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.
The Health Insurance Portability and Accountability Act of 1996 and the Health Information Technology for Economic and Clinical Health Act and related regulations (collectively "HIPAA") impose numerous requirements on employer group health plans concerning the use and disclosure of individual health information. This information, known as protected health information (referred to in this notice as "health information"), includes virtually all individually identifiable health information held by a group health plan, whether received in writing, in an electronic medium, or as an oral communication.
This notice describes the privacy practices that the group health plans under The Vanguard Group, Inc. Benefit Plan ("the Plan") will follow in order to comply with the requirements of HIPAA with respect to the following benefits:
- Prescription drug
- Health care flexible spending account
- Crew Assistance Program
- Wellness Program
This notice does not apply to health information collected or maintained by Vanguard on behalf of the non-health employee benefits that it sponsors, including disability benefits, life insurance, accident death and dismemberment insurance, and worker's compensation insurance.
The group health plans may share health information with each other to carry out treatment, payment, or health care operations. The medical, prescription, and dental benefits are self-insured plans. It is important to note that Vanguard does not routinely have access to your individual health information. We use third party administrators, such as Aetna, to perform the daily administrative functions of our plans. It is Vanguard's policy to train the limited number of crew members who have access to Plan personal health information in the manner necessary and appropriate to permit them to carry out plan functions in compliance with HIPAA.