This website is an overview of plan benefits. If there is a conflict between this website and the HUGHP benefit description, the HUGHP benefit description governs. Limitations and exclusions apply.

For your convenience, this website contains links to other websites. HUGHP disclaims liability for the content, the privacy, and the security policies on those websites.

A copy of the HUGHP benefit description may be obtained from Members Services:

Member Services
75 Mt. Auburn Street, First Floor
Cambridge, MA 02138

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.

Harvard University Group Health Plan is committed to protecting the privacy of our members:

We understand that medical information about you is personal, and that protecting that information is important. In order to provide you with quality care, customer service, and to comply with certain legal and accreditation requirements, we create records of your enrollment, referral authorizations, and the claims generated from all the medical care you receive as a member of Harvard University Group Health Plan (HUGHP). This notice tells you the ways in which we may use and disclose your personal, individually identifiable health information and our obligations to keep your information private. This notice also describes your privacy rights.

We are required by law to protect the privacy of individually identifiable health information about you (“Your Protected Health Information”), to give you this notice of our legal duties and our privacy practices, to follow the terms of this notice, and to notify you in the event you are affected by a breach of unsecured Protected Health Information.

Who will follow this notice:

This notice applies to HUGHP HMO, HUGHP POS, and HUGHP POS Plus hereafter referenced to as “the Plan”. It applies to all HUGHP HMO, HUGHP POS, and HUGHP POS Plus employees and other persons under the direct control of the Plan.

How we may use and disclose your protected health information:

The following categories show the different ways we may use and disclose to others Your Protected Health Information. For each category we give some examples, but not every use or disclosure in a category is listed. Your Protected Health Information will not be used or disclosed for purposes other than those described in this notice without your written authorization.

For Treatment: Your Protected Health Information may be used or disclosed by us to facilitate your treatment and for the coordination and management of your health care.  For example, a doctor treating you for a particular condition may need to obtain information from us about prior treatment of a similar or different condition, including the identity of the health care provider who treated you previously.

For Payment: Your Protected Health Information may be used and disclosed by HUGHP to let your health care providers know that anticipated services will be, or will not be, covered by the plan, for example, to make coverage determinations, administer claims and coordinate benefits with other coverage you may have. Your Protected Health Information may also be used and disclosed to pay for health care you have received, or may be disclosed to another health plan or provider for its payment activities. For example, a doctor submits a claim to us following your hospital visit for knee surgery and we pay the provider for that service.

For Health Care Operations: Your Protected Health Information may be used or disclosed for a variety of healthcare-related purposes that are necessary for HUGHP to function. We may use your Protected Health Information to ensure that all our plan members receive quality care and to ensure that HUGHP continues to comply with federal and state laws. For example, we may use your Protected Health Information to do business planning and conduct quality assessments and improvement activities.  We may also disclose Your Protected Health Information to another health plan or health care provider that has or had a relationship with you for it to conduct quality assessment and improvement activities, accreditation, certification, licensing, or credentialing activities; or for the purpose of health care fraud or abuse detection or compliance. In addition, we may use or disclose Your Protected Health Information to contact you to tell you about alternative treatments or health-related benefits and services that may be of interest to you.

Disclosures to the plan sponsor:

Your Protected Health Information may be disclosed to certain employees or other individuals under our control as necessary for them to carry out our responsibilities to administer HUGHP's payment and health care operations activities. Except as provided by exceptions listed in this privacy notice, we are not permitted to use Your Protected Health Information disclosed by or on behalf of HUGHP for any other purpose without your authorization. The plan documents identify by position the specific employees or other individuals under our control who are authorized to have access to or receive Your Protected Health Information for plan administration purposes. We cannot use Your Protected Health Information obtained from HUGHP for any employment-related actions or to administer plans that are not subject to HIPAA without your authorization.  However, health information derived from other sources, for example in connection with an application for disability benefits or for approval of a FMLA leave, is not protected by HIPAA.

Special Situations: In addition to the above, there may be times when we use or disclose Your Protected Health Information for the following reasons:

• As Required By Law: We will disclose Your Protected Health Information when required to do so by federal, state, or local law.
• Third Parties: We may disclose Your Protected Health Information to third party business associates who assist in plan administration. Third parties include third party administrators, consultants, lawyers and other service vendors. We will obtain assurances from our business associates that they will appropriately safeguard Your Protected Health Information.
• Health Oversight and Public Health Activities:  We may disclose Your 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 laws. We may also disclose Your Protected Health Information to public authorities for purposes of preventing or controlling disease, reporting child abuse or neglect or certain other public health reasons.
• Lawsuits and Disputes: We may disclose Your Protected Health Information about you in response to a subpoena, discovery request, or other lawful order from a court. We will take reasonable steps to notify you or your attorney before responding to such requests.
• Law Enforcement: We may release Your Protected Health Information as part of law enforcement activities: in investigations of criminal conduct or of victims of crime; in response to court orders; in emergency circumstances; or when required to do so by law.
• Workers’ Compensation: We may disclose Your Protected Health Information as necessary to comply with workers' compensation laws.

