Kaiser Permanente Member Handbook Out of Area Preferred

Transcription

Kaiser Permanente Member Handbook Out of Area Preferred
MEMBER
HANDBOOK
OUT-OF-AREA
Preferred Provider Organization (PPO) Plan
WELCOME!
Welcome to
KAISER PERMANENTE!
Thank you for choosing Kaiser Permanente’s Out-of-Area Preferred Provider Organization
(PPO) Plan. This plan is designed for people who live outside our service area† and
contiguous counties††, but work for an employer based in our service area. Out-of-Area
PPO benefits are underwritten by the Kaiser Permanente Insurance Company (KPIC), a
subsidiary of Kaiser Foundation Health Plan, Inc.
Kaiser Permanente’s Out-of-Area PPO Plan provides access to quality health care while at
the same time giving you the freedom to choose your own providers and to help control
your out-of-pocket costs.
Kaiser Permanente makes it convenient for you to access medical care by giving you the
information you need. This Member Handbook contains the following materials:
• Information explaining how to locate a participating physician, obtain payment for
claims, obtain prescription medication, and more.
• The notice of privacy mandated by the Health Insurance Portability and Accountability
Act of 1996 (HIPAA), which explains how Kaiser Permanente Insurance Company
collects, stores, protects, and shares the personal information of our members.
You will soon receive a Certificate of Insurance and Schedule of Coverage from Kaiser
Permanente Insurance Company, which explains the benefits and limitations under this
product. This Member Handbook is an overview of your benefits—your Certificate of
Insurance and Schedule of Coverage always take precedence over the Handbook.
Kaiser Permanente Insurance Company sincerely welcomes your enrollment in our Out-of-Area
PPO Plan. If you have any questions or need more information, please call Customer Relations,
Monday through Thursday, 8:15 a.m. to 5 p.m. EST, and Friday, 9 a.m. to 5 p.m. EST, at
1-800-686-7100 or (216) 621-7100, or 1-877-676-6677 or (216) 635-4444 TTY. Or you can
write to us at:
Kaiser Permanente
Customer Relations
P.O. Box 5309
Cleveland, OH 44101
Once again, welcome to Kaiser Permanente. We look forward to a long and healthy
relationship with you.
†
The service area includes the following Northeast Ohio counties: Cuyahoga, Geauga, Lake, Lorain, Medina,
Portage, Stark, Summit, and Wayne.
††
Contiguous counties include the following Northeast Ohio counties: Ashland, Ashtabula, Carroll, Columbiana,
Erie, Holmes, Huron, Mahoning, Trumbull, and Tuscarawas.
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Kaiser Permanente Out-of-Area Member Handbook | 1
TABLE OF CONTENTS
GETTING CARE AND UTILIZING YOUR BENEFITS ...................................... 3
Participating providers ........................................................................... 3
Non-Participating providers .................................................................. 3
Emergency care ....................................................................................... 3
Claims payment........................................................................................ 4
Prescription coverage ............................................................................. 4
Precertification ......................................................................................... 5
Health information and education ........................................................ 5
PRIVACY NOTICE ........................................................................................... 6
2 | Kaiser Permanente Out-of-Area Member Handbook
GETTING CARE AND UTILIZING YOUR BENEFITS
Getting Care And
Utilizing Your Benefits
PARTICIPATING PROVIDERS
NON-PARTICIPATING PROVIDERS
When you see participating providers, you enjoy a higher
level of coverage and lower out-of-pocket costs. Here is
how to locate a physician or hospital in your area:
If you have an established relationship with a
provider who is not one of our participating
providers, your needs are still covered, but at a
lower level of coverage. You have the option to
receive medical care from any licensed provider.
When you see non-participating providers, you will
be responsible for meeting an annual deductible
(for most services) and paying a percentage of
charges (coinsurance). Payments are based upon
the Maximum Allowable Charge (MAC) for covered
services. When you seek services from nonparticipating providers, you are responsible for any
charge that exceeds MAC.
Within Ohio
Call Emerald HealthSmart Network (EHN)
1-800-346-3141,
M–F 8:30 a.m.–5 p.m. or visit
www.healthsmart.com
Outside Ohio
Call Private Healthcare Systems (PHCS) at
1-888-507-7427 or visit www.multiplan.com/kaiser.
