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OBERLIN COLLEGE PRIVACY POLICIES AND PROCEDURES
Complaints
Those who want more information about privacy rights, who do not understand
their privacy rights, or who are concerned that their privacy rights may
have been violated or who disagree with a decision made about access to
their confidential information, may contact the Privacy Office at Oberlin
College or at CIGNA, or file a written complaint with the Office of Civil
Rights of the U.S. Department of Health and Human Services.
Complaints must be filed within 180 days of the occurrence, must be in writing and must include the complainant's name, address, and phone numbers, date of the alleged violation and the facts as known, a signature and date. Forms to aid in this process may be found on the HR website.
Complaints may be submitted to any of the following:
· Privacy Office, c/o Kim Wiggerly, Oberlin College, Service Bldg,
2nd Fl., 173 W. Lorain Street, Oberlin, OH 44074, 440-775-8430, fax: 440-775-8683,
e-mail: Privacy.Officer@oberlin.edu.
· Privacy Office, Cigna Healthcare, P.O. Box 5400, Scranton, PA
18503, 800-762-9940, Fax: 860-226-9513. A person may also call CIGNA Customer
Service at the toll-free number on the Cigna Healthcare ID card. (CIGNA
is the Third Party Administrator of the Plan.)
· The contact party named for purpose in any privacy notice, if
the Plan is insured.
· Office for Civil Rights, U.S. Department of Health and Human
Services, 233 N. Michigan Avenue, Suite 240, Chicago, Illinois, 60601,
voice phone (312) 886-2359, fax (312) 886-1807, TDD (312) 353-5693. For
all complaints filed by email send to: OCRComplaint@hhs.gov.
Compliance Line - If you do not feel comfortable using any of the
above methods, you may call the Oberlin College Compliance Line at 1-800-399-3593,
where a Compliance Risk Specialist will document your concern anonymously
if you so choose.
Sanctions for Violations of Privacy Policy
The College will address any violation of the Privacy Policy based on
the severity of the infraction and the current College policy regarding
violation of policy.
Mitigation of Inadvertent Disclosures of PHI
The College will mitigate, to the extent possible, any harmful effects
that become known to it of any use or disclosure of an individual's PHI
in violation of HIPAA. An employee of the College who becomes aware of
a disclosure of PHI that is not in compliance with this Privacy Policy
must immediately contact the Privacy Officer so that the appropriate steps
to mitigate the harm to the participant can be taken.
No Intimidating or Retaliatory Acts; No Waiver of HIPAA Privacy
No employee may intimidate, threaten, coerce, discriminate against, or
take any retaliatory action against individuals for exercising their rights,
filing a complaint, participating in an investigation, or opposing any
improper practice under HIPAA.
No individual is or will be required to waive his or her privacy rights
under HIPAA as a condition of treatment, payment, enrollment or eligibility
for participation in the Plan.
Revised 4/13/06
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