HIPAA Notice of Privacy Practices

Applies to Employee Health Information Only

April 2004

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.

USE AND DISCLOSURE OF HEALTH INFORMATION

WPI may use your health information, that is, information that constitutes protected health information as defined in the Privacy Rule of the Administrative Simplification provision of the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"), for purposes of making or obtaining payment for your care and conducting health care operations. WPI has established a policy and procedures regarding disclosure of your health information.

The following is a summary of the circumstances under and purposes for which your health information may be used and disclosed by WPI:

To Make or Obtain Payment.

WPI may use or disclose your health information to make payment to or collect payment from third parties, such as other health plans or providers, for the care you receive. For example, WPI may provide information regarding your coverage or health care treatment to other health plans to coordinate payment of benefits.

To Conduct Health Care Operations.

WPI may use or disclose health information for its own operations to facilitate the administration of the WPI health plan and Medical Reimbursement Account (FLEXCOMP), as necessary, to provide coverage and services to all of WPI's participants. Health care operations include such activities as:

For Distribution of Health-Related Benefits and Services.

WPI may use or disclose your health information to provide you with information on health-related benefits and services.

When Legally Required.

WPI will disclose your health information when it is required to do so by any federal, state, or local law.

To Conduct Health Oversight Activities.

WPI may disclose your health information to a health oversight agency for authorized activities including audits, civil administrative or criminal investigations, inspections, licensure, or disciplinary action. WPI, however, may not disclose your health information if you are the subject of an investigation and the investigation does not arise out of or is not directly related to your receipt of health care or public benefits.

In Connection With Judicial and Administrative Proceedings.

As permitted or required by state law, WPI may disclose your health information in the course of any judicial or administrative proceeding in response to an order of a court or administrative tribunal as expressly authorized by such order or in response to a subpoena, discovery request or other lawful process, but only when WPI makes reasonable efforts to either notify you about the request or to obtain an order protecting your health information.

For Law Enforcement Purposes.

As permitted or required by state law, WPI may disclose your health information to a law enforcement official for certain law enforcement purposes, including, but not limited to, if WPI has a suspicion that your death was the result of criminal conduct or in an emergency to report a crime. In the Event of a Serious Threat to Health or Safety. WPI may, consistent with applicable law and ethical standards of conduct, disclose your health information if WPI, in good faith, believes that such disclosure is necessary to prevent or lessen a serious and imminent threat to your health or safety or to the health and safety of the public.

For Specified Government Functions.

In certain circumstances, federal regulations require WPI to use or disclose your health information to facilitate specified government functions related to the military and veterans, national security and intelligence activities, protective services for the president and others, and correctional institutions and inmates.

For Worker's Compensation.

WPI may release your health information to the extent necessary to comply with laws related to worker's compensation or similar programs.

AUTHORIZATION TO USE OR DISCLOSE HEALTH INFORMATION

Other than as stated above, WPI will not disclose your health information other than with your written authorization. If you authorize WPI to use or disclose your health information, you may revoke that authorization in writing at any time.

YOUR RIGHTS WITH RESPECT TO YOUR HEALTH INFORMATION

You have the following rights regarding your health information that WPI maintains:

Right to Request Restrictions.

You may request restrictions on certain uses and disclosures of your health information. You have the right to request a limit on WPI's disclosure of your health information to someone involved in the payment of your care. However, WPI is not required to agree to your request. If you wish to make a request for restrictions, please contact the WPI Contact Person at (508) 831-5470.

Right to Receive Confidential Communications.

You have the right to request that WPI communicate with you in a certain way if you feel the disclosure of your health information could endanger you. For example, you may ask that WPI only communicate with you at a certain telephone number or by email. If you wish to receive confidential communications, please make your request in writing to the WPI Contact Person. WPI will attempt to honor your reasonable requests for confidential communications.

Right to Inspect and Copy Your Health Information.

You have the right to inspect and copy your health information. A request to inspect and copy records containing your health information must be made in writing to the WPI Contact Person.

Right to Amend Your Health Information.

If you believe that your health information records are inaccurate or incomplete, you may request that WPI amend the records. That request may be made as long as the information is maintained by WPI. A request for an amendment of records must be made in writing to the WPI Contact Person. WPI may deny the request if it does not include a reason to support the amendment. The request also may be denied if your health information records were not created by WPI, if the health information you are requesting to amend is not part of WPI's records, if the health information you wish to amend falls within an exception to the health information you are permitted to inspect and copy, or if WPI determines the records containing your health information are accurate and complete.

Right to an Accounting.

You have the right to request a list of disclosures of your health information made by WPI for any reason other than for treatment, payment, or health operations. The request must be made in writing to the WPI Contact Person. The request should specify the time period for which you are requesting the information, but may not start earlier than April 14, 2004. Accounting requests may not be made for periods of time going back more than six (6) years.

Right to a Paper Copy of this Notice.

You have a right to request and receive a paper copy of this Notice at any time, even if you have received this Notice previously or agreed to receive the Notice electronically. To obtain a paper copy, please contact the WPI Contact Person. You also may obtain a copy of the current version of WPI's Notice at its Web site.

DUTIES OF WPI

WPI is required by law to maintain the privacy of your health information as set forth in this Notice and to provide you this Notice of its duties and privacy practices. WPI is required to abide by the terms of this Notice, which may be amended from time to time. WPI reserves the right to change the terms of this Notice and to make the new Notice provisions effective for all health information that it maintains. If WPI changes its policies and procedures, WPI will revise the Notice and will provide a copy of the revised Notice to you within 60 days of the change. You have the right to express complaints to WPI and to the Secretary of the Department of Health and Human Services if you believe that your privacy rights have been violated. Any complaints to WPI should be made in writing to the WPI Contact Person. WPI encourages you to express any concerns you may have regarding the privacy of your information. You will not be retaliated against in any way for filing a complaint.

CONTACT PERSON

WPI has designated Melanie A. Desiata, Benefits Coordinator, as its Contact Person for all issues regarding patient privacy and your privacy rights. You may contact her at mailing address - 100 Institute Road, physical address - 39 Dean Street, Worcester, MA 01609, (508) 831-5470, mdesiata@wpi.edu, or via fax (508) 831-5715.

EFFECTIVE DATE

This Notice is effective April 14, 2004.

If you have any questions regarding this notice, please contact: A. Tracy Hassett, Director of Human Resources, 100 Institute Road, Worcester, MA 01609, (508) 831-5473, thassett@wpi.edu, or via fax (508) 831-5715.

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