Kaiser Permanente Insurance Company (KPIC) has
contracted with PHCS to provide access to hospitals
and physicians, with a commitment to keeping outof-pocket costs low through contracted rates.
You will be responsible for meeting an annual
deductible (for most services) and paying the
appropriate coinsurance, based on contracted
rates. Participating providers have agreed to accept
the negotiated fee as payment in full, and will not
charge you for any amounts over the negotiated fee
(no “balance billing”).
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EMERGENCY CARE
If you need emergency medical assistance, call 911
or go to the nearest emergency room.
An emergency medical condition means a medical
condition that manifests itself by such acute
symptoms of sufficient severity, including severe
pain, that a prudent lay person with average
knowledge of health and medicine could reasonably
expect the absence of immediate medical attention
to result in any of the following:
Kaiser Permanente Out-of-Area Member Handbook | 3
GETTING CARE AND UTILIZING YOUR BENEFITS
1. Placing the health of the individual or, with respect
to a pregnant woman, the health of the woman or
her unborn child, in serious jeopardy; or
2. Serious impairment to bodily functions; or
3. Serious dysfunction of any bodily organ or part.
If you receive emergency treatment, you will be
required to pay a copayment or deductible, as well
as any applicable coinsurance (see your Schedule
of Coverage). If you are admitted to a hospital, the
copayment or deductible will be waived. In the
event you are admitted to a hospital as a result of an
emergency, you, your doctor, or another responsible
party are required to obtain precertification within
24 hours after care has commenced (see the
“Precertification” section of this Handbook). This
requirement is not applied if notice is given as soon
as reasonably possible. Obtaining precertification
allows us to consult with the physician providing your
care and to coordinate further medical care when
necessary. KPIC will not deny emergency services
due to failure to obtain precertification. However, if
you are admitted to the hospital for treatment for
the same injury or sickness, precertification must be
obtained.
Please see your Certificate of Insurance and
Schedule of Coverage for more details about your
coverage for emergency care, or call Customer
Relations Monday through Thursday, 8:15 a.m. to
5 p.m., and Friday, 9 a.m. to 5 p.m., at 1-800-6867100 or (216) 621-7100, or 1-877-676-6677 or
(216) 635-4444 TTY.
4 | Kaiser Permanente Out-of-Area Member Handbook
CLAIMS PAYMENT
Whether you seek services from a participating
or non-participating provider, all claims should be
mailed to:
Meritain Health
P.O. Box 27216
Lansing, MI 48909-7216
This address is also located on the back of your
Kaiser Permanente ID card.
For questions concerning claims and/or payments,
contact:
Meritain Health
King James, Point VI
24651 Center Ridge Rd., Suite 200
Westlake, OH 44145
1-800-321-4085]
PRESCRIPTION COVERAGE
Please see your Schedule of Coverage to
determine whether your benefits include
prescription drug coverage.
Prescription drug coverage is administered through the
MedImpact MedCare® Network. With your KPIC Out-ofArea PPO insurance, you can fill covered prescriptions for
a low copayment at participating pharmacies around the
country. You can choose from generic, formulary brand,
nonformulary brand, and specialty drugs, each of which
have different copayments. Here are some definitions
that may be helpful:
• Generic drugs contain the same amount of the active
drug ingredient as the brand name drug and meet
the same FDA standards for safety and effectiveness.
• Brand formulary drugs are prescription medications
included on the Kaiser Permanente preferred brand
drug list.
• Nonformulary drugs are prescription medications
that are not included on the Kaiser Permanente
preferred brand drug list.
• Specialty drugs are high-cost prescription medications.
GETTING CARE AND UTILIZING YOUR BENEFITS
Participating pharmacies include, but are not limited
to, the following drugstores: Rite Aid, Wal-Mart,
Kmart, Ritzman, and Walgreens. (Participating stores
may change without notice.) To locate one of more
than 50,000 participating pharmacies nationally, call
MedImpact at 1-800-788-2949.
To obtain your prescription medications, please
follow these instructions:
1. Present your KPIC ID card to the pharmacist.
The necessary processing numbers are located
on this card.
2. Make sure the pharmacist enters the Medical
Record Number (MRN) from your ID card
instead of your Social Security number.
3. Be prepared to pay your copayment amount
(a lower copayment will be charged for generic
medications).
