VSP GLOBAL® EYES OF HOPE® MOBILE CLINICS PROGRAM NOTICE OF PRIVACY PRACTICES

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.

Purpose & VSP's Responsibilities

The purpose of this notice is to provide you with Vision Service Plan’s (“VSP”) information protection practices, and explain certain rights you have, and VSP’s obligations with respect to your information.
VSP is required to abide by the terms of this notice currently in effect by:

  • Maintaining the privacy and safeguarding the security of your protected health information (“PHI”).
  • Giving this notice to you about our privacy practices, our legal duties, and your rights concerning your PHI.
  • Notifying you, along with all other affected individuals, of any breaches of your unsecured PHI.
  • Following the practices that are described in this notice while in effect.

This notice takes effect January 1, 2018, and will remain in effect until further notice. VSP reserves the right to revise the terms of this notice, and to make the revised terms effective for all PHI that it maintains. If VSP revises this notice, it will be provided to you at your next visit. Alternatively, it shall be made available at any one of our mobile clinic locations and at globaleyesofhope.com.

Uses and Disclosures of Information

VSP uses PHI about you for treatment, to obtain payment for treatment, for administrative purposes, and to evaluate the quality of care and service that you receive. Your PHI is contained in a medical or optical dispensary record that is the physical property of VSP. Your PHI consists of any information, whether in oral or recorded form, that is created or received by VSP and individually identifies you, and that relates to your past, present or future physical, mental health or condition; the provision of health care to you; or the past, present or future payment for the provision of health care to you.

VSP will only use and disclose your PHI without your authorization when necessary for:

  • provision, coordination and management of your vision care treatment;
  • consultation between health care providers relating to a patient/customer;
  • the referral of a patient for health care from one health care provider to another;
  • health care operations; or
  • as required or permitted by law.

Use or Disclosure Requiring Authorization

VSP will request your written authorization if it becomes necessary to disclose any of your PHI for reasons other than as outlined in this notice. Further, VSP will obtain your authorization for any sale of your PHI, or to use or disclose your PHI for marketing.

If you provide written authorization for disclosure of your PHI, you may revoke it at any time in writing, except to the extent that VSP has relied upon the authorization prior to its being revoked.

Use or Disclosure Required or Permitted by Law

VSP may use or disclose your PHI to the extent that the law requires the use or disclosure:

  • For public health activities or as required by the public health authority.
  • To a health oversight agency for activities such as audits, investigations and inspections. Oversight agencies include, but are not limited to, government agencies that oversee the health care system, government benefit programs andother government regulatory programs.
  • In response to an order of a court or administrative tribunal, in response to a subpoena, discovery request or other lawful process.
  • Pursuant to a shared/joint custody and child care or support arrangement authorized by law or court order.
  • For law enforcement purposes, including:
    • legal process or as otherwise required by law;
    • limited information requests for identification and location;
    • use or disclosure related to a victim of a crime;
    • suspicion that death has occurred as a result of criminal conduct;
    • if a crime occurs on VSP’s premises; or
    • in a medical emergency where it is likely that a crime has occurred.

As requested by law enforcement authorities, if the use or disclosure is necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public.

Use and Disclosure Examples

  • Payment: VSP uses PHI for payment processing to verify that services provided were covered under the patient’s vision care plan.
  • Health Care Operations: VSP uses and discloses PHI in order to audit and review claims payment activity to ensure that claims were paid correctly.
  • Appointments, Treatment and Quality Assurance: VSP may use your information to provide appointment and refill reminders or recall notices (such as voicemail messages, postcards or letters) or to provide you with information about treatment alternatives or other health-related benefits, products and services that may be of interest to you. VSP may also contact you to conduct surveys about the quality of the products and services it provides.
  • Personal Representative: VSP may disclose your protected health information to a person who has legal authority to make health care decisions on your behalf.
  • Marketing Products or Services: “Marketing” means to make a communication to you that encourage you to purchase or use a product or service. VSP will not use or disclose your PHI for marketing communications without your prior written authorization. However, VSP may conduct face-to-face communications with you and VSP may offer a promotional gift of nominal value, without such authorization. VSP may also provide you with information from VSP’s affiliate companies, regarding products or services that it offers related to your health care needs, provided that VSP is not paid or otherwise receives compensation for such communications.
  • Family member, friend, or other person: VSP may disclose your PHI to a family member, friend or other person involved in your care, to include payment for your care, if the information is relevant to their involvement and you have agreed in writing to such disclosure and had an opportunity to object to any such disclosure.

YOUR HEALTH INFORMATION RIGHTS

  • Exercising your rights: You may exercise any of your below rights by calling our Member Services Department at 800.877.7195.
  • Review your protected health information: You have a right to inspect and obtain a copy of your PHI.
    • Important: If you feel your PHI is incomplete or incorrect, you have the right to request that it be amended.
  • Restriction: You can request restrictions on the use and disclosure of your PHI. VSP is not required to agree to a requested restriction.
    • Example: If a restriction request prevents VSP from providing service to you or from performing payment related functions, VSP will not be able to agree to the request.
  • Confidential Communication: When necessary, VSP may seek to contact you by calling you at your home or by sending mailings containing your PHI to your home. If you feel that such communications could compromise your safety, you may request in writing an alternate communication method and/or location.
    • Important: VSP may require that a request contain a statement that disclosure of all or part of the information to which the request pertains could endanger the individual, and VSP may, if and to the extent that applicable law allows, request payment for this service.
    • Examples: The patient may decide, for his or her safety, to have correspondence containing his or her PHI sent somewhere other than to his or her home, or to have the information sent via fax rather than mailed.
  • Accounting of Disclosures: If disclosure of your PHI was made for a reason other than treatment, payment or health care operations, you have a right to receive an accounting of the disclosure.
    • Important: If the disclosure was made to you, VSP will not provide an accounting.
  • Copy of Notice You may request a request a paper copy from VSP.
  • Complaints If you believe that your privacy rights have been violated, you may submit a complaint to VSP or to the U.S. Secretary of VSP will not retaliate against you for filing a complaint. You may file a complaint through vsp.com, or by calling our Member Services Department at 800.877.7195.

Contact Information

If you have questions about your privacy rights, believe that we may have violated your privacy rights, or disagree with a decision that we made about access to your PHI, you may contact us at the following address, telephone number, or email:

VSP Global
Attention: Privacy Specialist
3333 Quality Drive MS 163
Rancho Cordova, CA 95760
Phone: 916.685.7432
Email: HIPAA@vsp.com