Notice of Privacy Practices - Commercial

Your Information. Your Rights. Our Responsibilities.

Network Health Plan (NHP) and Network Health Insurance Corporation (NHIC) are committed to protecting the privacy of your personal information. This includes all oral, written and electronic non-public information including but not limited to race/ethnicity, language, gender identity, sexual orientation, reproductive health care, substance use disorder records and other protected health information (hereafter referred to as personal information). This Notice of Privacy Practices will be followed by all employees of our workforce, regardless of geographical location. It describes how your personal and financial information may be used and disclosed and how you can get access to or limit sharing of this information. Please review it carefully.

Our Responsibilities

• We are required by law to maintain the privacy and security of your personal information.
• We must follow all applicable federal or state laws, whichever is more protective of your privacy rights.
• We will let you know promptly if a breach occurs which may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it.
• We will not use or share your information other than as described here, unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.

For more information see HIPAA.gov and the Gramm-Leach-Bliley Act.

Your Rights

When it comes to your personal information, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get a copy of health and claims records

• You can ask to see or get a copy of your health and claims records and other personal information we have about you. Ask us how to do this.
• We will provide you with a copy or summary of your health and claims records within 30 days of your request. We may charge a reasonable, cost-based fee.
• If we need an extension, we will let you know in writing the reason and a date when we will provide the records.
• We may say “no” to your request, but we’ll tell you why in writing within 30 days with additional information on how you can have the decision reviewed.

Ask us to correct health and claims records

• You can ask us to correct your health and claims records if you think they are incorrect or incomplete. Ask us how to do this.
• We may say “no” to your request, but we’ll tell you why in writing within 60 days and include information on how you can appeal this decision.

Request confidential communications

• You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.
• We will consider all reasonable requests, and must say “yes” if you tell us you would be in danger if we do not.

Ask us to limit what personal information we use or share

• You can ask us not to use or share certain personal information. Your request must be made in writing.
• We are not required to agree to your request, and we may say “no” if it would affect your care.

Get a list of those with whom we’ve shared health information

• You can ask for a list showing the times we’ve shared your protected health information for six years prior to the date you ask, who we shared it with and why.
• We will include all the disclosures except for those about treatment, payment and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one list per year for free, but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice

• You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly. You may also print a copy of this page at any time.

Choose someone to act for you

• If you have given someone durable power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
• We will make sure the person has this authority and can act for you before we take any action.

File a complaint if you feel your rights are violated

• You can complain if you feel we have violated your rights by contacting the Privacy Manager, at 800-826-0940 (TTY 800-947-3529). Complaints may also be made in writing to

Network Health
Attn: Compliance
1570 Midway Pl.
Menasha, WI 54952

• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 877-696-6775 or visiting the U.S. Department of Health and Human Services website about what to expect when filing a complaint.
• We will not retaliate against you for filing a complaint.

Your Choices

For certain personal information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do and we will follow your instructions.

In these cases, you have both the right and choice to tell us to:

• Share information with your family, close friends or others involved in payment for your care
• Share information in a disaster relief situation

If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.

Written Authorization

State and other applicable laws may prohibit us from using or disclosing information related to certain medical conditions, including but not limited to, HIV/AIDS, mental health, substance abuse and developmental disabilities without written authorization. Substance abuse records or testimony relaying the content of such record, may not be used or disclosed in a civil, criminal, administrative, or legislative proceeding against you absent written consent from you or a court order. In these circumstances we will follow the applicable law. 

For example, we are prohibited from disclosing lawful reproductive health care information to law enforcement if the reason they are seeking the information is to conduct an investigation into that person obtaining such care.

In the example discussed above, if Network Health receives such a request from law enforcement we are required to obtain an attestation from the law enforcement agency stating they are not using the requested reproductive health care information to investigate the person for obtaining such care.

If you give us written authorization, you may revoke it at any time in writing. The revocation will not affect any uses or disclosures permitted while the authorization was in effect.

Our Uses and Disclosures

How do we typically use or share your personal information?

We typically use or share your health information in the following ways.

Help manage the health care treatment you receive

We can use your personal information and share it with professionals who are treating you.

Run our organization

We can use and disclose your information to run our organization and contact you when necessary.

Pay for your health services

We can use and disclose your personal information as we pay for your health services.

Administer your plan

We can disclose your personal information to a third party claims payor for enrollment and claims processing.

Business Associates

We may disclose your personal information to persons or organizations which perform a service for us that requires the use or sharing of health information. Such persons or organizations are our contracted business associates, and they are held to the same privacy standards as our organization.

