THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
Effective Date
This Notice of Privacy Practices (“Notice”) took effect on August 21, 2024. It will remain in effect until Welltel replaces it. Welltel Virtual Care must abide by the terms of this Notice while it is in effect.
Welltel Virtual Care’s Commitment To Your Privacy
Welltel Virtual Care and its wholly owned subsidiaries including but not limited to make up an organized health care arrangement. Welltel is a clinically integrated care setting in which our members receive health care (“Services”) from more than one health care provider. In addition, we are an organized health care system that jointly participates in numerous activities including quality assessment and improvement activities.Welltel respects and is committed to protecting the privacy of your medical information. In performing its services, Welltel will receive, create, and disclose your protected health information (“PHI”). Welltel is required by law to maintain the privacy and security of your PHI and to provide you with notice of our legal duties and privacy practices with respect to your PHI. For information about our collection, use, and disclosure of personal information other than PHI, please see our privacy policy at www.welltel.com/privacy-policy and the privacy policies posted on the websites of the affiliates listed above.
Your Information. Your Rights. Our Responsibilities.
In this Notice, we describe:
Information We Collect About You
When We Use and Share Your Information
When We Must Share Your Information
When We Need Your Authorization to Use or Share Your Information
Your Rights Regarding Your Information
How We Keep Your Information Safe
Changes to the Terms of This Notice
Information We Collect About You
To provide you with the Welltel Services, we collect PHI about you from a few sources including directly from you. PHI is information about you that may be used to identify you (such as your name), and that relates to:
Your past, present or future physical or mental health or condition,
The provision of healthcare to you, or
Your past, present, or future payment for the provision of healthcare.
PHI Collected From You
Of course, as you use the Welltel Services you will need to provide Welltel with information about yourself and your medical history, past treatment, and potential future treatment options. As you communicate with us, your telephone calls, emails, and other communications between you and Welltel and/or Welltel’s service providers, may be recorded and logged. As such, we will collect and maintain all information discussed during such communications including your identity, the date and time of the communication, and the contents of the communications.
PHI Collected from Third Parties
In connection with the Welltel Services, we may collect information about you from third parties such as: – Past or current health care providers – Health insurance and pharmacy benefit management companies – Your employer or other organization that has contracted with Welltel to give you access to the Services may provide us with your name and demographic information, so we know you are eligible for the Services
PHI Collected Automatically
When you register and log in to our secure websites and mobile apps, Welltel automatically collects information about you. Welltel must be able to link your activity back to your identity so that changes in our systems can be made and we can track the Services you used. As such, we automatically collect the following types of information about you when you use our secure websites:
IP address
Device information
General geographic information
Dates and times you accessed and used the secure websites/mobile apps, features you used, and how long you use the secure websites/mobile apps
When We Use And Share Your Information
To provide you with the Services, we will need to use and disclose your PHI for the following reasons:
Treatment Activities
We will use your PHI within Welltel to treat you and provide you with medical services. We may also disclose your PHI to other physicians or healthcare providers so that they can treat you and provide you with medical services. For example, electronic prescriptions written by Welltel may be available to your treating physician to ensure your quality of care. When you use our Services, to enhance the continuity and quality of care we provide to you, your PHI may be available to providers within Welltel for them to provide you with treatment and medical services. For example, your past consults will be available to the provider when you seek a new consult.
Payment Activities
We can use and share your PHI to get paid and for other payment activities. For example, we will send a claim to your health insurer to get paid. We may share PHI with other entities covered by HIPAA, such as health plans, for their payment activities.
Healthcare Operations Purposes
Welltel may use and disclose your PHI to run our business. For example, to improve medical services, provide customer service, conduct quality review, contact you about the Services available to you and health benefits, monitor the qualifications of providers, and other healthcare operations activities. We may share PHI with other entities covered by HIPAA, such as health plans, for their business operations only if they also have or had a relationship with you.We may also use PHI to:
Participate in health information exchanges (HIEs) so that we can share, request, and receive electronic health information from other health care organizations for treatment, payment, and healthcare operations purposes as described above.
Engage third parties to assist Welltel with our payment and healthcare operations. If any such third party needs access to PHI to perform its services on behalf of Welltel, Welltel will require that third party to enter a written agreement that protects the PHI. We provide only the minimal PHI to accomplish the intended purpose of the use and sharing of the PHI.
Communicate with family and friends who are involved in your care and payment for care.
Create deidentified and aggregate information.
