NOTICE OF PRIVACY POLICY

Phillips Administrative Service, Inc., is committed to superior customer service in the administration of your group health plan. We understand that medical information about you and your health is personal. We are committed to protecting the confidentiality of nonpublic and medical information about you. We are required by law to make sure that medical information which identifies you is kept private, to give you this notice of our legal duties and privacy practices with respect to medical information about you, and to follow the terms of the notice that is currently in effect. We create a record of the health care claims reimbursed under the Plan for Plan administration purposes. We have physical, electronic, and organizational safeguards in place in order to ensure that your private information is always protected. This notice applies to all of the medical records we maintain. This notice will tell you about the ways in which we may use and disclose medical information about you.

We do not sell your information to any third party for marketing or any other purpose, and we do not use your personal information for any investigative consumer reporting. We may use and disclose medical information about you to determine eligibility for Plan benefits, to facilitate payment for the treatment and services you receive from health care providers, to determine benefit responsibility or medical necessity under the Plan, or to coordinate Plan coverage. We may share medical information with a pharmacy benefit provider, a case management service provider, utilization review or precertification service provider, or a stop loss company. We may also share medical information with another entity, or plan, in order to assist with the adjudication or subrogation of health claims or to coordinate benefit payments. We may use or disclose medical information about you to facilitate medical treatment or services by providers. We may use medical information in connection with conducting quality assessment and improvements, underwriting, premium rating, and other activities relating to Plan coverage, submitting claims for stop-loss coverage, conducting or arranging for medical review, legal services, audit services, and fraud and abuse detection programs, business planning and development such as cost management, business management and general Plan administrative activities. We will disclose medical information about you when required to do so by federal, state, or local law. For example, we may disclose medical information when required by a court order in a litigation such as a malpractice action or fraud.

We may collect and use information which we believe is necessary in order to conduct our business and provide you with the best possible customer service. We may collect enrollment forms, waiver forms, continuation election forms, change of address forms, and other similar documents completed by you. We may also request divorce decrees, proof of paternity, court orders or Qualified Medical Child Support Orders for help in determining coverage eligibility or coordination. We may collect medical records from healthcare providers in order to assist us in processing your healthcare claims. This may include medical histories, chart notes, emergency room reports, operative or pathology reports, letters of medical necessity, case notes, x-rays, and any other type of medical reports we request and receive on your behalf. We may collect information for verification of pre-existing conditions or verification of continuous coverage or certificate of creditable coverage. We may request information from other carriers pertaining to your eligibility, such as verification of prior coverage, or coordination of benefits. We may ask your employer for information that pertains to your eligibility, such as your hire date or address.

You have a right to inspect and copy medical information that may be used to make decisions about your Plan benefits. In order to inspect and copy medical information which may be used to make decisions about you, you must submit a written request to Phillips Administrative Service, Inc., PO Box 218, Albany, OR 97321. If you request a copy of the information, we may charge a fee for the cost of copying, mailing or the cost of other supplies associated with your request.

We reserve the right to change this notice. We reserve the right to make the revised or changed notice effective for medical 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 the Plan website. The notice will contain the effective date of that notice on the first page, in the lower right-hand corner.

If you believe your privacy rights have been violated, you may file a complaint with the Secretary of the Department of Health and Human Services. To file a complaint with the Plan, contact Phillips Administrative Service, Inc., PO Box 218, Albany, OR 97321. All complaints must be submitted in writing. You will not be penalized for filing a complaint.

(In the case of conflicting information, your Schedule of Benefits takes precedence.)

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