Health-Related Products, Benefits and Services

We may contact you to give you information about certain health-related benefits and services which may be of interest to you. We may also contact you to recommend alternative treatments, health care providers or care settings.

How Else Can We Use or Share Your Health Information?

We are allowed or required to share your information in other ways, usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information about this visit the U.S. Department of Health and Human Services website for guidance materials for consumers.

Help with public health and safety issues
We can share health information about you for certain situations such as:

• Preventing or controlling disease
• Helping with product recalls
• Reporting adverse reactions to medications
• Reporting suspected abuse, neglect or domestic violence
• Preventing or reducing a serious threat to anyone’s health or safety

Notification and communication with family and friends

We may share protected health information about you with family members, friends or others you identify as being involved in your health care or payment for your health care. We will disclose only the health information relevant to the person’s involvement. If you are unable or unavailable to agree or object to a disclosure to such a person, we will use our best professional judgment in communicating with your family or friends.

Compliance with the law

We will share information about you if State or Federal laws require it, including with the Department of Health and Human Services if they want to see that we’re complying with Federal privacy law. Personal information disclosed pursuant to state and other applicable laws may be subject to redisclosure and no longer protected by the Privacy rule or other applicable law. 

Your Employer or Organization Sponsoring Your Health (pertains to group health plans only)

We may disclose to your employer whether you are enrolled in or have disenrolled from a health plan that your employer sponsors. We may disclose summary health information to your employer to use to obtain premium bids for the health insurance coverage offered under the group health plan in which you participate or to decide whether to modify, amend or terminate that group health plan.

We may disclose your health information and the health information of others enrolled in your group health plan to your employer to administer your group health plan. Before we may do that, your employer must amend the plan document for your group health plan to establish the limited uses and disclosures it may make of your health information. Please see your group health plan document to see whether your employer may receive this information and for a full explanation of those limitations.

Respond to organ, eye and tissue donation and transplantation requests and work with a medical examiner or funeral director

• We can share health information about you with organ, eye and tissue procurement and transplantation organizations.
• We can share certain health information with a coroner, medical examiner or funeral director when an individual dies.

Address workers’ compensation, law enforcement and other government requests
We can use or share health information about you for the following:

• Workers’ compensation claims
• Law enforcement purposes or with a law enforcement official
• Health oversight agencies for activities authorized by law, such as audits and investigations related to the oversight of government benefit programs (like Medicare)
• Special government functions such as military, national security and presidential protective services

Respond to lawsuits and legal actions

• We can share health information about you in response to a court or administrative order, a subpoena or to law enforcement if we first obtain an attestation confirming the request does not violate state or federal law.

Disaster relief

We may use or disclose your name and location to a public or private entity authorized by law or by its charter to assist in disaster relief efforts.

Changes to the Terms of this Notice

This notice takes effect January 1, 2025, and it will remain in effect until we replace it. We can change the terms of this notice, and the changes will apply to all information we have about you. Any changes to the notice will be effective for all of your records created or maintained in the past, as well as any records we create or maintain in the future. The new notice will be available upon request, on our website, and we will mail a copy to you. If there are no changes to the notice, you will be notified at least every three years that this notice is available to you.

Financial Information Privacy

Network Health Plan and Network Health Insurance Corporation are committed to maintaining the confidentiality of your personal financial information. We collect personal and financial information about you to perform functions such as premium payment transactions and electronic funds transfers.

We do not disclose personal financial information about past, present or future members to any third party, except as required or permitted by law. Access to your personal financial information is restricted only to employees, affiliates and service providers who are involved in administering your health care coverage or providing services to you. We maintain physical, electronic and procedural safeguards that comply with Federal standards to guard your personal financial information.

We may disclose personal and financial information to financial institutions which perform services for us, such as electronic fund transfer for payment of premiums.

We may begin disclosing this information as soon as you submit an application to become a member of Network Health. Once you’re no longer a member, we may continue to share this information as described in this notice.  

In limited circumstances, you can ask us to limit sharing of this information by calling member experience at 800-826-0940 (TTY 800-947-3529), or submitting a written request to:

Other Instructions for Notice

If you have questions about any part of this notice or would like to request a copy, you may call the member experience department at 800-826-0940 (TTY 800-947-3529), Monday, Wednesday, Thursday and Friday, 8 a.m. to 5 p.m. and Tuesday 8 a.m. to 4 p.m.