Privacy Statement

At Group Health Cooperative of South Central Wisconsin (GHC-SCW), we respect your privacy.  As you navigate our website, you will find numerous mechanisms we have in place to demonstrate our commitment to privacy in the use of our website, as well as in the collection, use and disclosure of your protected health information (PHI) and financial information.

 

Website Privacy

This website may request personal information in the following ways:

1. In activating your personal account, your date of birth, e-mail address and member number are requested in order to ensure your identity.
2. In the general use of our website, other information such as IP address, browser, operating system, and the date and time each page is viewed may be collected, but it will not be used to identify you personally.
3. Any information that you provide to us on our website is considered voluntary, however, GHC-SCW will not disclose this information to anyone outside of our organization.
4. We may use your information internally for purposes related to use of or access to our website, to identify or resolve problems or in our efforts to improve or enhance the website.

 

Our Commitment to Privacy

At GHC-SCW, we respect the privacy of your information.  We demonstrate this commitment in numerous important ways including, but not limited to, acknowledgement of our legal, ethical and professional obligations as an insurer, health care provider and employer.  We commit to staying current with federal and state laws and regulations and to ongoing compliance with all external regulatory bodies that govern our organization.  We maintain comprehensive privacy policies and procedures and educate our staff regarding the application of these principles in their specific job responsibilities.  We also ensure ongoing communication of this information to our members, encouraging feedback and questions and ensuring readily-available, relevant privacy resources.

 

An important component of privacy at GHC-SCW relates to the storage of most member information in an electronic format.  While paper documents are still maintained, our organization has diligently sought and implemented state-of-the-art electronic applications for the collection, use and disclosure of our member’s health, financial and insurance information.  We feel that our member’s should be informed of these electronic solutions as well as to provide assurance that reliable mechanisms are in place to protect the privacy and security of this information in all phases of its collection, use and disclosure.  Regardless of how member information is stored:  paper, electronic, or another medium, GHC-SCW ensures that the provision of access occurs in a consistent, timely manner that protects confidential, sensitive or proprietary information from unauthorized use or access. 

 

We know that you place your trust in us to protect all of your personal information, and we take this responsibility seriously. 

Privacy Policies & Procedures

GHC-SCW maintains comprehensive policies and procedures that guide the actions and behaviors of staff as they conduct their daily work functions.   Employees have ongoing access to this information on the GHC-SCW intranet site and they are expected to understand and consistently apply these principles.  The policies and procedures include, but are not limited to, the following functions:

1. Information in the Notice of Privacy Practices. 
2. Member’s  Rights to Access to PHI
3. Member’s Right to Request Restrictions to PHI
4. Member’s Right to Request Record Amendment
5. Member’s Right to Request and Accounting of Disclosures
6. The internal protection of oral, written, and electronic information across the organization
7. Member’s are also informed of the processes to obtain additional information or clarification about GHC-SCW’s privacy practices.   For example, how to obtain a copy of the Notice of Privacy Practices, how to file a privacy complaint, how to obtain and complete an Authorization to Request Release of Health Records. 
8. This information is communicated to the member in the Member Handbook, upon enrollment, through the member publication, HouseCall and the GHC-SCW website, www.ghc-hmo.com.

How GHC-SCW Collects Member Information

Members provide us with personal information in several ways.  For example, when a potential GHC-SCW member completes an enrollment application, it is stored in our computer systems.  When a member begins to receive care in our health care facilities, clinical information such as vital signs, provider documentation, labs and x-rays initiate a medical record.  Since GHC-SCW offers not only primary care, but also services such as chiropractic care, physical therapy, optometry, mental health, and complementary medicine, the GHC-SCW medical record also contains this information.   As care continues, the medical record continues to develop and the primary care provider frequently reviews these previous records to ensure excellence in health care and treatment at GHC-SCW.  Additionally, documentation maintained between GHC-SCW and other health care organizations where members also receive care may be exchanged to ensure comprehensive and ongoing treatment.  Such information exchange occurs in compliance with applicable laws and regulations.

