Aetna may use and disclose your information in various ways, including those listed
In administering your EAP Program, Aetna says it may use and disclose personal information about you in various ways 'including' the uses described next (health care operations, payment, treatment, and disclosures to other covered entities). The word 'including' means the list is illustrative. The notice later adds that for situations other than those it describes Aetna will ask for your written authorization, and that stricter state or federal protections for sensitive information are followed where they apply.
Supporting quotations
In administering your EAP Program, we may use and disclose personal information about you in various ways, including:
Qualifications & exceptions
Modal wording is 'may', not 'will': the notice permits these uses and does not say each one happens for every member.
Later sections require written authorization for situations not described and require following stricter or more protective laws for sensitive information; those limits apply to this general permission.
Use & Processing · Permission or license
Health care operations: running the business, fraud detection, contract and company transfers
Aetna may use and disclose personal information for the operations of its health business, including quality assessment and improvement, licensing, accreditation by independent organizations, performance measurement and outcomes assessment, health services research, and preventive health, disease management, case management and care coordination. It also lists detecting and investigating fraud, administering payments, and other general administrative activities such as data information systems management and customer service.
Supporting quotations
Health care operations: We may use and disclose personal information during the course of running our health business – that is, during operational activities such as quality assessment and improvement; licensing; accreditation by independent organizations; performance measurement and outcomes assessment; health services research; and preventive health, disease management, case management and care coordination.
Other operational activities requiring use and disclosure include detection and investigation of fraud; administration of payments;
and other general administrative activities, including data information systems management, and customer service.
Qualifications & exceptions
'Such as' and 'include' mark the activities as examples. The permission is for operations, not stated to require your consent.
Use & Processing · Permission or license
Payment: reviews, collection, cost-sharing and disclosure to your provider
To arrange payment for your EAP services, Aetna may use and disclose personal information to conduct utilization and medical necessity reviews, coordinate care, collect payments, calculate cost-sharing amounts, and respond to complaints, appeals and requests for external review. As an example, it may use your medical history and other health information to decide whether a treatment is medically necessary and what payment should be, and may disclose information to your provider during that process.
Supporting quotations
Payment: To arrange payment for your EAP services, we may use and disclose personal information in a number of ways – in conducting utilization and medical necessity reviews; coordinating care; collecting payments; calculating cost-sharing amounts; and responding to complaints, appeals and requests for external review.
For example, we may use your medical history and other health information about you to decide whether a particular treatment is medically necessary and what the payment should be – and during the process, we may disclose information to your provider.
Qualifications & exceptions
'In a number of ways' and 'for example' mean the activities are illustrative.
Use & Processing · Permission or license
Treatment alternatives, reminders and other health-related benefits and services
Aetna may use or disclose personal information about you in providing you with treatment alternatives, treatment reminders or other health-related benefits and services.
Supporting quotations
We may use or disclose personal information about you in providing you with treatment alternatives, treatment reminders or other health-related benefits and services.
Qualifications & exceptions
The notice separately says it asks for your written authorization for marketing purposes that are unrelated to your benefit plan(s); this passage covers benefits and services, not unrelated marketing.
Not stated here
The notice does not say who provides these benefits and services or how often they are offered.
Use & Processing · Company commitment
Substance use disorder information: Aetna is not a treatment program
Aetna says it is not a substance use disorder treatment program but may receive or keep information about you that comes from one. If such a program provides the information through a 42 CFR Part 2 consent, including a consent for future uses and disclosures for treatment, payment and health care operations, Aetna says it will use or share the information in accordance with both the consent and HIPAA.
Supporting quotations
We are not a substance use disorder treatment program. We may receive or keep information about you that comes from a substance use disorder program.
If a substance use disorder program provides us this information through a 42 CFR Part 2 consent, including a consent for future uses and disclosures for treatment, payment, and health care operations, we will use or share that information in accordance with both the consent and HIPAA.
Qualifications & exceptions
Applies when the information arrives through a Part 2 consent.
Not stated here
The notice does not say what a Part 2 consent covers beyond the quoted description, or what happens to information that arrives without one.