LAPRA Privacy Notice

LOS ANGELES POLICE RELIEF ASSOCIATION, INC. HEALTH PLAN NOTICE OF PRIVACY PRACTICES

General Information About This Notice

Los Angeles Police Relief Association, Inc. (“LAPRA”) is committed to maintaining the confidentiality of your private medical information. This Notice describes our efforts to safeguard your health information from improper or unnecessary use or disclosure. This Notice only applies to health-related information created or received by or on behalf of the LAPRA benefit programs listed below (collectively referred to in this Notice as the “Health Plans”). We are providing this Notice to you because privacy regulations issued under federal law, the Health Insurance Portability and Accountability Act of 1996, 45 CFR Parts 160 and 164 (“HIPAA”), require us to provide you with a summary of the Health Plans’ privacy practices and related legal duties, and your rights in connection with the use and disclosure of your Health Plans information.

This Notice applies to LAPRA Health Plans members, former members, and dependents who participate in any of the following benefit programs:

1. Medical Benefits
2. Dental Benefits
3. Vision Benefits


In this Notice, the terms “Health Plans,” “we,” “us,” and “our” refer to the Health Plans, all LAPRA employees involved in the administration of the Health Plans, and third parties to the extent they perform administrative services for the Health Plans.

Please note:

LAPRA employees perform only limited Health Plans functions – most Health Plans administrative functions are performed by third party service providers. We require these third parties to appropriately safeguard the privacy of your information.

If you are enrolled in an HMO you will also receive a separate notice from your HMO provider that describes the HMO provider’s specific use and disclosure of your health information. Your rights with respect to their use and disclosure of your health information are set forth in that separate notice.


What is Protected?


Federal law requires the Health Plans to have a special policy for safeguarding a category of medical information called “protected health information,” or “PHI,” received or created in the course of administering the Health Plans. PHI is health information that can be used to identify you and that relates to (1) your physical or mental health condition; (2) the provision of health care to you; or (3) payment for your health care.

Medical records, claims for benefits, and the explanation of benefits (“EOB’s”) sent in connection with payment of claims are all examples of PHI.


> Back to top


Uses and Disclosures of Your PHI


To protect the privacy of your PHI, the Health Plans not only guard the physical security of your PHI, but we also limit the way your PHI is used or disclosed to others. We may use or disclose your PHI in certain permissible ways described below. To the extent required under federal health information privacy law, we use the minimum amount of your PHI necessary to perform these tasks.


  • To determine proper payment of your Health Plans benefit claims. The Health Plans use and disclose your PHI to reimburse you or your doctors or health care providers for covered treatments and services. For example, your diagnosis information may be used to determine whether a specific procedure is medically necessary or to reimburse your doctor for your medical care.

  • For the administration and operation of the Health Plans. We may use and disclose your PHI for numerous administrative and quality control functions necessary for the Health Plans’ proper operation. For example, we may use your claims information for fraud and abuse detection activities or to conduct data analyses for cost-control or planning-related purposes.

  • To inform you or your health care provider about treatment alternatives or other health-related benefits that may be offered under an Health Plan. For example, we may use your claims data to alert you to an available case management program if you are diagnosed with certain diseases or illnesses, such as diabetes.

  • To a health care provider if needed for your treatment.

  • To a health care provider or to another health plan to determine proper payment of your claim under the other plan. For example, we may exchange your PHI with your spouse’s health plan for coordination of benefits purposes.

  • To another health plan for certain administration and operations purposes. We may share your PHI with another health plan or health care provider who has a relationship with you for quality assessment and improvement activities, to review the qualifications of health care professionals who provide care to you, or for fraud and abuse detection and prevention purposes.

  • To a family member, friend, or other person involved in your health care if you are present and you do not object to the sharing of your PHI, or it can reasonably be inferred that you do not object, or in the event of an emergency.

  • For Health Plans design activities or to collect Health Plans premium contributions. LAPRA may use summary or de-identified health information for Health Plans design activities. In addition, LAPRA employees may use information about your enrollment or disenrollment in a Health Plan in order to collect premiums through payroll or pension deductions.

  • To the Plan Sponsor. The Health Plans may disclose PHI to LAPRA to the extent provided by a rule of the Health Plans, provided that LAPRA protects the privacy of the PHI and it is only used for the permitted purposes described in this Notice.

  • To Business Associates. The Health Plans may disclose PHI to other people or businesses that provide services to the Health Plans and which need the PHI to perform those services. These people or businesses are called business associates, and the Health Plans will have a written agreement with each of them requiring each of them to protect the privacy of your PHI. For example, the Health Plans may have hired a consultant to evaluate claims or suggest changes to the Health Plans, for which he needs to see PHI.

  • To comply with an applicable federal, state, or local law, including workers’ compensation or similar programs.

  • For public health reasons, including (1) to a public health authority for the prevention or control of disease, injury or disability; (2) to 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; or (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.

  • To report a suspected case of abuse, neglect or domestic violence, as permitted or required by applicable law.

