Employee Manual 2023 - Flipbook - Page 72
Freedom of Information Act, 1976 PA 441, MCL 15.231 to 15.246
o The document or information is a copy of a vital record recorded as provided by law
and is mailed to a person entitled to receive that record.
o The document or information is mailed by or at the request of the individual whose
social security number appears in the document or information or at the request of
the individual’s parent or legal guardian.
o The document or information is mailed in a manner or for a purpose consistent with
the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191;
or with section 537 or 539 of the Insurance Code of 1956, 1956 PA 218, MCL 500.537
and 500.5539.
If you believe that your social security number or PHI has been improperly used or disclosed by an
employee of the City, you are welcome to contact the City’s privacy officer to register a complaint.
How will the City generally use or disclose Social Security Numbers and PHI?
The City is permitted by law to use or disclose PHI for treatment, payment, or health care
operations without the authorization or consent of the employee. The following are a few
examples of how PHI is used or disclosed by the City.
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Treatment:
PHI may be used or disclosed to provide, coordinate and manage health care services,
including worker's compensation, rendered to employees. To the extent the City is required
to assist with health care services, it may disclose PHI to health care providers or other
agents or affiliates of the City.
Payment:
The City will use and disclose PHI to obtain and to provide payment information for the
provision of health care. Examples of these payment activities include: billing, claims
management, collection activities, and administration of stop-loss and excess loss insurance
policies, as well as related data processing; determining eligibility, coverage, medical
necessity and related documentation, coordinating benefits among various payers,
recovering payment from third parties liable for coverage, risk adjustment, utilization
review activities and disclosures to consumer reporting agencies.
Health Care Operation:
PHI may be used or disclosed as part of the City’s business operations related to the
administration of the City’s employee health benefit plans. Such operations may include
quality of service audits of the City and its affiliates, including improvement activities, and
other standard business operations. PHI may also be used or disclosed to evaluate the City’s
plans or the providers servicing the plan; underwriting, premium rating and other activities
relating to the creation, renewal or replacement of benefits contracts; fraud and abuse
detection and compliance programs; business planning and development; or the resolution
of complaints registered by other health plan participants.
Disclosures to Family and Friends:
In an emergency, the City may disclose PHI information to family members, friends, or other
people that may aid in treatment. The information may also be disclosed to a person
responsible for payment of medical services received by an employee. A disclosure of PHI
City of Plymouth Employee manual - Page 72 – March 2023