Aetna entities designated as one affiliated covered entity can share protected health information
In this notice "Aetna," "we," "us" and "our" refer to all of the HMO and licensed insurer subsidiaries of Aetna Inc. Those entities are designated as a single affiliated covered entity for federal privacy purposes, and its members can share protected health information with each other for treatment, payment and health care operations of the affiliated covered entity and as HIPAA and this notice allow.
Supporting quotations
For purposes of this notice, “Aetna” and the pronouns “we,” “us” and “our” refer to all of the HMO and licensed insurer subsidiaries of Aetna Inc. 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 among members is for treatment, payment and health care operations of the affiliated covered entity, or as HIPAA and the notice allow.
Not stated here
The notice does not list the members of the affiliated covered entity; it says to contact the Aetna Privacy Office for the list.
Sharing & Disclosure · Company practice
Information may be disclosed to facilitate a sale, merger or transfer of the plan business, including due diligence
As a health care operations activity, Aetna may use and disclose personal information to facilitate a sale, transfer, merger or consolidation of all or part of Aetna Student Health with another entity, including due diligence related to that activity. It also lists transferring policies or contracts from and to other health plans.
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facilitation of a sale, transfer, merger or consolidation of all or part of Aetna Student Health with another entity (including due diligence related to such activity)
transfer of policies or contracts from and to other health plans
Not stated here
The notice does not say who the other entity would be, what information would be disclosed, or whether members would be notified.
Sharing & Disclosure · Company practice
Explanation of Benefits forms and claim information are mailed to the subscriber
Aetna mails Explanation of Benefits forms and other information to the address it has on record for the subscriber, meaning the primary insured. That can include claim information about a covered dependent.
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We also mail Explanation of Benefits forms and other information to the address we have on record for the subscriber (i.e., the primary insured).
Qualifications & exceptions
The Your Legal Rights section lets you ask Aetna to communicate at a different address or in a certain way, and says Aetna will accommodate reasonable requests; it also describes a way to stop paper mailing of Explanation of Benefits forms.
Not stated here
This passage does not itself say that the subscriber receives information about adult dependents; the notice's later example of an adult dependent wanting a different address suggests it can.
Sharing & Disclosure · Company practice
Claims information is available to subscribers and covered dependents on the Navigator health site
Aetna makes claims information available to subscribers and covered dependents on its Navigator health site.
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In addition, we make claims information available to subscribers and covered dependents on the Navigator® health site.
Not stated here
The notice does not say how access to the site is controlled or what claim detail each covered dependent can see.
Sharing & Disclosure · Company practice
Treatment: Aetna may disclose information to doctors, pharmacies, hospitals and other providers who care for you
Aetna may disclose information to doctors, dentists, pharmacies, hospitals and other health care providers who take care of you. It gives as an example doctors requesting medical information from Aetna to add to their own records, and says it may send certain information to doctors for patient safety or other treatment-related reasons.
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Treatment: We may disclose information to doctors, dentists, pharmacies, hospitals, and other health care providers who take care of you. For example, doctors may request medical information from us to supplement their own records. We also may send certain information to doctors for patient safety or other treatment-related reasons.
Qualifications & exceptions
The recipients are providers who take care of you.
Sharing & Disclosure · Company practice
Aetna may disclose information to other covered entities and their business associates
Aetna 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, it may disclose information to another health plan, such as a parent's plan covering you as a dependent, if arrangements have been made to do so to have certain expenses 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 (i.e. if you are covered as a dependent under a parent’s plan) if it has been arranged for us to do so in order to have certain expenses reimbursed.
Qualifications & exceptions
Limited to treatment, payment and "certain" health care operations purposes.
Not stated here
The notice does not say which health care operations purposes are covered by "certain."
Sharing & Disclosure · Company practice
Plan administration: disclosure to your school when plan documents contain appropriate language
Aetna may disclose information to your school for plan administration when it has been informed that appropriate language is included in your plan documents.
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Plan Administration – to your school, when we have been informed that appropriate language has been included in your plan documents.
Qualifications & exceptions
Applies only when Aetna has been informed that appropriate language has been included in the plan documents.
Not stated here
The notice does not say what information goes to the school, what the "appropriate language" is, or who informs Aetna.
Sharing & Disclosure · Company practice
Research: disclosure to researchers when privacy protection measures are taken
Aetna may disclose information to researchers, provided measures are taken to protect your privacy.
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Research – to researchers, provided measures are taken to protect your privacy.
Qualifications & exceptions
Conditioned on measures being taken to protect your privacy.
Not stated here
The notice does not say what those measures are, who decides they are adequate, or whether the information is identifiable.
Sharing & Disclosure · Company practice
Business partners: disclosure to service providers who assure Aetna they will protect it
Aetna may disclose information to persons, including student health centers, who provide services to Aetna and assure Aetna they will protect the information.
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Business Partners – to persons, including student health centers, who provide services to us and assure us they will protect the information.
Qualifications & exceptions
Conditioned on the recipient assuring Aetna that it will protect the information.
Not stated here
The notice does not say what services these partners provide, how many there are, or what form the assurance takes.
Sharing & Disclosure · Company practice
Decedents and organ donation: coroners, medical examiners, funeral directors and organ donation groups
Aetna may disclose information to a coroner or medical examiner to identify a deceased 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 disclose information to organ donation groups to facilitate donation and transplantation.
Supporting quotations
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 · Company practice
Aetna may disclose information to relatives, friends and others involved in your care or payment
Aetna may disclose health information to a Student Health Center, a relative, a friend, the subscriber of your plan, or any other person you identify, provided the information is directly relevant to that person's involvement with your health care or payment for it. For example, if a family member, student health center, school department providing a service function for Aetna, or other caregiver calls with prior knowledge of a claim, Aetna may confirm whether the claim has been received and paid.
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We may disclose health information about you to a Student Health Center, a relative, a friend, the subscriber of your health benefits plan or any other person you identify, provided the information is directly relevant to that person’s involvement with your health care or payment for that care.
For example, if a family member, a student health center, or a school department providing a service function for us, or other caregiver calls us with prior knowledge of a claim, we may confirm whether or not the claim has been received and paid.
Qualifications & exceptions
Limited to information directly relevant to the person's involvement with your care or payment for it.
Not stated here
The notice does not say how Aetna verifies who is calling or whether it confirms more than whether a claim was received and paid.
Sharing & Disclosure · Restriction or exception
Health information disclosed as HIPAA permits may be redisclosed by the recipient and no longer protected by HIPAA
The notice warns that protected health information disclosed as HIPAA permits may be redisclosed by the recipient and may then no longer be 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.
Not stated here
The notice does not say whether other laws or the recipient's own policies would still protect the information.