Notice of Privacy Practices

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

The Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Health Information Technology for Economic and Clinical Health (HITECH) Act, imposes conditions on how a health plan may use and disclose your individual health information, referred to here as “protected health information.” It also gives you certain rights with respect to that information.

This notice describes the privacy practices of the following health plan1:

Health Reinsurance Association

The Plan’s responsibilities

We are required by federal law to maintain the privacy of protected health information, to advise you of any breach that may have compromised the privacy or security of your protected health information and to provide you with this Notice about your rights and our legal duties and privacy practices with respect to your protected health information. We must follow the terms of this Notice while it is in effect.

The Plan will follow the terms of this notice, as it may be updated from time to time. The Plan reserves the right to change the terms of its privacy policies at any time and to make new provisions effective for all health information that the Plan maintains.

How the Plan may use or disclose your health information

The privacy rules generally allow the use and disclosure of your health information without your written authorization for purposes of treatment, payment and health care operations. Here are some examples of what this encompasses:

Treatment includes providing, coordinating, or managing health care by a health care provider or doctor. Treatment can also include coordination or management of care between a provider and a third party, and consultation and referrals between providers. For example, the Plan may share health information about you with physicians who are treating you.

Payment includes activities by this Plan, other plans, or providers to obtain premiums, make coverage determinations and provide reimbursement for health care. For example, if you receive benefits through a group health insurance plan, we may disclose personal information to other health plans maintained by your employer if it has been arranged for us to do so in order to have certain expenses reimbursed.

Health care operations include activities by the Plan such as wellness and risk assessment programs, quality assessment and improvement activities, customer service, and the claims and appeal process. Health care operations also include vendor evaluations, credentialing, training, accreditation activities, underwriting, premium rating, arranging for medical review and audit activities, and business planning and development. The Plan will not use PHI that is genetic information for underwriting purposes. For example, the Plan may use information about your claims to review the effectiveness of wellness programs.

We will only disclose the minimum information necessary with respect to the amount of health information used or disclosed for these purposes. In other words, only information relating to the task being performed will be used or disclosed. Information not required for the task will not be used or disclosed.

The Plan may also contact you to provide information about treatment alternatives or other health-related benefits and services that may be of interest to you.

Other allowable uses or disclosures of your health information

Generally, we may disclose your protected health information to a friend or family member that you have identified as being involved in your health care or payment for that care. In the case of an emergency, information describing your location, general condition, or death may be provided to a similar person (or to a public or private entity authorized to assist in disaster relief efforts.) In addition, your health information may be disclosed without authorization to your legal representative.

We may use or disclose your health information without your written authorization for the following activities:

As required by law Disclosures to federal, state or local agencies in accordance with applicable law.
Workers’ compensation Disclosures to workers’ compensation or similar programs in accordance with federal, state or local laws.
To prevent serious threat to health or safety Disclosures made in the good-faith belief that releasing your health information is necessary to prevent or lessen a serious and imminent threat to public or personal health or safety; includes disclosures to assist law enforcement officials in identifying or apprehending an individual in certain circumstances.
Public health activities Disclosures for public health reasons, including: (1) to a public health authority for the prevention or control of disease, injury or disability; (2) a proper government or health authority to report child abuse or neglect; (3) to report reactions to medications or problems with products regulated by the Food and Drug Administration; (4) to notify individuals of recalls of medication or products they may be using; (5) to notify a person who may have been exposed to a communicable disease or who may be at risk for contracting or spreading a disease or condition.
Victims of abuse, neglect, or domestic violence Disclosures to report a suspected case of abuse, neglect, or domestic violence, as permitted or required by applicable law.
Judicial and administrative proceedings Disclosures in response to an order of a court or administrative tribunal or in response to a subpoena, discovery request, or other lawful process once HIPAA’s administrative requirements have been met.
Law enforcement purposes Disclosures to law enforcement officials required by law or pursuant to legal process for law enforcement purposes.
Death Disclosures to a coroner or medical examiner to identify the deceased or determine cause of death; and to funeral directors to carry out their duties.
Organ, eye, or tissue donation Disclosures to organ procurement organizations or other entities to facilitate organ, eye, or tissue donation and transplantation after death.
Research purposes Disclosures subject to approval by institutional or private privacy review boards, and subject to certain assurances and representations by researchers regarding necessity of using your health information and treatment of the information during a research project.
Health oversight activities Disclosures to comply with health care system oversight activities, such as audits, inspections, or investigations and activities related to health care provision or public benefits or services.
Specialized government functions Disclosures to facilitate specified government functions related to the military and veterans, national security or intelligence activities; disclosures to correctional facilities about inmates.
HHS investigations Disclosures of your health information to the Department of Health and Human Services (HHS) to investigate or determine the Plan’s compliance with the HIPAA Privacy Rule.