The GHC-SCW website, www.ghc-hmo.com may request personal information in the following ways:

1. In the activation of a personal account, the member’s date of birth, e-mail address, and member number are requested in order to ensure proper identify
2. In the general use of our website, other information such as IP address, browser, operating system, and the date and time each page is viewed may be collected, but it will not be used to identify the member personally
3. While information collected on our website is considered voluntarily provided, GHC-SCW will not disclose this information to anyone outside of the organization
4. We may use member information internally for purposes related to use of or access to our website, to identify or resolve problems or in our efforts to improve or enhance the website

Members use of applications such as MyChart or KidsChart involve the collection and use of PHI.  A secure messaging function is in place for communication between the member and the provider.  Provision of private information in this information is considered voluntary but is defined as a legal component of the GHC-SCW medical record, thus it may be disclosed in the release of information process.

If a member chooses to communicate with GHC-SCW using electronic mail (e-mail), this is not a secure or confidential transmission and is strongly discouraged.  If information is submitted to us in this manner, it is maintained as a standard document in our computer systems and its confidentiality cannot be guaranteed.

Authorization Form for Disclosure of Protected Health Information (PHI)

 GHC-SCW provides an Authorization to Disclose Member’s Protected Health Information Form.  Member’s are informed that this document is available electronically via the GHC website, www-ghc-hmo.com or in paper by contacting the Member Services Department at (608) 828-4853.  Some of the patient’s right outlined on the Authorization Form include the member’s right to inspect or receive a copy of the authorization or the information to be used or disclosed, the member’s right to refuse to sign, refuse to authorize or deny the release of information beyond treatment, payment and health care operations functions, and the right to revoke or withdraw the authorization at any time.

 How Member Information is Used and Disclosed

 Without Member Authorization

GHC-SCW routinely uses and discloses protected health information (PHI), without authorization, for the following purposes:

1. reatment, payment and health care operations
2. Appointment reminders
3. As required by law
4. Public health
5. Health oversight activities
6. Judicial & administrative proceedings
7. Law enforcement
8. Coroners, medical examiners, & funeral directors
9. Organ & tissue donation
10. Public safety
11. Worker’s compensation
12. Plan Sponsor disclosures (limitations)
13. Research
14. To those involved with your care (limitations)

With Member Authorization

Except as described above, we will not use or disclose protected health information (PHI) without the member’s written authorization.  If the member does not authorize the use or disclosure or if an existing authorization is no longer desired, it may be revoked at any time.  It would not, however, be possible to take back any disclosure already made prior to the revocation.  Additional information about the revocation process is available in the GHC-SCW Notice of Privacy Practices.  This document may be obtained in electronic format via the GHC-SCW website at www.ghc-hmo.com or a paper copy may be obtained by contacting the Member Services Department at (608) 828-4853.

GHC-SCW Member’s Rights

Member rights include:

1. Right to Request Restrictions
2. Right to Request Confidential Communications
3. Right to Access, Inspect or Copy
4. Right to Request Amendment
5. Right to Request an Accounting of Disclosures
6. Right to be Informed Regularly of the mechanisms available to obtain more information about GHC-SCW’s privacy practices, how to obtain a copy of the Notice of Privacy Practices, how to file a complaint and how to obtain and complete and authorization to disclose records

GHC-SCW’s  Privacy Responsibilities

 Our responsibilities include, but are not limited to:

1. Develop, implement and maintain comprehensive privacy policies and procedures
2. Provide education and training to staff regarding these policies and ensure ongoing application and understanding on an ongoing basis
3. Comply with federal, state and other laws, regulations and regulatory agencies governing the application of privacy across our organization
4. Ensure appropriate collection, use and disclosure of protected health information

Notice of Privacy Practices

The GHC-SCW Notice of Privacy Practices outlines member rights and organization responsibilities as they related to the collection, use and disclosure of protected health information.  The Notice was provided to all members before April 15, 2003.  Subsequently, new members are provided with the Notice in the Member Handbook.  In addition, the Notice is located on the GHC-SCW website and a paper copy may be obtained by contacting the Member Services Department at (608) 828-4853.  Member’s may choose to complete and return the Notice of Privacy Practices Acknowledgement Form in accordance with the procedure outlined on this document.

