The National Foot Care Program (NFCP), consistent with the Health Information Portability and Accountability Act of 1996 (HIPAA), is required to provide members notice regarding the uses and disclosures of protected health information (PHI) and your rights as a member. PHI is individually identifiable health information that is maintained or transmitted by us in any form. NFCP will maintain PHI private and protect PHI from unlawful use and disclosure. We reserve the right to change the terms of this notice and our privacy policies at any time. Any changes to this notice will be made available on our website.

• If the inquiring party verifies thier identity with NFCP and request thier own PHI.
• Payment: NFCP may use and disclose your PHI to health care providers and other plans to pay claim and other related payment activities. Examples include eligibility, claims management, pre-certification or pre-authorization, medical review, utilization review, risk adjustment of payment, billing, and subrogation.
• Health Care Operations: NFCP may use and disclose your PHI for daily operations. Examples include business management and administration, business planning and development, cost management, customer service, enrollment, underwriting, premium rating, care management, case management, legal services, audit functions, fraud and abuse detection, performance evaluation, professional training, provider credentialing, due diligence, and quality improvement or other quality initiatives.
• As Required by Law: NFCP may use and disclose your PHI as required by state and federal law. Examples include judicial and administrative proceedings pursuant to legal authority, to report information regarding victims of abuse; neglect; or domestic violence, to assist law enforcement officials in the performance of law enforcement duties; and to comply with the law and regulations related to Workers’ Compensation.

• NFCP restricts access of PHI to employees based on the minimum amount of information necessary for each employee to do their job. NFCP will maintain safeguards to protect your PHI against unauthorized access and use.
• NFCP will enter into Business Associate Agreements with individuals as necessary and as required by law. Examples include accountants, attorneys, consultants, and other individuals related to our licensure and other compliance obligations.

To exercise any of your rights listed below, you must submit a request in writing. NFCP will consider all requests but is not obligated to agree. In some circumstances, your request could result in loss of coverage. We will respond in writing with any limitations necessary.

• Communication: Communication related to payment and benefit decisions may contain PHI and is sent to the cardholder. You have the right to request that we send your PHI to you at an address of your choice or communicate with you in a certain way if you tell us it is necessary to protect you from danger.
• Limitations: You have the right to request a limit on how we use and disclosure your PHI for payment and health care operations. Except as needed for emergency situations or as required by law, all approved limitations will be honored.
• Access: You have the right to look at or receive copies of your PHI records for a reasonable fee to cover the administrative costs associated with processing your request. Additional costs may apply for specific format and summary requests.
• Disclosures: You have the right to obtain a list of certain instances where your PHI has been disclosed as required by law. This list will not include disclosures made for payment or health care operations. We will not include disclosures made prior to April 14, 2003. Requests will only be honored for a maximum of six years after April 14, 2003.
• Amendment: You have the right to request that we amend your PHI if you believe there is an error. If your request is approved, the amendment will be made and we will make reasonable efforts to ensure all individuals who need to know are informed of the change. If your request is denied, you have the right to request that your written request, our written denial, and your statement of disagreement be made part of your PHI anytime a disclosure is made.