Aetna affiliates can share protected health information with each other
The Aetna entities covered by this notice are designated a single affiliated covered entity for federal privacy purposes (the Aetna ACE). Members of the Aetna ACE can share protected health information (PHI) with each other for the treatment, payment and health care operations of the ACE and as allowed by HIPAA and this notice. A full list of members is available by contacting the Aetna Privacy Office by email.
Supporting quotations
These entities have been designated as a single affiliated covered entity for federal privacy purposes.
The members of the Aetna ACE can share Protected Health Information (PHI) with each other. We do this for the treatment, payment and health care operations of the Aetna ACE and as allowed by HIPAA and this Notice.
For a full list of the members of the Aetna ACE, contact the Aetna Privacy Office at PrivacyAetna@aetna.com.
Qualifications & exceptions
Sharing is described as among members of the Aetna ACE, not with outside parties; other disclosures are covered by separate sections.
Not stated here
The list of ACE members is not in the supplied text.
Sharing & Disclosure · Permission or license
Information can move in a sale, merger or contract transfer
Among the operational activities, Aetna lists transfers of contracts from and to other EAP vendors and facilitating a sale, transfer, merger or consolidation of all or part of Aetna Resources For Living with another entity, including due diligence related to that activity. In practice, this means information about EAP members may be used or disclosed when the business or its contracts change hands.
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transfer of contracts from and to other EAP vendors; facilitation of a sale, transfer, merger or consolidation of all or part of Aetna Resources For Living with another entity (including due diligence related to such activity);
Qualifications & exceptions
Listed as an operational activity 'requiring use and disclosure'; the notice does not name any specific transaction or recipient.
Not stated here
Whether the other party must keep the information protected is not stated in this passage.
Sharing & Disclosure · Permission or license
Treatment: disclosure of PHI to health care providers
Aetna may disclose your protected health information to health care providers for the provision, coordination or management of your healthcare.
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Treatment: We may disclose your Protected Health Information to health care providers for the provision, coordination or management of your healthcare.
Not stated here
The notice does not say whether the EAP itself provides treatment or which providers are meant.
Sharing & Disclosure · Permission or license
Disclosures to other covered entities and their business associates
Aetna may disclose personal information to other covered entities, or their business associates, for treatment, payment and certain health care operations purposes. As an example, it may disclose information to other health plans maintained by your employer, if it has been arranged for Aetna to do so, so that certain expenses can be reimbursed.
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Disclosures to other covered entities: We may disclose personal information to other covered entities, or business associates of those entities for treatment, payment and certain health care operations purposes.
For example, we may disclose personal information to other health plans maintained by your employer, if it has been arranged for us to do so, in order to have certain expenses reimbursed.
Qualifications & exceptions
'Certain health care operations' is not defined in this passage.
Sharing & Disclosure · Permission or license
Research disclosures with privacy measures
Aetna may disclose personal information to researchers, provided measures are taken to protect your privacy.
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We also may disclose such information in support of:
Research – to researchers, provided measures are taken to protect your privacy.
Qualifications & exceptions
Listed among 'additional reasons for disclosure' that Aetna says it 'may' make.
Not stated here
The notice does not say what the privacy measures are or whether the research disclosure is of identifiable information.
Sharing & Disclosure · Permission or license
Business partners that assure they will protect the information
Aetna may disclose personal information to persons who provide services to it and who assure Aetna they will protect the information.
Supporting quotations
We also may disclose such information in support of:
Business partners – to persons who provide services to us and assure us they will protect the information.
Qualifications & exceptions
The protection is an assurance given to Aetna; the passage does not describe a contract or how the assurance is checked.
Sharing & Disclosure · Permission or license
Regulators and government agencies that regulate Aetna
Aetna may disclose personal information to state insurance departments, boards of pharmacy, the U.S. Food and Drug Administration, the U.S. Department of Labor and other government agencies that regulate it.
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We also may disclose such information in support of:
Industry regulations – to state insurance departments, boards of pharmacy, U.S. Food and Drug Administration, U.S. Department of Labor and other government agencies that regulate us.
Qualifications & exceptions
The named agencies are examples; the passage ends with 'and other government agencies that regulate us'.
Sharing & Disclosure · Permission or license
Workers' compensation disclosures
Aetna may disclose personal information to comply with workers' compensation laws.
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We also may disclose such information in support of:
Workers’ Compensation – to comply with workers’ compensation laws.
Not stated here
The passage does not name the recipient.
Sharing & Disclosure · Permission or license
Law enforcement, court orders and legal requirements
Aetna may disclose personal information to federal, state and local law enforcement officials, in response to a court order or other lawful process, and to comply with legal obligations and requirements.
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We also may disclose such information in support of:
Law enforcement – to federal, state and local law enforcement officials.
Legal proceedings – in response to a court order or other lawful process.
As Required by Law – to comply with legal obligations and requirements.
Qualifications & exceptions
These are separate listed reasons: law enforcement, legal proceedings and 'As Required by Law'. The wording does not require a warrant or court order for the law enforcement item.
For substance use disorder information received through a Part 2 consent, the notice sets stricter limits on use in legal cases.
Not stated here
The notice does not say what conditions Aetna applies before releasing information to law enforcement.
Sharing & Disclosure · Permission or license
Public welfare disclosures
Aetna may disclose personal information to address matters of public interest as required or permitted by law, for example child abuse and neglect, threats to public health and safety and national security.
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We also may disclose such information in support of:
Public welfare – to address matters of public interest as required or permitted by law (e.g., child abuse and neglect, threats to public health and safety and national security).
Qualifications & exceptions
The examples are introduced by 'e.g.' and are not exhaustive.
Sharing & Disclosure · Permission or license
Coroners, medical examiners, funeral directors and organ procurement groups
Aetna may disclose personal information about a deceased person to a coroner or medical examiner to identify the person, determine a cause of death or as authorized by law, and to funeral directors as necessary to carry out their duties. It may also respond to organ donation groups to facilitate donation and transplantation.
Supporting quotations
We also may disclose such information in support of:
Decedents – to a coroner or medical examiner for the purpose of identifying a deceased person, determining a cause of death, or as authorized by law; and to funeral directors as necessary to carry out their duties.
Organ Procurement – to respond to organ donation groups for the purpose of facilitating donation and transplantation.
Sharing & Disclosure · Context
Disclosed information may be redisclosed and lose HIPAA protection
The notice warns that protected health information disclosed as permitted by HIPAA may be subject to redisclosure by the recipient and no longer protected by HIPAA.
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PHI disclosed as permitted by HIPAA may be subject to redisclosure by the recipient and no longer protected by HIPAA.
Qualifications & exceptions
The warning is phrased with 'may'; the notice does not say which recipients are covered by HIPAA themselves.