 GHC-SCW’s Privacy Protections

 Some of the steps we take to ensure the privacy of our member’s health, financial and insurance information:

1. Internal Protection of Oral, Written and Electronic Information:
1. Oral information is protected through policies and procedures and ongoing staff education.  Examples of training points include encouraging the use of a moderate voice tone & level, use of the minimum amount of information necessary, and heightened awareness of others who may hear confidential conversations conducted in the context of daily work
2. Written information is protected through the communication of policies and procedures regarding these documents.  Staff are required to keep confidential materials out of plain view, picking up faxes or printed documents immediately, and appropriate disposal of paper documents in established shredding processes.
3. Electronic information is ensured through policies and procedures, staff education such as e-mail reminders, training on development and maintenance of strong passwords, auto-secure functions,
4. Staff access to protected health information, regardless of format or medium, is based on a need-to-know.  Access is assigned based on the employee’s job role (role-based access).
5. Auditing mechanisms are in place to monitor and confirm appropriate use of all employees access into all applications and venues containing private information.
2. Plan Sponsors and Employers:  Employers or plan sponsors are provided only with the enrollment and disenrollment information necessary to administer health plan benefit programs.  In all other situations, GHC-SCW will not disclose information to employers or plan sponsors without the specific, written authorization of the member.
3. Notice of Privacy Practices, including ongoing communication to member’s, provides a detailed structure and mechanism for the protection of health information across the organization.
4. Website Privacy Statement outlines information collected and its protections.
5. Business Associate Agreements are in place with organizations outside of GHC-SCW with whom confidential information is exchanged in the performance of delegated, legitimate work related function.
6. Privacy Policies and Procedures
7. Staff Education & Training (at least annually)
8. Audit Trails & Role Based Access
9. Confidentiality Agreement:  All staff are required to attend privacy training and sign the GHC-SCW Confidentiality Agreement on the first day of employment and annually, upon performance evaluation thereafter.
10. Authorization to Disclose Protected Health Information Form
11. Availability of the GHC-SCW Privacy Officer:  The Privacy Officer is responsible for the following:
1. Develop and implement all privacy policies
2. Chair of the Confidentiality Committee
3. Works with the Confidentiality Committee to ensure appropriate access to PHI, identification of unnecessary data collection, mechanisms to limit access to PHI, and processes to review requests to use PHI
12. Ongoing Member Communications Regarding Privacy Practices is ensure through:
1. GHC-SCW website
2. HouseCall
3. Member Handbook
4. Notice of Privacy Practices

 

Privacy of Financial Information

 At GHC-SCW, we recognize that the very nature of our relationship with our members may result in the collection and sharing of information required to conduct routine business activities.  This information may relate specifically to your care and treatment, but often this processing also includes financial information.  Laws and regulations such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the Gramm-Leach-Bliley Act (GLB) outline the restrictions and expectations that GHC-SCW must honor as they relate to the use of health and financial information.  We understand and ensure compliance with these important guidelines.  You have the right to know how your financial information is used.  Most of the data collected remains within the organization and is used for purposes such as membership applications, registration forms, employment and demographic data, social security number, date of birth and health history, medications and allergies. 

In some cases, however, information is shared with other organizations or employers.  When this occurs, we are extremely careful to comply with the applicable laws and consistently exercise our respect for the privacy and security of this information.  For example, if you are being cared for at another health care facility, we may disclose health information for the purpose of treatment, payment and health care operations to ensure that you receive the best possible care.  We may also release information if an external company is performing a business function on behalf of GHC-SCW, such as a secondary insurance carrier, collection agency, actuary or claims clearinghouse.  We will not share this information with non-affiliates for their own marketing purposes and we pledge to further protect your information through the development of our privacy and security policies.  Under GLB, you are offered an opportunity to “opt-out” of allowed disclosures, but since GHC discloses information only for the purpose of treatment, payment and health care operations, in accordance with the law, or with your specific written authorization, this option is not available.