Exceptions: Federal and state law require special privacy protections for certain health information regarding drug and alcohol information, genetic testing information and HIV test results. We will abide by all applicable state and federal laws related to the protection of this information. In order for us to disclose any information that is entitled to special restrictions, we must obtain your separate, specific consent, unless we are otherwise permitted by law to make such disclosure.

Uses and disclosures requiring your authorization:

Your prior authorization is required for most uses and disclosures of psychotherapy notes, most uses and disclosures of Your Protected Health Information for marketing purposes, and for the sale of Your Protected Health Information.

Your rights regarding health information about you:

You have the following rights regarding Your Protected Health Information:

Right to Inspect and Copy: With certain exceptions, you have the right to access and/or receive a copy of your Protected Health Information maintained by HUGHP. Usually, this includes enrollment, payment, claims adjudication, and case or medical management record systems maintained by or for HUGHP. In the event we use or maintain an electronic health record with respect to Your Protected Health Information, you shall have the right to obtain a copy of such information in an electronic format and, if you choose, to direct us to transmit such copy directly to another recipient.

To inspect and copy Your Protected Health Information, you must submit your request in writing to Member Services. If you request a copy of the information, we may charge a reasonable fee for the costs of copying and postage. Under limited circumstances, HUGHP may deny you access to a portion of your records.

Right to Request Amendment: If you feel that the Protected Health Information we have about you in the set of records we maintain is incorrect or incomplete, you may ask us to amend the information. You have the right to request an amendment for as long as the information is kept by HUGHP.

To request an amendment, your request must be made in writing and submitted to our Privacy Officer.  In addition, you must provide a reason that supports your request. You may obtain a form for this purpose from the Privacy Officer.

If we deny your request, we will provide you with a written explanation of why we did not make the amendment and explain your rights. You may then submit a written statement disagreeing with our denial.

Right to an Accounting of Disclosures: You have the right to an “accounting” (a list or report) of disclosures of Your Protected Health Information, with certain exceptions. To request this list or accounting of disclosures, you must submit your request in writing to our Privacy Officer. Your request must state a time period that may not be longer than six years prior to the request date. The first list you request within a 12-month period will be free. For additional lists during the same 12-month period, we may charge you for the cost of providing the list. We will notify you of the cost involved and you may choose to withdraw or modify your request at the time before any costs are incurred. To the extent we use or maintain an electronic health record with respect to Your Protected Health Information, you have the right to an accounting for disclosures that is also related to treatment, payment, or healthcare operations for a period of three years prior to the date on which the accounting is requested.

Right to Request Restrictions: You have the right to request a restriction or limitation on Your Protected Health Information we use or disclose for treatment, payment, or health care operations. We will comply with your restriction requests if the disclosure is not related to your treatment and the services to which Your Protected Health Information relates have been paid out of pocket and in full. You also have the right to request a limit on Your Protected Health Information we disclose to someone who is involved in your care or the payment of your care, such as a family member or friend. We are not required to agree to your request. If we do agree, we will comply with your request unless the information is needed to provide you with emergency treatment. To request restrictions, you must make your request in writing to our Privacy Officer. In your request, you must state (1) what use or disclosure you want to limit, (2) what information you want to limit, and/or (3) to whom you want the limits to apply. No agreement to comply with a requested restriction shall be effective unless an authorized representative of HUGHP signs the agreement.

Right to Request Confidential Communications: You have the right to request and we will accommodate any reasonable written request to our Privacy Officer to receive Your Protected Health Information by alternative means of communication or alternative locations. Please note that in certain instances such as eligibility and enrollment concerns, the health plan is obliged to communicate directly with the employee rather than a dependent member.

Right to a Paper Copy of This Notice: You have the right to a paper copy of this notice at any time, even if you have agreed to receive this notice electronically. To obtain a paper copy of this notice, please request one from Member Services.

Right to Notice of Breach: In the unlikely event of a breach of unsecured Personal Health Information which causes you a significant risk of financial, reputational or other harm, we shall notify you of such breach. We will send you written notice of the breach via first class mail to your last known address, unless you have indicated a preference for email. The notice will include, among other things, a brief description of what happened, a brief description of the types of unsecured personal health information that was disclosed in the breach, steps that you should take to protect yourself from potential harm resulting from the breach, a brief description of our actions taken to investigate the breach, mitigate the harm and protect against further breaches and contact procedures to learn additional information.

Changes to this notice:

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for health plan information we already have about you as well as any information we receive in the future. We will post a copy of the current notice on our website (www.hughp.harvard.edu). Our notice will always contain the effective date in the top right-hand corner of the first page.