  • To comply with health oversight activities, such as audits, investigations, inspections, licensure actions, and other government monitoring and activities related to health care provision or public benefits or services.

  • To the U.S. Department of Health and Human Services to demonstrate our compliance with federal health information privacy law.

  • To respond to an order of a court or administrative tribunal.

  • To respond to a subpoena, warrant, summons or other legal request if, to the extent required by applicable law, sufficient safeguards, such as a protective order, are in place to maintain your PHI privacy.

  • To a law enforcement official for a law enforcement purpose.

  • For purposes of public safety or national security.

  • To allow a coroner or medical examiner to identify you or determine your cause of death.

  • To allow a funeral director to carry out his or her duties.

  • To respond to a request by military command authorities if you are or were a member of the armed forces.

  • For cadaveric organ, eye or tissue donation. The Health Plans may use and disclose protected health information to organ procurement organizations or other entities engaged in the procurement, banking, or transplantation of cadaveric organs, eyes, or tissue for the purpose of facilitating organ, eye or tissue donation and transplantation.

  • For research. The Health Plans may use and disclose protected health information to assist in research activities, regardless of the source of the funding for the research, where a privacy board or an Institutional Review Board has approved an alteration to or waived entirely the authorization requirements of the law and the Health Plans receive certain specific representations and documentation.

  • To avert serious threat to health or safety. The Health Plans may use and disclose protected health information to prevent or lessen a serious threat to health or safety of any one person or the general public and the use or disclosure is (1) to a person or persons reasonably able to prevent or lessen the threat to health or safety or (2) necessary for law enforcement authorities to identify or apprehend an individual.

  • Incident to a permitted use or disclosure. The Health Plans may use and disclose protected health information incident to any use or disclosure permitted or authorized by law.

  • As part of a limited data set. The Health Plans may use and disclose a limited data set that meets the technical requirements of 45 Code of Federal Regulations, Section 164.514(e), if the Health Plans have entered into a data use agreement with the recipient of the limited data set.

  • For fundraising. The Health Plans may use and disclose certain types of protected health information to a business or to an institutionally related foundation for the purpose of raising funds. The type of information that may be disclosed under this exception to the authorization requirement is (1) demographic information relating to an individual and (2) dates of health care provided to an individual.

Absent your written permission, LAPRA employees will only use or disclose your PHI as described in this Notice. LAPRA employees will not access your PHI for reasons unrelated to Health Plans administration, and LAPRA does not use your PHI for any employment-related reason without your express written authorization.

If an applicable state law provides greater health information privacy protections than the federal law, we will comply with the stricter state law.



> Back to top


Other Uses and Disclosures of Your PHI


Before we use or disclose your PHI for any purpose other than those listed above, we must obtain your written authorization. You may revoke your authorization, in writing, at any time. If you revoke your authorization, the Health Plans will no longer use or disclose your PHI except as described above (or as permitted by any other authorizations that have not been revoked). However, please understand that we cannot retrieve any PHI disclosed to a third party in reliance on your prior authorization.

In no event will the Health Plans use or disclose your PHI that is “genetic information” for “underwriting purposes,” as such terms are defined by the Genetic Information Nondiscrimination Act of 2008.


Your Rights


Federal law provides you with certain rights regarding your PHI. Parents of minor children and other individuals with legal authority to make health decisions for a Health Plans participant may exercise these rights on behalf of the participant, consistent with state law.

Right to request restrictions: You have the right to request a restriction or limitation on the Health Plans’ use or disclosure of your PHI. For example, you may ask us to limit the scope of your PHI disclosures to a case manager who is assigned to you for monitoring a chronic condition. Because we use your PHI only to the extent necessary to pay Health Plans benefits, to administer the Health Plans, and to comply with the law, it may not be possible to agree to your request. Except in the limited circumstances described below, the law does not require the Health Plans to agree to your request for restriction. Except as otherwise required by law (and excluding disclosures for treatment purposes), the Health Plans are obligated, upon your request, to refrain from sharing your PHI with another health plan for purposes of payment or carrying out health care operations if the PHI pertains solely to a health care item or service for which the health care provider involved has been paid out-of-pocket in full. The Health Plans will not agree to any restriction which will cause it to violate or be noncompliant with any legal requirement. However, if we do agree to your requested restriction or limitation, we will honor the restriction until you agree to terminate the restriction or until we notify you that we are terminating the restriction with respect to PHI created or received by the Health Plans in the future.

You may make a request for restriction on the use and disclosure of your PHI by completing the appropriate request form available from the LAPRA Benefits Department at the number and address provided on the first page of this Notice.

> Back to top


Right to receive confidential communications: You have the right to request that the Health Plans communicate with you about your PHI at an alternative address or by alternative means if you believe that communication through normal business practices could endanger you. For example, you may request that the Health Plans contact you only at work and not at home.