 

Standards for Ethical Conduct

GHC-SCW adheres to the following standards for ethical conduct:

1. Mission:  Our mission is to provide accessible, comprehensive, high quality care and outstanding service in an efficient and personalized manner on a prepaid basis to persons in our service area, which is Dane County, Wisconsin;
2. Compliance:  We are committed to conducting all activities in compliance with applicable federal, state and local laws.  These laws pertain to human resource activities, fraud and abuse in the Medicare and Medicaid programs, lobbying and political activity, and numerous other areas.  We ask that our vendors and business associates and their representative’s act in accordance with these laws. 
3. Consumer Orientation:  GHC-SCW is a member-sponsored consumer cooperative that (1) provides accessible comprehensive services; (2) is dedicated to high quality care; (3) provides efficient and personalized care to all members; and (4) reflects proper and ethical business practices in all we do.
4. Business Ethics:  All employees must represent GHC-SCW accurately and honestly and must not engage in any activity intended to defraud anyone of money, property, services or care.  All GHC-SCW employees must pay careful attention to business transactions with suppliers, contractors, business associates, and other third parties.  Employees must not accept offers that would result in personal benefit.  This includes gifts, favors, and other incentives to perform work in a way that benefits outside parties.  While nominal gifts are acceptable, the value of items accepted by an employee from a business associate or vendor may not exceed $25.  If a gift exceeds $25, the employee must notify his or her department manager.  If the value of cash or a gift received is over $200, the department manager must also notify the division director.  We ask that vendors, business associates and their representative’s act consistently with such standards.
5. Privacy:  As noted above, GHC-SCW is committed to the privacy of all information collected, used and disclosed, we adhere to the minimum necessary rule and we maintain a Notice of Privacy Practices that outlines in detail, the management of privacy at GHC-SCW. 
6. Conflicts of Interest:  a conflict of interest is any situation in which an employee has a financial or business interest that might conflict with the financial or business interests of GHC-SCW.  All employees much avoid conflicts of interest or the appearance of conflicts of interest.  A potential conflict of interest must be reported promptly, including relevant information relating to the impact it might have on GHC-SCW patients, their family members and others.  Talking about conflict of interest issues with supervisors, or other entity managers, or the Human Resources Department can clarify whether a true conflicts exists.  We ask that vendors and business associates act in accordance with these principles.  Awareness of any situation involving an employee that has violated, or may have violated, these standards are reported to the Human Resources Department at (608) 251-4156.

 

Cookies

GHC-SCW does collect cookies, which are bits of information, but only for purposes such as saving your personal website preferences, such as font and screen size.<

 

Terms and Conditions

 

1. Through your use of this site, you are demonstrating your agreement to its terms and conditions.
2. As such, you acknowledge that you have provided any personal information of your own free will, that you agree to its uses within the organization and affirm that GHC-SCW is not responsible for, nor liable for, any claim, loss, or damage resulting from its use.
3. Your use of this website also acknowledges your understanding of the organization’s right to change, modify, add or remove portions of any materials at any time and at our discretion.
4. Any information provided on this website is not intended to be or implied to be a substitute for professional health care and treatment.  Such services must be sought through established processes as outlined in your GHC-SCW Member Information Booklet.
5. GHC-SCW is not responsible for information provided through links available on this website.  We cannot guarantee the accuracy of information obtained in this manner.
6. Your use of this website serves as confirmation of your acceptance of these terms and conditions.
7. Acceptance of these terms and conditions acknowledges your understanding that this information is a summary of the principles outlined in the GHC-SCW Notice of Privacy Practices and information provided the Member Information Booklet.  Copies of these documents are available upon request by contacting our Member Services Department at (608) 828-4853.

 

GHC-SCW Privacy Resources

 Members may utilize any of the following mechanisms to obtain more information about privacy practices at GHC-SCW:

1. GHC-SCW Website, www.ghc-hmo.com
2. HouseCall
3. Member Handbook
4. Member Services Department at (608) 828-4853
5. Contact the GHC-SCW Privacy Officer at (608) 662-4899
6. Notice of Privacy Practices (paper copy available from Member Services Department)

If you have any questions regarding our privacy practices, please do not hesitate to contact Member Services at (608) 828-4853.