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Billing Manual for Community Care Network Providers

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POLICY<strong>Community</strong> <strong>Care</strong>, our staff and agents, shall protect the confidentiality of all confidentialdata and in<strong>for</strong>mation to which they have access. “Confidential” in<strong>for</strong>mation is defined asany in<strong>for</strong>mation by which the member could be identified. The purpose of this policy isto assure that all data and in<strong>for</strong>mation obtained by <strong>Community</strong> <strong>Care</strong>, and ourrepresentatives, are maintained and used with the degree of confidentiality and securitythat the data and in<strong>for</strong>mation warrant.PROCEDUREGeneral Confidentiality Provisions<strong>Community</strong> <strong>Care</strong> has designated the privacy officer to oversee company policies andprocedures regarding confidentiality and privacy. The specific functions <strong>for</strong> which theprivacy officer is responsible include but are not limited to:Annual review of all confidentiality policies.Annual training of <strong>Community</strong> <strong>Care</strong> employees on confidentiality.Follow-up to concerns of members or providers regarding confidentiality.The Compliance Department will assist the privacy officer with these responsibilities asrequired and requested.<strong>Community</strong> <strong>Care</strong> employees, staff, and volunteers are required to sign <strong>Community</strong><strong>Care</strong>’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 <strong>Community</strong> <strong>Care</strong>’s Compliance Department.<strong>Community</strong> <strong>Care</strong> business associates potentially having access to confidentialin<strong>for</strong>mation are required to sign <strong>Community</strong> <strong>Care</strong>’s “Statement of Confidentiality”agreeing to be bound by <strong>Community</strong> <strong>Care</strong>’s strict confidentiality policies and proceduresor must con<strong>for</strong>m to equivalent provisions as determined by <strong>Community</strong> <strong>Care</strong> staff orlegal counsel.Breach of the “Statement of Confidentiality” or equivalent is grounds <strong>for</strong>immediate termination.When <strong>Community</strong> <strong>Care</strong> becomes aware of a breach in confidentiality:The privacy officer will alert senior management of the breach.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.<strong>Community</strong> <strong>Care</strong> Provider <strong>Manual</strong> | 1-888-251-CCBH | © 2012 All Rights Reserved | Page 171

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