Office of Origin: Human Resources
Responsibility: Executive Director, Human Resources
Date Adopted: 3-23-04
Dates Reviewed: 5-1-17, 7-1-18, 2-24-21(C)
Last Date Board Approved: 5-01-17

In compliance with the Health Insurance Portability & Accountability Act of 1996 (HIPAA), Lake Michigan College (the College) will protect the privacy and confidentiality of protected health information (PHI) whenever it is used by College representatives and employees in the course of their job duties. The protected use of PHI is the responsibility of all individuals with job duties that requires access to PHI. College representatives and employees will not disclose PHI for employment-related actions, except as provided by administrative procedures approved by the Executive Director, Human Resources, who is the College HIPAA Compliance Officer (HCO.)

PHI refers to individually identifiable health information received by the College, its group health plans, or a healthcare provider or health plan that relates to the past or present health of an individual or to payment of healthcare claims. PHI includes medical conditions, health status, claims experience, medical histories, physical examinations, genetic information, and evidence of disability.

At least annually, the College will perform benefits enrollment and changes in enrollment and payroll deductions. Employees may be provided assistance with claim problem resolution and explanation of benefits issues, as well as assistance with coordination of benefits with other providers; these activities may require the use or transmission of PHI.

Disclosures that do not qualify as PHI-protected disclosures include disclosures:

1. To the individual to whom the PHI belongs
2. To providers for treatment or payment
3. To parties authorized by the individual PHI holder
4. To government agencies for reporting or enforcement purposes
5. To workers’ compensation providers and those authorized by the workers’ compensation providers
6. About whether an individual is covered by a plan for claims processing purposes
7. For claims processing purposes involving workers’ compensation or short- or long-term disability
8. Of medical information received to verify Americans with Disabilities Act or Family & Medical Leave Act status.

Personnel records and disclosures of PHI will be maintained in accordance with the Record Retention policy.

Questions or concerns regarding PHI should be directed to the HCO.

References:
Acceptable Use of Technology policy
Health Insurance Portability & Accountability Act of 1996 (HIPAA)
Institutional Data Management policy
Record Retention policy