Notice of Privacy Practices
Companies Issuing This Notice
This Notice describes the privacy practices of csONE Benefit Solutions (csONE) and any other third party which assists csONE in the administration of your Flexible Benefits Plan, Health Reimbursement Arrangement, Health Savings Account, or COBRA.
The Purpose of This Notice
csONE is committed to protecting the privacy of your personal information. We are required by law to maintain the privacy of your personal information, and to give you this Notice of our privacy practices, our legal duties and your rights concerning your protected health information. In the event of a breach of your unsecured protected health information, we will notify you.
csONE must follow the practices described in this Notice as long as this Notice is in effect. This Notice will remain in effect until it is replaced. csONE reserves the right to revise or change this Notice at any time. Any such revision will affect information we already have about you and any information we receive in the future. If there is any significant change in csONE’s privacy practices, this Notice will be changed and the new Notice will be available upon your request. You may request a paper copy of this Notice at any time, and the current Notice is also available on the csONE Benefit Solutions website, www.combinedservices.com.
If you have any questions regarding this Notice, or if you wish to receive another copy, please contact:
HIPAA Privacy Officer
csONE Benefit Solutions
PO Box 1320
Concord, NH 03302-1320
1 888 227-9745
Uses and Disclosures of Your Health Information
csONE uses and discloses your protected health information only as permitted by federal and state law. For each category of uses or disclosures, we explain what we mean and present some examples. Not every use or disclosure in a category is listed. However, all of the ways we are permitted to use and disclose information fall within one of the categories. When using or disclosing protected health information or when requesting protected health information from another covered entity, we make reasonable efforts to limit the protected health information to the minimum necessary to accomplish the intended purpose of the use, disclosure, or request.
For Treatment: We may use and disclose protected health information to a health care provider who is providing treatment for you.
For Payment: We may use and disclose protected health information about you to determine eligibility for benefits, to facilitate payment for the treatment and services you receive from health care providers, and to determine coverage under your plan. For example, we may receive and exchange your protected health information with other health plans to facilitate payment and to substantiate medical claims with other plans.
For Health Care Operations: We may use and disclose protected health information about you for health care operations. These uses and disclosures are necessary to provide quality services to plan participants. For example, we may use protected health information in connection with activities to coordinate changes in coverage, quality assessment and improvement, audit services, and fraud and abuse detection, in addition to creating de-identified health information for business management and administrative services such as customer service, privacy compliance, and providing aggregated de-identified reports to plan sponsors.
As Required By Law: We will disclose protected health information about you when required to do so by federal, state or local law. For example, we may disclose protected health information when required by a court order in a litigation proceeding such as a malpractice action.
Use or Disclosure of Protected Health Information for Marketing Purposes: csONE does not use and disclose your protected health information for marketing purposes outside of health care operations communications for which csONE receives no remuneration and as permitted by law.
Sale of Protected Health Information: csONE does not sell your protected health information.
Disclosures to Your Family: We may disclose your protected health information to a family member to help you with payment for your health care to the extent permitted by law.
Disclosures to Your Employer or Group Health Plan Sponsor: We may disclose your protected health information to your employer or sponsor of your plan. The summary health information we may disclose summarizes claims history, claims expenses, and experience by the members in your group plan. In similar fashion, we may disclose to your plan sponsor information about whether you have been enrolled, are participating, or are no longer enrolled in the group plan. Your plan sponsor’s plan document may require or permit other uses and disclosures. Please ask your plan sponsor for a more complete explanation of the sponsor’s uses and disclosures of protected health information.
Disclosures You Authorize: Other uses and disclosures of protected health information not covered by this notice or the laws that apply to us will be made only with your written authorization. If you provide us authorization to use or disclose protected health information about you, you may revoke that authorization, in writing, at any time. If you revoke your authorization, we will no longer use or disclose protected health information about you for the reasons covered by your written authorization. However, we are unable to take back any disclosures we have already made with your permission, and we are required to retain our records regarding care provided to you.
Military and Veterans: If you are a member of the armed forces, we may release protected health information about you as required by military command authorities. We may also release protected health information about foreign military personnel to the appropriate foreign military authority.