For questions about the coverage level for a specific
drug, please contact MedImpact at 1-800-788-2949.
If you have prescription drug coverage, your
plan may have a mail order option for purchasing
prescriptions. The KPIC Mail Order Prescription
Program allows some Out-of-Area PPO members
to order prescription maintenance medications
through Immediate Pharmaceutical Services (IPS),
a mail order service facility. Members may order
their refills online at www.ipsrx.com, by phone at
1-800-233-3872, or by mail. Once the order has
been received, it will be delivered to you within 7
to 10 days, with no charge for delivery. In addition,
you may be eligible to receive up to a 90-day
supply of maintenance medication for twice the
single copayment. Please refer to your Schedule of
Coverage for details.
PRECERTIFICATION
No referrals are necessary to see providers,
including specialists. However, precertification
is required for some inpatient and outpatient
services. Precertification is a required review of the
necessity and appropriateness of specified services
or treatments. You need to get precertification for
certain services listed in your Certificate of Insurance.
You or your physician need to call 1-866-433-1333 in
advance of when you need these services. (For your
convenience, this telephone number is also printed
on the back of your Kaiser Permanente ID card.) For
complete information about which services are covered
or excluded please refer to your Certificate of Insurance.
HEALTH INFORMATION AND EDUCATION
Our website, kp.org, has a wealth of information you
can review 24 hours a day. You can research various
topics in our health and drug encyclopedias, take
online health assessments, and view information
on our featured health topics, such as allergies,
diabetes, nutrition, and weight management.
When you’re ready to make a healthy change in your
life, knowing where to start can help you figure out
your next steps. With HealthMedia® Succeed™, our
free, online total health assessment (THA) tool, you
can get a good look at your current overall health.
It helps you prioritize what kinds of health changes
you may want to make, based not only on your risk
for developing certain health conditions, but also on
your confidence and readiness to make a change.
Once you’ve completed an online questionnaire,
you’ll receive a customized action plan to get you
started on a better, healthier you.
Visit kp.org/healthylifestyles to access Succeed. This
feature requires you to be registered and signed on
to our website. So if you haven’t registered yet,
please start by going to kp.org/register.
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Kaiser Permanente Out-of-Area Member Handbook | 5
PRIVACY NOTICE
Privacy Notice
At Kaiser Permanente, we want you to know that we’re committed to protecting your privacy. Your medical
and financial information is confidential. The Kaiser Permanente Insurance Company HIPAA privacy notice
in this section of the Member Handbook explains how we collect, store, protect, and share the personal
information of our members and former members. This notice fulfills federal disclosure requirements
mandated by the Health Insurance Portability and Accountability Act of 1996 (HIPAA).
What do you need to do?
Please take a moment to do the following:
• Review the notice. It tells you about your rights and our obligations concerning your health information.
• Share the notice with other Kaiser Permanente members in your household.
We hope you find the enclosed information helpful. We take our responsibility to protect your health
information seriously and, as in the past, we will continue to take appropriate steps to safeguard that
information. As always, thank you for entrusting your health care to Kaiser Permanente.
6 | Kaiser Permanente Out-of-Area Member Handbook
PRIVACY NOTICE
KAISER PERMANENTE INSURANCE COMPANY
HIPAA PRIVACY NOTICE
HIPAA NOTICE OF PRIVACY PRACTICES
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.
Please Note: This is Kaiser Permanente Insurance Company’s (“KPIC”) Notice of Privacy Practices
(“Notice”). This Notice refers to KPIC by using the terms “we,” “us,” and “our.”
I. What is “Protected Health Information?” • Collecting information from visitors to our Web
Your protected health information (“PHI”) is health
information that contains identifiers, such as your
name, Social Security number, or other information
that reveals who you are. For example, your medical
record is PHI because it includes your name and
other identifiers.
site such as online forms, site visit data, and other
online communications; and
• Collecting information from consumer or medical
reporting agencies or other sources such as
insurance support organizations and credit
bureaus.
