Aetna uses and discloses NPI as in Section V regardless of individual preferences, as far as the law permits
Aetna says it considers the Section V activities key to administering its group life and disability plans, and gives examples: target marketing to educate employees about their benefits, quality assessment and research programs, and coordinated or integrated disability and health programs. It then says that, to the extent permitted by law, it uses and discloses NPI as provided in Section V regardless of individual preferences. The notice describes no opt-out from the Section V uses and disclosures. The one carve-out it describes is marketing, covered in the next card.
Supporting quotations
V. What personal information does Aetna and other benefits plans use or disclose to third parties, and for what purposes?
We consider the activities described in Section V key for the administration of our group life and disability benefit plans. For example, target marketing helps us to better educate employees about the benefits available to them. Quality assessment and research programs help us to review and improve the services we provide. Coordinated or integrated disability and health benefit programs let us work more effectively with members to manage their disabilities and improve their health and productivity. Therefore, to the extent permitted by law, we use and disclose NPI as provided in Section V regardless of individual preferences.
We do not disclose NPI to anyone, except with member authorization (see Section VII) or otherwise as permitted by law.
Administration of life and disability benefits policies or contracts, which may involve claims payment and management
Qualifications & exceptions
“To the extent permitted by law” limits the statement.
The statement covers uses and disclosures “as provided in Section V,” and Section V itself is stated as examples with a catch-all for “other related activities.”
Not stated here
The notice does not describe any right to object to or restrict the Section V uses and disclosures; other laws or the plan documents might, but they are not supplied.
Cross-references
qualifies (model-proposed): Aetna does not disclose NPI except with member authorization or as permitted by law — qualifies: The Section VI statement that Section V uses and disclosures occur regardless of individual preferences, to the extent permitted by law, qualifies the Section V statement that NPI is not disclosed except with authorization or as permitted by law: the permitted-by-law path is available without member preference.
Use & Processing · Restriction or exception
Earlier unfavorable underwriting decisions are not the basis for future ones without an independent evaluation
The notice says previous unfavorable underwriting decisions may not be used as the basis for future underwriting decisions unless Aetna makes an independent evaluation of the basic facts.
Supporting quotations
Previous unfavorable underwriting decisions may not be used as the basis for future underwriting decisions unless we make an independent evaluation of the basic facts.
Qualifications & exceptions
The restriction has one exception: an independent evaluation of the basic facts.
Not stated here
The notice does not say what an independent evaluation involves.
Use & Processing · Permission or license
Examples of uses: administering benefits, claims, appeals, auditing and building awareness of products
Aetna gives examples of what it does with collected information and why it might be disclosed to third parties. The first group is administration of life and disability benefits policies or contracts. It may involve claims payment and management, coordination of care, benefits and other services, response to member inquiries or requests, building awareness about Aetna’s products and programs, grievance and appeals programs, benefits and program analysis and reporting, fulfillment, and auditing and quality assessment and improvement activities. The list ends with “other activities described below.”
Supporting quotations
Here are some examples of what we do with the information we collect and the reasons it might be disclosed to third parties:
Administration of life and disability benefits policies or contracts, which may involve claims payment and management; coordination of care, benefits, and other services; response to member inquiries or requests for services; building awareness about our products and programs; conduct of grievance and appeals programs; benefits and program analysis and reporting; fulfillment;
auditing and quality assessment and improvement activities;
Qualifications & exceptions
The bullets are introduced as examples of what Aetna does and the reasons information might be disclosed to third parties.
“Building awareness about our products and programs” is a marketing-type use of NPI inside the administration list; Section VI says special authorization is sought before NPI is disclosed for marketing unrelated to the Benefits Plans.
Not stated here
The list does not say, item by item, whether the information is only used inside Aetna or also disclosed, or to whom.
Use & Processing · Permission or license
Examples of uses: risk management, fraud detection, underwriting, ratemaking and reinsurance
Among the examples of uses and disclosures, Aetna lists risk management; detection and investigation of fraud and other unlawful conduct; underwriting and ratemaking; and administration of reinsurance and excess or stop loss insurance policies, including coordination with reinsurance and excess or stop loss insurers. This means NPI may be shared with reinsurance and stop loss insurers.
Supporting quotations
risk management; detection and investigation of fraud and other unlawful conduct;
underwriting and ratemaking; administration of reinsurance and excess or stop loss insurance policies and coordination with reinsurance and excess or stop loss insurers; and other activities described below.
Qualifications & exceptions
Listed as examples within the administration bullet.
Not stated here
The notice does not say what NPI is shared with reinsurers or stop loss insurers, or how it is limited.
Use & Processing · Permission or license
Disability plan administration may be blended with health or workers compensation plans, including third-party ones
Aetna lists operation of benefits programs in which it coordinates or blends the administration or case management of its disability plans with health or workers compensation benefit plans. Those other plans may be administered by Aetna or by third parties.
Supporting quotations
Operation of benefits programs in which we coordinate or blend the administration or case management of our disability plans with health or workers compensation benefit plans administered by Aetna or third parties.
Qualifications & exceptions
The coordinated plans may be administered by “Aetna or third parties.”
Not stated here
The notice does not say what NPI is exchanged with third-party administrators of health or workers compensation plans.
Use & Processing · Permission or license
Examples of uses: performance measurement, claims analysis, research and systems management
Aetna lists performance measurement and outcomes assessment; claims analysis and reporting; and research as examples of uses. It also lists data and information systems management.
Supporting quotations
Performance measurement and outcomes assessment; claims analysis and reporting, and research.
Data and information systems management.
Qualifications & exceptions
Listed as examples of uses and possible disclosures.
Not stated here
The notice does not say who conducts the research, whether it uses identifiable information, or whether disclosure outside Aetna is involved.