Worker’s Compensation: csONE may disclose protected health information about you for worker’s compensation or similar programs, which provide benefits for work-related injuries or illness.
Health Oversight Activities: We may disclose protected health information to a health oversight agency for activities authorized by law. These oversight activities include, for example, audits, investigations, inspections, and licensure. These activities are necessary for the government to monitor the health care system, government programs, and compliance with civil rights laws.
Lawsuits and Disputes: If you are involved in a lawsuit or a dispute, we may disclose protected health information about you in response to a court or administrative order. We may also disclose protected health information about you in response to a subpoena, discovery request, or other lawful process by someone else involved in the dispute.
Law Enforcement: We may release protected health information if asked to do so by a law enforcement official:
- in response to a court order, subpoena, warrant, summons or similar process;
- to identify or locate a suspect, fugitive, material witness, or missing person;
- about the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
- about a death regarding which we have been advised may be the result of criminal conduct;
- about criminal conduct on our premises; and
- in emergency circumstances to report a crime; the location of the crime or victims; or the identity, description or location of the person who committed the crime.
National Security and Intelligence Activities: We may release protected health information about you to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law.
Inmates: If you are an inmate of a correctional institution or under the custody of a law enforcement official, we may release protected health information about you to the correctional institution or law enforcement official. This release would be necessary for the institution to provide you with health care; to protect your health and safety or the health and safety of others; or for the safety and security of the correctional institution.
Your Rights Regarding Health Information About You
You have the following rights regarding the protected health information we maintain about you:
Right to Inspect and Copy: You have the right to inspect and copy your health information which csONE maintains. To inspect and copy your health information, please contact the HIPAA Privacy Officer at the address or telephone number given above. If you request a copy of information, we may charge a fee for the costs of copying, mailing or other supplies needed to fulfill your request.
Right to Amend: If you feel your health information maintained by csONE is incorrect or incomplete, you may ask to amend the information by contacting the HIPAA Privacy Officer at the address or telephone number listed above. You may request an amendment for as long as the information is maintained by csONE. Your request may be denied if it does not include a reason to support the request. In addition, it may be denied if you request to amend information that:
- is not part of the health information maintained by csONE;
- was not created by csONE unless the person or entity creating the information is no longer available to make the amendment;
- is not part of the information you would be permitted to inspect or copy; or
- the information you seek to amend is accurate and complete.
Right to an Accounting of Disclosures: You have the right to request an “accounting of disclosures” if any such disclosure was made for any purpose other than treatment, payment or health care operations. To request an accounting of disclosures, you must submit your request in writing to the HIPAA Privacy Officer listed above. Your request must state a time period which may not be longer than six (6) years prior to the date of the request. Your request should state in what form you want the accounting of disclosures (for example, paper or electronic).
Right to Request Restrictions: You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment or health care operations. You have the right to request a restriction or limitation on health information we disclose about you to someone who is involved in your care or the payment for your treatment. Your request to limit or restrict use of your health information must be made in writing to the HIPAA Privacy Officer listed above and the request must include the information you wish to limit, whether you wish to limit use, disclosure or both, and to whom the limits may apply. For example, you could ask that we limit disclosures to your spouse or that we not disclose information about a procedure you had. We are not required to agree to your request unless the disclosure is for the purpose of carrying out payment or health care operations and is not required by law, and the protected health information pertains solely to a product or service for which you or someone other than csONE paid the health care provider in full.
Right to Request Confidential Communications: You have the right to request that we communicate with you concerning your health information only in certain ways or at certain locations. For example, you may request that we only contact you at work or by mail. Any such request must be made in writing to the HIPAA Privacy Officer listed above. Where possible, we will accommodate all reasonable requests.
Right to a Paper Copy of This Notice: Even if you have received this Notice electronically, you are entitled to receive a paper copy of this Notice. A request for a copy of the Notice should be sent to the HIPAA Privacy Officer at the address above. You may also obtain a copy of this at our website, www.combinedservices.com.
How to File a Complaint: If you believe your privacy rights have been violated by csONE, you may file a written complaint addressed to the HIPAA Privacy Officer, at the address noted above. The complaint must be in writing. Or, you may file a written complaint with the Secretary of the Department of Health and Human Services. You will not be penalized or retaliated against for filing a complaint.