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In 1999, the Gramm-Leach-Bliley Act (P.L. 106-102) (“the Act”) was enacted by Congress. Pursuant to the Act, Denver Health Medical Plan, Inc. (“the Plan”) has an obligation to give you notice of the types of nonpublic personal financial information that it collects from you and about you from others. In addition, it has an obligation to give you notice of the ways in which the Plan uses such information in the process of providing health coverage to you. This Privacy Notice is intended to satisfy the Plan’s obligations under the Act, as well as to explain the policies and procedures that the Plan has in place, and has had in place, to protect your nonpublic personally identifiable financial information.
Definitions
“Nonpublic personal financial information” means personally identifiable financial information and any lists, descriptions or other groupings of consumers that are obtained through the use of personally identifiable financial information that is not publicly available. It does not include health information, publicly available information or any list, description or other grouping of consumers that is obtained without using personally identifiable financial information.
Example: Lists of member names and addresses grouped by use of Plan ID or account numbers.
“Personally identifiable financial information” means any information (a) that you provide to the Plan to obtain health coverage from the Plan; (b) that the Plan generates about you during the period of your coverage by the Plan; and (c) that the Plan receives from third parties about you in connection with your health coverage. Personally identifiable financial information does not include health information.
Example: Information collected from your application or enrollment form; your use of the Plan’s website; your correspondence with the Plan; account balance information.
The Plan Collects Nonpublic Personal Financial Information From You
The Plan collects nonpublic personal financial information regarding you, both at the time of your enrollment in the Plan and during the period you are covered by the Plan, on your application form (taxpayer ID number, employee list, employer tax returns and, in some cases, employer financial statements); enrollment form (your name, address, telephone number, date of birth and social security number, as well as the names, dates of birth and social security numbers of each of your dependents); change in status form (new dependents, changes in marital status, changes in addresses and telephone numbers and changes in employment status).
The Plan Collects Nonpublic Personal Financial Information From Other Sources
The Plan collects information from other insurers regarding additional coverage for you or your dependents, and the dates of coverage for any previous health coverage you may have had. It also collects information from your employer regarding your employment status and changes in family and dependent status.
The Plan does not collect information from any consumer credit reporting agency or any other third-party commercial database.
The Plan Uses Nonpublic Personal Financial Information to Assure Timely and Appropriate Coverage for You and Your Family
The Plan has the following contractual relationships with both affiliated and nonaffiliated third parties to ensure timely, effective and appropriate health care to you and your family. All of the following disclosures of your information are permitted by the Act without further notice to you:
| Third Party Relationship | Information Disclosed |
|---|---|
| Administrative services agreement with Denver Health and Hospital Authority, an affiliate of the Plan, to provide all membership services, medical management services, quality improvement and credentialing services, marketing, sales, underwriting and other administrative services (other than claims processing) for the Plan. | The Plan shares all information collected through the enrollment process and through other entities. |
| Service and consulting agreement with a nonaffiliated third party to conduct member satisfaction surveys for quality of care purposes. | The Plan shares your name, address and telephone number with the third party; once survey information is obtained, it is analyzed and summarized, in an aggregate fashion (not in a personally identifiable format) for the Plan. |
| Provider agreements with the Denver Health and Hospital Authority and with affiliated and nonaffiliated physician groups to facilitate proper and timely medical and hospital services to Plan members. | The Plan numbers shares as part names, dates of birth of the eligibility lists and social security produced for providers. |
| Claims processing agreement with a nonaffiliated out-of-state entity to perform all claims processing functions. | The Plan shares eligibility lists with the claims processing entity, along with any specific payment information that the Plan may have related to pending claims. |
| Vendor agreements related to information management and database development. | The Plan shares all personal financial information it collects with the vendors in order to facilitate the development of data field for all such information. |
| Employer arrangements with employers, such as the Denver Health and Hospital Authority and the City and County of Denver. | The Plan shares eligibility lists and premium information with the employers. |
| Managed care agreement with the Children’s Basic Health Plan (“CHP+”) to provide an HMO in Denver County. The Plan is one of a number of HMOs responsible for providing managed care services to certain low-income children through the CHP+ program. | The Plan shares eligibility information with the CHP+. |
| The Plan provides certificates of coverage to succeeding health insurers. | The certificate discloses your name, address and dates of health coverage by the Plan, as required by federal law. This disclosure provides the information necessary to the succeeding health insurer to waive any pre-existing condition limitations that might otherwise be applicable. |
| Grant arrangements with Community Voices and other nonprofit foundations to facilitate premium subsidies for certain policyholders and subscribers. | The Plan shares all nonpublic personal financial information that is deemed necessary for the processing of a grant. |
The Plan reserves the right to disclose nonpublic personal financial information in the future to other third parties as necessary to administer health coverage. The information that the Plan would disclose would not go beyond that listed in the above chart.
Your Right to Opt Out of Disclosure of Nonpublic Personal Financial Information
All of the disclosures described above, except for the last entry on the chart, are disclosures that are integral to the provision of health coverage to you and your family and are permitted by the Act. The Plan does not disclose nonpublic personal financial information to nonaffiliated third parties for purposes not related to the administration of the Plan. To the extent that the Plan should determine at some future time that any such disclosure were necessary, you would receive a revised privacy notice, and you would be offered the opportunity to opt out of any such disclosure by contacting the Plan by letter, e-mail or telephone. If you would like to request restrictions or would like to opt out of use/disclosure of your personal health information, please call our Health Plan Services Department at 303-602-2100 or 1-800-700-8140.
The Privacy Policies of The Plan
The Plan has policies and procedures in place to protect the confidentiality of your nonpublic personal financial information. All agreements with affiliated and nonaffiliated third parties require such third parties to maintain the confidentiality of all policyholder and subscriber information shared with them, including nonpublic personal financial information. All affiliated and nonaffiliated third parties with whom the Plan contracts are prohibited from redisclosing any confidential information, including nonpublic personal financial information, to any other persons without the express written consent of the Plan. The Plan would give such consent only if required to do so by law or if the redisclosure were necessary to the administration of your health coverage. Generally, the Plan requires that only persons who have a need to know your nonpublic personal financial information for their specific job duties may have access to such information.
Where You Can Get More Information
If you would like more information regarding how the Plan collects nonpublic personal financial information, how the Plan uses such information or how the Plan protects such information, please contact our Health Plan Services Department at 303-602-2100 or 1-800-700-8140.