurance, compliance, auditing, rating and other functions related to your health benefits plan. We may also disclose your personal health information to another health care facility, health care professional, or health plan for things such as quality assurance and case management, but only if that facility, professional or plan also has or had a patient relationship with you and the information pertains to that relationship.

Family and Friends Involved in Your Care
With your approval, we may from time to time disclose your personal health information to designated family, friends and others who are either involved in your care or in the payment for your care. Generally, we accomplish this by requesting a person to provide specific information about your care or by requiring a written authorization from you. If you are unavailable, incapacitated, or facing an emergency medical situation, and we determine that a limited disclosure may be in your best interest, we may share limited personal health information with such individuals without your approval.

Business Associates
Certain aspects and components of our services are performed through contracts with outside persons or organizations, such as auditing, accreditation, actuarial service, claims payment, legal services, etc. At times it may be necessary for us to provide certain portions of your personal health information to one or more of these outside persons or organizations who assist us with our health care operations. In all cases, we require these business associates to appropriately safeguard the privacy of your information.

Other Health-Related Products or Services
We may from time to time use your personal health information to determine whether you might be interested in or benefit from treatment alternatives or other health-related programs, products or services which may be available to you as a member of the health plan. For example, we may use your personal health information to identify whether you have a particular illness, and contact you to advise you that a disease management program to help you better manage your illness is available to you as a health plan member. We will not use your information to communicate with you about products or services which are not health related without your written permission.

Research
In limited circumstances, we may use and disclose your personal health information for research purposes. For example, a research organization may wish to compare outcomes of patients by payer source and will need to review a series of records that we hold. 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 of member information.

Other Uses and Disclosures
We are permitted or required by law to make certain other uses and disclosures of your personal health information without your authorization.

• We may release your personal health information for any purpose required by law;
• We may communicate with you regarding your claims, premiums or other services connected with The Ohio State University Faculty and Staff Health Plans;
• We may release your personal health information for public health activities, such as required reporting of disease, injury, and birth and death, and for required public health investigations;
• We may release your personal health information to a health oversight agency for activities authorized by law;
• We may release your personal health information to a government authority authorized to receive such reports, if we suspect child abuse or neglect; we may also release your personal health information as required or permitted by law if we believe you to be a victim of abuse, neglect, or domestic violence;
• We may release your personal health information to a person subject to the jurisdiction of the Food and Drug Administration if necessary to report adverse events, product defects, or to participate in product recalls;
• We may release your personal health information to other members of the organized health care arrangement described above, as necessary to carry out treatment, payment, and health care operations permitted by law;
• We may release your personal health information to the plan sponsor of The Ohio State University Faculty and Staff Health Plans; provided, however, that the plan sponsor has certified that the information provided will be maintained in a confidential manner and not used for employment related decisions or for other employee benefit determinations or in any other manner not permitted by law;
• We may release your personal health information in the course of an administrative or judicial proceeding, such as in response to a court order or (under certain circumstances) in response to a subpoena, discovery request or other lawful process not accompanied by a court order;
• We may release your personal health information to law enforcement officials for law enforcement purposes, including reporting wounds and injuries and crimes;
• We may release your personal health information to medical examiners, coroners and/or funeral directors consistent with law;
• We may release your personal health information if necessary to arrange an organ, eye or tissue donation from you or a transplant for you;
• We may release your personal health information under certain circumstances and consistent with applicable law and standards of ethical conduct, if we believe it necessary to avert a serious threat to the health or safety of a person or the public;
• We may release your personal health information if you are a member of the military as required by armed forces services; we may also release your personal health information if necessary for national security or intelligence activities;
• We may release your personal health information to a correctional institution or to law enforcement official under certain circumstances, if you are an inmate of a correctional institution or under the custody of a law enforcement official; and
• • We may release your personal health information as necessary to comply with worker’s compensation laws or similar programs established by law to provide benefits for work-related injuries or illness without regard to fault.

RIGHTS THAT YOU HAVE

Access to Your Personal Health Information
You have the right to copy and/or inspect much of the personal health information that we retain on your behalf. All requests for access must be made in writing and signed by you or your authorized representative. You may obtain an access request form online at http://hr.osu.edu/hrpubs/forms.htm or by calling Customer Service at (614) 292-1050.

Amendments to Your Personal Health Information
You have the right to request in writing that certain personal information we maintain about you be amended or corrected. We are not obligated to make all requested amendments but will give each request careful consideration. All amendment requests, in order to be considered by us, must be in writing, signed by you or representative, and must state the reasons for the amendment/correction request. If an amendment or correction you request is made by us, we may also notify others who we know have copies of the uncorrected record, if we believe such notification is necessary. You may obtain an amendment request form online at http://hr.osu.edu/hrpubs/forms.htm or by calling Customer Service at (614) 292-1050.

Confidential Communications
You have the right to request that you receive communications regarding your personal health information from us by alternative means or at alternative locations. For instance, you may wish to not have messages left on voice mail or sent to a particular address. We will accommodate all reasonable requests for confidential communications. You may request these confidential communications in writing by sending your request to the Compliance and Quality Improvement Manager, Managed Health Care Systems, Inc., 700 Ackerman Road, Suite 580, Columbus, OH 43202.

Accounting for Disclosures of Your Personal Health Information
You have the right to receive an accounting of certain disclosures of your personal health information made by us after April 14, 2003, but in no case earlier than six years before the date of the request. Requests must be made in writing and signed by you or your representative. Accounting request forms are available online at http://hr.osu.edu/hrpubs/forms.htm or by calling Customer Service at (614) 292-1050.

Restrictions on Use and Disclosure of Your Personal Health Information
You have the right to request restrictions on certain uses and disclosures of your personal health information made by us for treatment, payment or health care operations or to family, friends and others involved in your care by notifying us of your request for a restriction in writing. A restriction request form can be obtained online at http://hr.osu.edu/hrpubs/forms.htm or by calling Customer Service at (614) 292-1050. We are not required to agree to your restriction request but will attempt to accommodate reasonable requests when appropriate and we retain the right to terminate an agreed to restriction if we believe such termination is appropriate. In the event of a termination by us, we will notify you of such termination. You also have the right to terminate, in writing or orally, any agreed to restriction by sending such termination notice to the Compliance and Quality Improvement Manager, Managed Health Care Systems, Inc, 700 Ackerman Road, Suite 580, Columbus, OH 43202 or by calling the Compliance and Quality Improvement Manager at (614) 292-5703.

Complaints
If you believe your privacy rights have been violated, you can file a written complaint with the Compliance and Quality Improvement Manager, Managed Health Care Systems, Inc., 700 Ackerman Road, Suite 580, Columbus, OH 43202. You can access a complaint form online at http://hr.osu.edu/hrpubs/forms.htm or by calling Customer Service at (614) 292-1050.

You may also file a written complaint with the Secretary of the U.S. Department of Health and Human Services in Washington DC within 180 days of a violation of your rights. There will be no retaliation for filing a complaint.

As a member, you retain the right to obtain a paper copy of this Notice of Privacy Practices, even if you have requested such copy by e-mail or other electronic means.