Billing Manual for Community Care Network Providers

APPENDIX A.2. ConfidentialityPOLICYCommunity Care, our staff and agents, shall protect the confidentiality of all confidentialdata and information to which they have access. “Confidential” information is defined asany information from which the member could be identified. The purpose of this policy isto assure that all data and information obtained by Community Care, and ourrepresentatives, are maintained and used with the degree of confidentiality and securitythat the data and information warrant. In addition Community Care shall follow allfederal, state, and other regulatory guidelines about privacy and security of protectedhealth information (PHI).PROCEDUREGeneral Confidentiality ProvisionsCommunity Care has designated the privacy officer to oversee company policies andprocedures regarding confidentiality and privacy. The specific functions for which theprivacy officer is responsible include but are not limited to: Annual review of all confidentiality policies. Annual training of Community Care employees on confidentiality. Follow-up to concerns of members or providers regarding confidentiality.The Fraud, Waste, and Abuse (FWA) Department will assist the privacy officer withthese responsibilities as required and requested.Community Care employees, staff, and volunteers are required to sign CommunityCare’s “Statement of Confidentiality” agreeing to be bound by strict confidentialitypolicies and procedures, including all federal and state laws, and the Health InsurancePortability and Accountability Act of 1996 (HIPAA). Signed “Statements ofConfidentiality” are maintained by Community Care’s FWA Department.CommunityCare business associates potentially having access to confidential information arerequired to sign Community Care’s “Statement of Confidentiality” agreeing to be boundby Community Care’s strict confidentiality policies and procedures or must conform toequivalent provisions as determined by Community Care staff or legal counsel.Breach of the “Statement of Confidentiality” or equivalent is grounds forimmediate termination.When Community Care becomes aware of a breach in confidentiality: The privacy officer will alert senior management of the breach of confidentiality. An investigation regarding the breach of the member’s (or provider’s) confidentialitywill be conducted by, or under the direction of, the privacy officer. All necessary staff will be interviewed. Any physical material involved will be reviewed.Community Care Provider Manual | 1-888-251-CCBH | © 2012 All Rights Reserved | Page 130