Complaints:

If you believe your privacy rights have been violated or we are not in compliance with these privacy practices, you may file a complaint with the Plan’s Privacy Officer or with the Office of Civil Rights at the Department of Health and Human Services. To file a complaint with HUGHP, write to our Privacy Officer whose address is listed below. All complaints must be submitted in writing.

The Privacy Officer and Harvard University Group Health Plan will investigate all complaints. You will not be penalized in any way for making a complaint.

Complaints filed with the Secretary of Health and Human Services must be in writing and must be sent within 180 days of when you knew (or should have known) that the act or omission occurred to the Office of Civil Rights, U.S. Department of Health and Human Services, JFK Building, Room 1875, Government Center, Boston, MA 02203. Your letter must include: the name of the plan, and a description of the acts or omissions that you believe are in violation of privacy requirements.

Other uses of health plan information:

Other uses and disclosures of health plan information not covered by this notice will be made only with your written authorization. If we obtain your written authorization to disclose Your Protected Health Information for any reason not stated in this notice you may revoke your written authorization, except to the extent that we have taken action in reliance upon it, by delivering a written revocation statement to the Privacy Officer identified below.

Limitations on application of this notice:

This Notice does not apply to information that does not identify an individual and with respect to which there is no reasonable basis to believe that the information can be used to identify an individual. In addition, the Plan may use or disclose "summary health information" to Harvard University, the Plan Sponsor, for purposes of obtaining premium bids or modifying, amending or terminating the plan. Summary health information is information that summarizes claims history, claims expenses or types of claims experienced by individuals for whom the Plan Sponsor provides benefits under the plan and from which individual identifying information, other than a zip-code, has been deleted. The Plan and the Plan Sponsor may also use or disclose eligibility and enrollment information without your authorization.

Contact Information:

To request any of the above rights, or for further information about this Privacy Notice, please contact us as directed below:

Harvard University Group Health Plan
Attn: Privacy Officer
75 Mt. Auburn Street
Cambridge, MA 02138
(617) 496-1630

The Harvard University Group Health Program (HUGHP) is committed to protecting your privacy. This Privacy Policy applies to the HUGHP website and governs data collection and usage. By using the HUGHP website, you consent to the data practices described in this Policy.

The HUGHP website intends to provide general information about HUGHP, its services, and practice locations. HUGHP intends to keep the information on the website as current as possible, but does not guarantee its accuracy, timeliness, and completeness, and any other warranty, express or implied.

The HUGHP website is not intended to provide medical advice or medical treatment. Please consult with a health care provider for treatment or to answer your questions.

Collection of information

HUGHP website collects information about your computer hardware and software such as: your IP address, browser type, domain names, access times, and referring website addresses. HUGHP uses this information for the operation of the website, to maintain quality of the service, and to provide general statistics regarding use of the HUGHP website.

Use of personal information

HUGHP website collects and uses some personal information to operate the HUGHP website. For example, if you submit an inquiry through a web form on a contact-us page, you may be asked to include your name and/or email address so that we can reach you to resolve your comment.

HUGHP website does not sell, rent, or lease visitor information to third parties. All such third parties are prohibited from using your personal information except to provide these services to the HUGHP website, and they are required to maintain the confidentiality of your information.

HUGHP website will only disclose your personal information without notice if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on HUGHP website; (b) protect and defend the rights or property of HUGHP website; and, (c) act under exigent circumstances to protect the personal safety of users of HUGHP website, or the public.

Use of cookies

Cookies are small files that are stored on your computer (unless you block them). We use cookies to understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the HUGHP website.

Cookies may be set by an organization other than Harvard.edu. These “third-party cookies” may, for example, originate from websites such as YouTube, Twitter, Facebook, Google Plus or other services for which HUGHP has implemented “plug-ins.” Since the cookie policies of these sites change over time, you should determine their policies by visiting the privacy policy pages of these sites directly.

Security of personal information

HUGHP website secures your personal information from unauthorized access, use, or disclosure. HUGHP website secures the personally identifiable information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use, or disclosure.

Links to external third-party websites

The HUGHP website may provide links to some external, non-HUGHP websites for your convenience. HUGHP is not responsible for the accuracy, availability, or content of any non-HUGHP sites, nor does HUGHP endorse them.

HUGHP encourages you to review the privacy statements of websites you choose to link to from the HUGHP website so that you can understand how those websites collect, use, and share your information. HUGHP is not responsible for the privacy statements or other content on websites outside of the HUGHP website.

Changes to this statement

We may change this Privacy Policy from time to time. If we change the Policy, we will post the modified text on this page.

Contacting this website

If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, contact the Harvard University Health Services Webmaster at webmaster@huhs.harvard.edu.

Effective date

The effective date of this policy is May 14, 2014.