You may request confidential communication of your PHI by completing an appropriate form available from the LAPRA Benefits Department. We will accommodate all reasonable requests if you clearly state that you are requesting the confidential communication because you feel that disclosure in another way could endanger your safety.

Right to inspect and obtain a copy of your PHI: You have the right to inspect and obtain a copy of your PHI that is contained in records that the Health Plans maintain for enrollment, payment, claims determination, or case or medical management activities. If the Health Plans use or maintain an electronic health record with respect to your PHI, you may request such PHI in an electronic format, and direct that such PHI be sent to another person or entity

However, this right does not extend to (1) psychotherapy notes, (2) information compiled in reasonable anticipation of, or for use in, a civil, criminal, or administrative action or proceeding, and (3) any information, including PHI, as to which the law does not permit access. We will also deny your request to inspect and obtain a copy of your PHI if a licensed health care professional hired by the Health Plans has determined that giving you the requested access is reasonably likely to endanger the life or physical safety of you or another individual or to cause substantial harm to you or another individual, or that the record makes references to another person (other than a health care provider), and that the requested access would likely cause substantial harm to the other person.

In the event that your request to inspect or obtain a copy of your PHI is denied, you may have that decision reviewed. A different licensed health care professional chosen by the Health Plans will review the request and denial, and we will comply with the health care professional’s decision.

You may make a request to inspect or obtain a copy of your PHI by completing the appropriate form available from the LAPRA Benefits Department. We may charge you a fee to cover the costs of copying, mailing or other supplies directly associated with your request. You will be notified of any costs before you incur any expenses.

Right to amend your PHI: You have the right to request an amendment of your PHI if you believe the information the Health Plans have about you is incorrect or incomplete. You have this right as long as your PHI is maintained by the Health Plans in a designated record set. We will correct any mistakes if we created the PHI or if the person or entity that originally created the PHI is no longer available to make the amendment. However, we cannot amend PHI that we believe to be accurate and complete.

You may request amendments of your PHI by completing the appropriate form available from the LAPRA Benefits Department.

Right to receive an accounting of disclosures of PHI: You have the right to request a list of certain disclosures of your PHI by the Health Plans. The accounting will not include disclosures (1) to carry out treatment, payment and health care operations, (2) to you, (3) incident to a use or disclosure permitted or required by law, (4) pursuant to an authorization provided by you, (5) for directories or to people involved in your care or other notification purposes as permitted by law, (6) for national security or intelligence purposes, (7) to correctional institutions or law enforcement officials, (8) that are part of a limited data set, (9) that occurred prior to April 14, 2003, or more than six years before your request. Your first request for an accounting within a 12-month period will be free. We may charge you for costs associated with providing you additional accountings. We will notify you in advance of any costs, and you may choose to withdraw or modify your request before you incur any expenses.

You may make a request for an accounting by submitting the appropriate request form available from the LAPRA Benefits Department.

Right to Receive Notice: If your unsecured PHI is acquired, used or disclosed in a manner that is impermissible under the HIPAA privacy rules and that poses a significant risk of financial, reputational or other harm to you, the Health Plans must notify you within 60 days of discovery of such breach. Right to file a complaint: If you believe your rights have been violated, you should let us know immediately. We will take steps to remedy any violations of the Health Plans’ privacy policy or of this Notice.

You may file a formal complaint with our Privacy Officer and/or with the United States Department of Health and Human Services at the addresses below. You should attach any evidence or documents that support your belief that your privacy rights have been violated. We take your complaints very seriously. LAPRA prohibits retaliation against any person for filing such a complaint.

Complaints should be sent to:

Privacy Officer Los Angeles Police Relief Association, Inc.
600 N. Grand Avenue
Los Angeles, California 90012
Phone: (213) 674-3701
(888) 252-7721
Fax: (213) 674- 3715

Region IX, Office for Civil Rights
U.S. Department of Health and Human Services
90 7th Street, Suite 4-100
San Francisco, CA 94103
Phone: (415) 437-8310
FAX: (415) 437-8329
TDD: (415) 437-8311
www.hhs.gov/ocr/privacy/hipaa/complaints/index.html


> Back to top


Additional Information About This Notice


Changes to this Notice: We reserve the right to change the Health Plans’ privacy practices as described in this Notice. Any change may affect the use and disclosure of your PHI already maintained by the LAPRA Health Plans, as well as any of your PHI that the Health Plans may receive or create in the future. If there is a material change to the terms of this Notice, a revised Notice will be made available to you upon your request or as otherwise required by HIPAA.

How to obtain a copy of this Notice: You can obtain a copy of the current Notice by contacting the Privacy Officer at the address listed on the front of this Notice.

No change to Health Plans benefits: This Notice explains your privacy rights as a current or former participant in LAPRA Health Plans. The Health Plans are bound by the terms of this Notice as they relate to the privacy of your protected health information. However, this Notice does not change any other rights or obligations you may have under the Health Plans. You should refer to the Health Plans documents for additional information regarding your Health Plans benefits.


> Back to top