When We Must Share Your Information
There are limited times when Welltel may be permitted or required by law to use or disclose your PHI without your authorization. These include the following:
For public health activities such as reporting certain diseases
To protect victims of abuse or neglect, such as child abuse and elder neglect
For judicial and administrative proceedings such as responding to subpoenas
For workers compensation claims
To prevent or lessen a serious and imminent threat of harm to a person or the public
When required by law or for law enforcement purposes
For state and federal health oversight activities such as physician licensing and disciplinary action
To coroners, medical examiners, and funeral directors in limited circumstances
For organ donation and transplantation
For research approved by an institutional review board
For specialized government functions such as national security
When We Need Your Authorization To Use Or Share Your Information
Welltel will not share your PHI for other purposes not described in this Notice unless you give us your written permission. For instance, your written authorization is needed prior to us using and disclosing your PHI:
For Marketing purposes
For a sale of your PHI
For fundraising purposes
To your employer
If Welltel wants to use or disclose your PHI for the purposes listed above or for any other purpose not described in this Notice, we will seek your authorization using the HIPAA Authorization to Disclose Protected Health Information Form here. You have the right to revoke any authorization that you previously provided.
Your Rights Regarding Your PHI
You have the following rights regarding your PHI maintained by Welltel. Additionally, your medical power of attorney or legal guardian can exercise these rights on your behalf and make choices about your health information.Right to Access PHIMost of your PHI that Welltel maintains is available to you directly on the Member Portal. Simply log in to obtain your medical and consult history. To request access to information that is not available to you online, you must submit your request in writing to Welltel using our Webform found here. Welltel may impose a fee for the costs related to copying and mailing. Welltel may deny your request to access your PHI in certain limited circumstances. If that occurs, we will inform you of the reason for the denial.Right to Request Amendment of PHIYou have a right to request that Welltel amend your PHI if you believe it is incorrect. Some changes to your PHI you can make yourself on the Member Portal. To request an amendment of your PHI that you cannot make yourself online, you must submit your request in writing to Welltel using our Webform found here. If Welltel denies your request, you will be permitted to submit a statement of disagreement for inclusion in your records.Right to Request Restrictions on Uses and Disclosures of PHIYou have the right to request that Welltel not use or disclose your PHI for treatment, payment, or healthcare operations purposes. To request a restriction, you must submit your request in writing to Welltel using our Webform found here. Welltel is not required to agree to your request unless you are requesting that we not disclose your PHI to your insurance company or health plan. In such cases, you will be required to pay for services out of pocket.Right to Request Confidential CommunicationYou may request that Welltel communicate with you through alternate means or at an alternate location. To request confidential communications, you must submit your request in writing to Welltel using our Webform found here. Welltel is not required to agree to your request however we will use best efforts to agree to reasonable requests.Right to Request an Accounting of DisclosuresYou have a right to receive an accounting of disclosures Welltel has made of your PHI. To request for an accounting of disclosures, you must submit your request in writing to Welltel using our Webform found here. Your right to an accounting of disclosures does not include disclosures made for treatment, payment or healthcare operations, disclosures made pursuant to an authorization, and certain other disclosures. Your first accounting will be free of charge.You also have the right to: 1) Obtain a paper copy of this Notice from Welltel at any time upon request; 2) File a complaint with Welltel and/or the Secretary of Health and Human Services (at www.hhs.gov/ocr/privacy/hipaa/complaints/) if you believe that your privacy rights have been violated; and 3) Obtain more information about Welltel’s privacy practices by contacting the Privacy Officer in the following ways:By email[email protected]By phone(718) 540-7440
How We Keep Your PHI Safe
The security of your PHI is very important to us and all the PHI you provide to Welltel is protected by strict security safeguards. We use administrative, technical, and physical safeguards to keep your PHI from unauthorized access, and other threats and hazards to its security and integrity. We base our security program on complying with state and federal law, including the HIPAA Security Regulations, as well as industry best practices. We regularly validate the controls we have in place through annual assessment and audits, including SOC II, Type Two and HITRUST certification. More specifically, we protect the confidentiality of your PHI in many ways including the following:
Our databases are encrypted at both the volume layer (physical) as well as within the database columns themselves.
Access to our databases is tightly controlled and is only allowed to a small subset of technical administrators.
On a quarterly basis, access reviews are performed to certify staff roles are still appropriately assigned.
Our employees are trained on an annual basis on how to maintain the privacy and security of our members’ information.
If your unsecured PHI is disclosed to an unauthorized person, despite our security safeguards, we will notify you promptly if such disclosure may have compromised the privacy or security of the PHI.
Changes To This Notice
Welltel reserves the right to change the terms of this Notice at any time, as long as the changes are in compliance with applicable laws. If Welltel changes the terms of this Notice, the new terms will apply to all PHI that it maintains. If Welltel changes this Notice, it will post the new Notice on its Web site and will make the new Notice available upon request.