In the course of administering and paying for health
care services, we collect various types of nonpublic
personal information, including PHI, from various
sources, such as you, other members, health
care professionals, your employer, your benefits
plan sponsor, or association regarding any group
coverage you may have. Such information may
include information contained in your health records,
personally identifiable information, and financial
information. KPIC collects information using a variety
of techniques. Examples include:
• Collecting information from you through surveys,
applications, related forms, and other written
requests and communications;
• Collecting information from your employer,
benefits plan sponsor, or association regarding
group coverage that you may have through group
applications, census data, and other written
requests and communications;
II. About our responsibility to protect
your PHI
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By law, we must:
1. protect the privacy of your PHI;
2. provide you with this Notice of your rights and our
legal duties and privacy practices with respect to
your PHI; and
3. follow the terms of the Notice currently in effect.
III. Your rights regarding your PHI
This section tells you about your rights regarding
your PHI, for example, your medical and billing
records maintained by or for an insurance company,
enrollment, payment, claims adjudication, case
or medical/dental management record systems
maintained by or for a health plan or insurance
company. It also describes how you can exercise
these rights.
Kaiser Permanente Out-of-Area Member Handbook | 7
PRIVACY NOTICE
Your right to see and receive copies of your PHI
In general, you have a right to see and receive
copies of your PHI in designated record sets such as
your medical and billing records maintained by or for
an insurance company, enrollment, payment, claims
adjudication, case or medical/dental management
record systems maintained by or for a health plan
or insurance company. If you would like to see or
receive a copy of such records maintained by KPIC,
please write us at:
If you believe there is a mistake in your PHI or that
important information is missing, you may request
that we correct or add to the record. Please write
to us and tell us what you are asking for and why
we should make the correction or addition. We will
respond in writing after receiving your request. If we
approve your request, we will make the correction or
addition to your PHI. If we deny your request, we will
tell you why and explain your right to file a written
statement of disagreement.
Kaiser Permanente Insurance Company
Attention: Privacy Director
One Kaiser Plaza, 25 B
Oakland, CA 94612
Your right to an accounting of disclosures of PHI
You may ask us for a list of our disclosures of your
PHI. Write to us at:
After we receive your written request, we will let
you know when and how you can see or obtain a
copy of your record. If you agree, we will give you
a summary or explanation of your PHI instead of
providing copies. We may charge you a fee for the
copies, summary, or explanation. If we do not have
the record you asked for but we know who does, we
will tell you whom to contact to request it.
In limited situations, we may deny some or all of your
request to see or receive copies of your records, but
if we do, we will tell you why in writing and explain
your right, if any, to have our denial reviewed.
Your right to choose how we send PHI to you
You may ask us to send your PHI to you at a different
address (for example, your work address) or by
different means (for example, fax instead of regular
mail). We will accommodate this request if you
clearly state that the disclosure of all or part of the
information we will disclose to you could endanger
you. However, we are permitted to charge you for
any additional cost of sending your PHI to different
addresses or by different means.
Your right to correct or update your PHI
8 | Kaiser Permanente Out-of-Area Member Handbook
Kaiser Permanente Insurance Company
Attention: Privacy Director
One Kaiser Plaza, 25 B
Oakland, CA 94612
The list we give you will include disclosures made
in the last six years, unless you request a shorter
time or if less than six years have passed since April
14, 2003. For example, if you requested a list of
disclosures on April 14, 2005, the list would cover
only two years.
You are entitled to one disclosure accounting in any
12-month period at no charge. If you request any
additional accountings less than 12 months later, we
may charge you a fee.
Except as otherwise required under state law,
an accounting does not include, for example,
disclosures to carry out treatment, payment, and
health care operations; disclosures that occurred
prior to April 14, 2003; disclosures for which KPIC
had a signed authorization; disclosures of your PHI
to you; disclosure for notification for disaster relief
purposes; or disclosures to persons involved in your
care and persons acting on your behalf.
PRIVACY NOTICE
Your right to request limits on uses and disclosures
of your PHI
You may request that we limit our uses and
disclosures of your PHI for treatment, payment, and
health care operations purposes. However, by law,
we do not have to agree to your request. Because
we believe that this information may be needed
to appropriately manage the care of individuals
covered under our health insurance plans, it is our
policy to not agree to requests for restrictions.
Your right to receive a paper copy of this Notice
You also have a right to receive a paper copy of this
Notice upon request.
