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Billing Manual for Community Care Network Providers

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III.C.1c Transferring Confidential In<strong>for</strong>mationThe transfer of confidential in<strong>for</strong>mation <strong>for</strong> legitimate business purposes between<strong>Community</strong> <strong>Care</strong>’s agents, contractors (including providers), employees, staff, andvolunteers in their official capacities as representatives of <strong>Community</strong> <strong>Care</strong> isconsidered an internal transfer, even though they may be in different physical locations.The transfer of confidential in<strong>for</strong>mation other than to <strong>Community</strong> <strong>Care</strong>’s agents,contractors, employees, staff, and volunteers in their official capacities asrepresentatives of <strong>Community</strong> <strong>Care</strong> is considered an external transfer and must bemade in accordance with <strong>Community</strong> <strong>Care</strong>’s Authorization to Disclose In<strong>for</strong>mation (SeeSection III.C.6). The internal transfer of all confidential data and in<strong>for</strong>mation must be conducted in amanner that limits potential access by individuals who do not have a right to accessthe data and in<strong>for</strong>mation. When not hand-carried and personally delivered to therecipient, physical media containing confidential data and in<strong>for</strong>mation must beplaced in a sealed envelope marked “Confidential.” Confidential data and in<strong>for</strong>mation sent by facsimile must bear a prominentconfidentiality notice similar to the following: “This facsimile transmission containsconfidential and privileged in<strong>for</strong>mation <strong>for</strong> use only by the intended recipient. Do notread, copy, or disseminate this material unless you are the intended recipient. If youbelieve you have received this message in error, please notify the sender byfacsimile or telephone and destroy this document.” Confidential data and in<strong>for</strong>mation sent by email must be flagged as confidential andbear a confidentiality notice similar to the following within the message: “This emailcontains confidential and privileged in<strong>for</strong>mation <strong>for</strong> use only by the intendedrecipient. Do not read, copy, or disseminate this material unless you are theintended recipient. If you believe you have received this email in error, please notifythe sender by return email, securely delete this file and any electronic or magneticcopies and destroy any paper copies.”III.C.1d Destroying Confidential In<strong>for</strong>mationConfidential data and in<strong>for</strong>mation no longer required <strong>for</strong> legitimate business purposesmust be destroyed in a secure manner. Paper records must be thoroughly shredded.Magnetic files must be deleted in a manner that does not permit the files to beundeleted, <strong>for</strong> example, by re<strong>for</strong>matting a floppy disk using the “secure” <strong>for</strong>mat option.Either optical storage media must have the files securely deleted or, if this is notpossible, the storage media must be destroyed.III.C.1e Committee Oversight of Confidentiality<strong>Community</strong> <strong>Care</strong>’s privacy officer and the Compliance Department are responsible <strong>for</strong>approving and periodically reviewing all policies and procedures related toconfidentiality and <strong>for</strong> identifying, developing and implementing mechanisms to oversee<strong>Community</strong> <strong>Care</strong> Provider <strong>Manual</strong> | 1-888-251-CCBH | © 2012 All Rights Reserved | Page 69

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