Except as described in this notice, other uses and disclosures of PHI, such as marketing purposes, use of psychotherapy notes, and disclosures that constitute the sale of PHI, will be made only with your written authorization.

You may revoke your authorization as allowed under the HIPAA rules. However, you can’t revoke your authorization with respect to disclosures the Plan has already made.

Your individual rights

You have the following rights in connection with your health information that the Plan maintains. These rights are subject to certain limitations, described below.

Right to request restrictions on certain uses and disclosures of your health information and the Plan’s right to refuse

You have the right to request a restriction or limitation on the Plan’s use or disclosure of your health information. We will consider, but may not agree to, such requests. You also have the right to ask us to restrict disclosures to persons involved in your health care.

Right to receive confidential communications of your health information

You have the right to request that the Plan communicate with you about your health information at an alternative address or by alternative means if you think that communication through normal processes could endanger you in some way. The health plan will make every reasonable attempt to accommodate all reasonable requests and must accommodate that request if you state in writing that communication through normal processes could endanger you in some way.

Right to inspect and copy your health information

You have the right to inspect or obtain a copy of your health information contained in records that the Plan maintains for enrollment, payment, claims determination, or case or medical management activities, or that the Plan uses to make enrollment, coverage or payment decisions (the Designated Record Set). However, you do not have a right to inspect or obtain copies of psychotherapy notes or information compiled for civil, criminal, or administrative proceedings. In addition, the Plan may deny your right to access, although in certain circumstances you may request a review of the denial. If the Plan doesn’t maintain the health information but knows where it is maintained, you will be informed of where to direct your request.

The Plan may provide you with a summary or explanation of the information instead of access to or copies of your health information, if you agree in advance and pay any applicable fees. The Plan also may charge reasonable fees for copies or postage.

Right to access electronic records

You may request access to electronic copies of your PHI held in a Designated Record Set or in an electronic health record, or you may request in writing or electronically that another person receive an electronic copy of these records. The electronic PHI will be provided in a mutually agreed-upon format, and you may be charged for the cost of any electronic media (such as a USB flash drive) used to provide a copy of the electronic PHI.

Right to amend your health information that is inaccurate or incomplete

With certain exceptions, you have a right to request that the Plan amend your health information if you believe that the information the Plan has about you is incomplete or incorrect. You must include a statement to support the requested amendment. The Plan will notify you of its decision to grant or deny your request.

Right to receive an accounting of disclosures

You have the right to a list of certain disclosures of your health information. The accounting will not include: (1) disclosures made for purposes of treatment, payment or health care operations; (2) disclosures made to you; (3) disclosures made pursuant to your authorization; (4) disclosures made to friends or family in your presence or because of an emergency; (5) disclosure for national security purpose; and (6) disclosures incident to other permissible disclosures.

You may receive information about disclosures of your health information going back for six (6) years from the date of your request. You may make one (1) request in any 12-month period at no cost to you, but the Plan may charge a fee for subsequent requests. You will be notified of the fee in advance and have the opportunity to change or revoke your request.

Additional information and How to exercise your rights in this notice

For additional information or how to exercise your rights listed in this notice, you should contact:

Health Reinsurance Association Privacy Office
Attn.: Privacy Officer Liaison
c/o Pool Administrators Inc.
628 Hebron Avenue, Suite 100
Glastonbury, CT. 06033
Toll free customer service number 1-800-842-0004


If you believe that your privacy rights have been violated, you may file a written complaint with:

Health Reinsurance Association Privacy Office
Attn.: Privacy Officer Liaison
c/o Pool Administrators Inc.
628 Hebron Avenue, Suite 100
Glastonbury, CT. 06033
Toll free customer service number 1-800-842-0004.

You may also file a complaint with the regional Office for Civil Rights of the United States Department of Health and Human Services. Information on how to file a complaint is available on the Department of Health and Human Services website at

You will not be retaliated against for filing a complaint.

Effective Date

This notice is effective as of September 23, 2013

1Throughout this Notice, the Health Reinsurance Association is referred to as “we” or “us”.


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