IV. How we may use and disclose your PHI
Your confidentiality is important to us. Our
employees are required to maintain the
confidentiality of the PHI of our insureds and we
have policies and procedures and other safeguards
to help protect your PHI from improper use and
disclosure. Sometimes we are allowed by law to
use and disclose certain PHI without your written
permission. We briefly describe these uses and
disclosures below and give you some examples.
How much PHI is used or disclosed without your
written permission will vary depending, for example,
on the intended purpose of the use or disclosure.
Sometimes we may only need to use or disclose a
limited amount of PHI, such as to confirm that you
are a KPIC insured. At other times, we may need to
use or disclose more PHI such as when we assist in
resolving an appeal or grievance.
Treatment alternatives and health-related benefits
and services: In some instances, the law permits
us to contact you: 1) to describe our network or
describe the extent to which we offer and pay for
various products and services; 2) for your treatment;
3) for case management and care coordination;
or 4) to direct or recommend available treatment
options, therapies, health care providers, or care
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settings. For example, we may tell you about a new
drug or procedure or about educational or health
management activities.
Payment: Your PHI may be needed to determine our
responsibility to pay for, or to permit us to bill and
collect payment for, treatment and health-related
services that you receive. When you or a provider
sends us the bill for health care services, we use and
disclose your PHI to determine how much, if any, of
the bill we are responsible for paying.
Health care operations: We may use and disclose
your PHI for certain health care operations, for
example, quality assessment and improvement,
licensing, accreditation, activities relating to the
creation, renewal, or replacement of health insurance
or health benefits; conducting medical review;
legal services; auditing functions, including fraud
and abuse detection and compliance programs;
customer service, underwriting, and determining
premiums and other costs of providing health care.
Business associates: We may contract with business
associates to perform certain functions or activities
on our behalf, such as payment and health care
operations. These business associates must agree to
safeguard your PHI.
Specific types of PHI: There are stricter
requirements for use and disclosure of some
types of PHI, for example, mental health and
drug and alcohol abuse patient information or the
results of HIV/AIDS tests. However, there are still
circumstances in which these types of information
may be used or disclosed without your authorization.
Communications with family and others when you
are present: Sometimes a family member or other
person involved in your care, or payment for your
care, will be present when we are discussing your
PHI with you. If you object, please tell us and we
Kaiser Permanente Out-of-Area Member Handbook | 9
PRIVACY NOTICE
won’t discuss your PHI or we will ask the person to
leave.
Communications with family and others when
you are not present: There may be times when it is
necessary to disclose your PHI to a family member or
other person involved in your care, or payment for
your care, because there is an emergency, you are
not present, or you lack the decision making capacity
to agree or object. In those instances, we will use
our professional judgment to determine if it’s in your
best interest to disclose your PHI. If so, we will limit
the disclosure to the PHI that is directly relevant to
the person’s involvement with your health care, or
payment for your care. For example, we may allow
someone to pick up a prescription for you.
Disclosure in case of disaster relief: We may
disclose your name, city of residence, age, gender,
and general condition to a public or private disaster
relief organization to assist disaster relief efforts,
unless you object at the time.
Disclosures to parents as personal representatives
of minors: In most cases, we may disclose your
minor child’s PHI to you. In some situations, however,
we are permitted or even required by law to deny
your access to your minor child’s PHI. An example
of when we must deny such access is when you are
a nonresidential parent of a minor child and we are
presented with a court order that limits the terms
and conditions under which you may have access to
the records that pertain to your child.
Public health activities: Public health activities
cover many functions performed or authorized by
government agencies to promote and protect the
public’s health and may require us to disclose your
PHI.
For example, we may disclose your PHI as part of
our obligation to report to public health authorities
certain diseases, injuries, conditions, and vital
10 | Kaiser Permanente Out-of-Area Member Handbook
events such as births. Sometimes we may disclose
your PHI to someone you may have exposed to a
communicable disease or who may otherwise be at
risk of getting or spreading the disease.
The Food and Drug Administration (FDA) is
responsible for tracking and monitoring certain
medical products, such as pacemakers and hip
replacements, to identify product problems and
failures and injuries they may have caused. If you
have received one of these products, we may use
and disclose your PHI to the FDA or other authorized
persons or organizations, such as the maker of the
product.
We may use and disclose your PHI as necessary
to comply with federal and state laws that govern
workplace safety.
Health oversight: As a health insurer, we are
subject to oversight conducted by federal and state
agencies. These agencies may conduct audits of our
operations and activities and in that process, they
may review your PHI.
