Billing Manual for Community Care Network Providers

Community Care does not collect information on the following; in regards to organ andtissue donation or the deceased member’s wishes, information about decedents,information for fundraising purposes, or information for marketing purposes. In the eventthe Community Care would collect information on any of the above, an appropriatepolicy and procedure will be drafted.Disclosure of Information to EmployersCommunity Care does not share member identifiable data or information withemployers without the authorization of the subscriber, member, or member’s legallyauthorized representative and only the specific information requested will be releasedin accordance with all federal and state laws. All authorizations for the release ofinformation will be verified by Community Care prior to the information being sent. Community Care recognizes that the member or member’s legally authorizedrepresentative, and not a subscriber (unless the subscriber is also the member orthe member’s legally authorized representative) is the preferred individual fromwhom to obtain authorization to release member identifiable information to anemployer. Community Care also acknowledges, however, that current industry practice is forthe subscriber, and not each member, to sign authorization forms and otherdocuments at the time of enrollment. Requiring the signature of each member ormember’s legally authorized representative at the time of enrollment is impractical. Community Care accepts its role as an advocate of the members’ rights and willwork to effect change in the industry to increase protections for confidential memberidentifiable data and information. Community Care follows all state and federal lawsand regulations.When Community Care is responsible for managing the enrollment process,Community Care obtains authorization from a subscriber at the time of enrollment torelease the minimum member identifiable data or information to the employer.In many instances, Community Care is not responsible for managing the enrollmentprocess. If Community Care manages behavioral health benefits through an agreementwith a managed care organization (MCO), Community Care’s policy is to releasemember identifiable data or information to the MCO, knowing that in the absence of theMCO’s agreement with Community Care, the MCO itself would be responsible formanaging behavioral health benefits and would therefore have access to the memberidentifiable data or information.In any instance where Community Care must release member identifiable data orinformation to an employer, whether self-insured or fully insured, Community Caremust verify that the member has signed an authorization to release such data orinformation to the employer. Community Care will require that the employer agree inwriting to protect all member identifiable data and information from being used in anydecisions affecting the member (HIPAA 164.504(h)(3)(iv)).Community Care Provider Manual | 1-888-251-CCBH | © 2012 All Rights Reserved | Page 190