Disclosures to your employer or your employee
organization: If you are enrolled in a KPIC health
insurance plan through your employer or employee
organization, we may share certain PHI with them
without your authorization, but only when allowed
by law. For example, we may disclose your PHI for
a workers’ compensation claim or to determine
whether you are enrolled in the plan or whether
premiums have been paid on your behalf. For other
purposes, such as for inquiries by your employer or
employee organization on your behalf, we will obtain
your authorization when necessary under applicable
law.
Workers’ compensation: In order to comply
with workers’ compensation laws, we may use
and disclose your PHI. For example, we may
communicate your medical information regarding a
PRIVACY NOTICE
work-related injury or illness to claims administrators,
insurance carriers, and others responsible for
evaluating your claim for workers’ compensation
benefits.
Military activity and national security: We may
sometimes use or disclose the PHI of armed forces
personnel to the applicable military authorities when
they believe it is necessary to properly carry out
military missions. We may also disclose your PHI to
authorized federal officials as necessary for national
security and intelligence activities or for protection
of the President and other government officials and
dignitaries.
Marketing: KPIC may use and disclose your PHI to
contact you about benefits, services, or supplies
that we can offer you in addition to your KPIC health
coverage.
Required by law: In some circumstances federal
or state law requires that we disclose your PHI
to others. For example, the secretary of the
Department of Health and Human Services may
review our compliance efforts, which may include
seeing your PHI.
Lawsuits and other legal disputes: We may
use and disclose PHI in responding to a court or
administrative order, a subpoena, or a discovery
request. We may also use and disclose PHI to the
extent permitted by law without your authorization,
for example, to defend a lawsuit or arbitration.
Law enforcement: We may disclose PHI to
authorized officials for law enforcement purposes,
for example, to respond to a search warrant, report
a crime on our premises, or help identify or locate
someone.
abuse or neglect or to identify suspected victims of
abuse, neglect, or domestic violence.
Coroners and funeral directors: We may disclose
PHI to a coroner or medical examiner to permit
identification of a body, determine cause of death,
or for other official duties. We may also disclose PHI
to funeral directors.
Inmates: Under the federal law that requires us to
give you this Notice, inmates do not have the same
rights to control their PHI as other individuals. If
you are an inmate of a correctional institution or in
the custody of a law enforcement official, we may
disclose your PHI to the correctional institution or
the law enforcement official for certain purposes,
for example, to protect your health or safety or
someone else’s.
All other uses and disclosures of your PHI require
your prior written authorization.
Except for those uses and disclosures described
above, we will not use or disclose your PHI without
your written authorization. When your authorization
is required and you authorize us to use or disclose
your PHI for some purpose, you may revoke that
authorization by notifying us in writing at any time.
Please note that the revocation will not apply to any
authorized use or disclosure of your PHI that took
place before we received your revocation. Also, if
you gave your authorization to secure a policy of
insurance, including health insurance from us, you
may not be permitted to revoke it until the insurer
can no longer contest the policy issued to you or a
claim under the policy.
Abuse or neglect: By law, we may disclose PHI to
the appropriate authority to report suspected child
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Kaiser Permanente Out-of-Area Member Handbook | 11
PRIVACY NOTICE
V. How to contact us about this Notice or
to complain about our privacy practices
If you have any questions about this notice, or want
to lodge a complaint about our privacy practices,
please let us know by writing to us at:
Kaiser Permanente Insurance Company
Attention: Privacy Director
One Kaiser Plaza, 25 B
Oakland, CA 94612
You also may notify the secretary of the Department
of Health and Human Services.
We will not take retaliatory action against you if you
file a complaint about our privacy practices.
VI. Changes to this Notice
We may change this Notice and our privacy practices
at any time, as long as the change is consistent
with state and federal law. Any revised notice will
apply both to the PHI we already have about you
at the time of the change, and any PHI created or
received after the change takes effect. If we make
an important change to our privacy practices, we will
promptly change this Notice and provide the new
notice to you via the U.S. Postal Service addressed
to your last known address on file with us. Except for
changes required by law, we will not implement an
important change to our privacy practices before we
revise this Notice.
VII. Effective date of this Notice
This Notice is effective on April 14, 2003.
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