Interoperability and Patient Access

• Patient Demographics
  • first name
  • last name
  • previous name
  • middle name
  • suffix
  • birth sex
  • date of birth
  • race
  • ethnicity
  • preferred language
• Allergies & Intolerances
  • substances (medications)
  • substances (drug class)
  • reaction
• New Demographics
  • current address
  • previous address
  • phone number
  • phone number type
  • email address
• Health Concerns
• Immunizations
• Procedures
• Medications
• Laboratory Tests & Results
• Assessment & Treatment Plan
• Care Team Members

* Applies to Medicare Advantage, Medicaid and CHIP Managed Care, and federally-funded ACA exchange plans

** Data will be available for dates of service on or after Jan. 1, 2016; data for Payer-to-Payer only covers clinical data.

*** For Medicare Advantage Prescription Drug (MAPD) plans

Having your health information in one place may help you and your providers:

• Understand your health better
• Make better decisions
• Improve your health outcomes
• Reduce healthcare costs
• Carry information to new providers or health plans

Your privacy and the security of your PHI is a top concern of ours. The new rule allows you to use an app from a third-party application developer (a company with no connection to Trillium Community Health Plan). You can use this app to look up your health information.  When choosing an app, it is important to consider how your data can be used and the app’s security and privacy practices.

The CARIN Alliance is working to advance the exchange of health information. We will require third-party application developers to agree to follow certain privacy standards outlined in the CARIN Code of Conduct. The CARIN Code of Conduct is a set of practices that these applications have voluntarily adopted to protect and secure your health information. Visit the My Health Application website to see a list of apps that have agreed to the CARIN Code of Conduct. We will give you information on federal agencies you can contact if you feel your rights to patient privacy have not been protected. Learn more about the CARIN Alliance.

Before sharing your data with a third party application, we will ask you to agree to an Access Your Data statement. This is an added security step to protect your data.

1.  Find an app. Visit the My Health Application website for a list of apps that meet the CARIN Code of Conduct.

By agreeing to the CARIN Code of Conduct, the app developer attests it meets certain standard security practices. These practices include, but are not limited to:

• Protection of a user’s personal data against:
  • loss or unauthorized access
  • use
  • alteration
  • destruction
  • unauthorized annotation
  • disclosure
• Protect personal data through a combination of mechanisms including:
  • secure storage
  • encryption of digital records both in transit and at rest
  • data-use agreements and contractual obligations
  • accountability measures (e.g., access controls, logs and independent audits)
• Comply with applicable breach notification laws
• Provide meaningful remedies to address security breaches or other violations due to a misuse of the user’s personal data
• Adopt internal policies and secure contractual commitments with third parties to prohibit the re-identification of de-identified or anonymized data

2.  Download the app. Smartphone apps are available through the Google Play Store (Android) and the App Store (iOS).  Web apps are also available for computers.

3.  Create your account. Use the app to do so.

• To link your health information, choose your health plan
• On the login screen, enter your member portal username and password
• Read the Access your Health Data statement. If you agree to the terms, click “Allow Access”

4.  Use your information to manage your healthcare.

Q: How do I find the right Third-Party app?
A: Read our Frequently Asked Questions or call us at 1-877-600-5472 (TTY/TDD: 711).

Q: How does Payer-to-Payer data exchange work for both current and former members? 
A: Members may request that Trillium Community Health Plan send health records to other health plans. They can also request that Trillium Community Health Plan receive health records from other health plans.  If a member switches health plans, Trillium Community Health Plan will send their clinical records (included in the USCDI data set) to another health plan. This is in order to build a complete health record. A complete health record will help a member make decisions that improve their quality of care and health outcomes.

Former members of Trillium Community Health Plan should start the request through their new health plan.  Based on this request, Trillium Community Health Plan will send the clinical records to their new health plan.

Current members of Trillium Community Health Plan may start the request by logging into the Trillium Community Health Plan secure member portal.  There they can request and receive the clinical records from their previous health plan.

Q: How does the new Interoperability and Patient Access Rule affect me?
A: To learn more, call Trillium Community Health Plan at 1-877-600-5472 (TTY/TDD: 711).

Q: How many years will my health information go back?
A: You will have access to health information with a date of service of January 1, 2016 or later.

Q: Can I access my health information if I go to a different health plan or provider?
A; Yes. You will be able to access your health information no matter what health plan or provider you go to.

Q; Can I find out if I’m up to date on my immunizations?
A: Yes.  You can use an app to see what shots you’ve had with a date of service January 1, 2016 or later.

Q: Do I have to use an app from Trillium Community Health Plan?
A: No.  The app is not affiliated with Trillium Community Health Plan. Visit the My Health Application website for a list of apps.  This includes apps that promise to meet the CARIN Code of Conduct.  Follow the instructions on the app to connect it with your health record.

Q: Will all apps keep my health information private?
A: Not every app has agreed to meet the CARIN Code of Conduct or any other set of guidelines. We will let you know which apps have agreed to follow our privacy guidelines. You will have a chance to select another app if you selected the app before they shared their privacy practices with us.

We suggest that you request a Notice of Privacy Practices from the app.  Read it carefully before using that app. If the app does not provide you with a Notice of Privacy Practices, we suggest that you choose another app. Visit the My Health Application website for a list of apps that agree to follow the CARIN Code of Conduct.

Q: When can I have access to my health information in the app?
A: You will be able to access your health plan information in the apps starting on July 1, 2021.

Q: Do I have to use an app to get my health information?
A: No. You do not have to use an app to access your health information. You can contact your provider or health plan for information.

Q: What health data will the app collect?
A: It depends on the app you choose. Some apps will collect your health data.  This includes (but is not limited to):

• claims
• medications
• diagnoses
• procedures
• doctor visits

You give the app permission to collect your health information when you sign up for it.  The app’s Notice of Privacy Practices should tell you what information it collects.

Q: Will the app collect non-health data from my device, such as my location?
A: The app's Notice of Privacy Practices should tell you what information it collects.  Apps do have the ability to collect non-health data, such as your location. Some apps give you the option to provide that information. We suggest that you ask your app provider.

Q: Does sharing my data with this app have an impact on my family members?
A: If a family member is linked to your health account, there is a chance that their health information will be shared.

Q: How do I correct mistakes in my health data?
A: You will need to contact your provider or health plan.  The app only makes data available from healthcare sources. The app does not create this data.

Q: What are my rights under the Health Insurance Portability and Accountability Act (HIPAA)?
A: We suggest that you ask the app provider for their Notice of Privacy Practices.

Most apps will not be covered by HIPAA.  They will instead be covered by the Federal Trade Commission (FTC) and the protections provided by the FTC Act. The FTC Act protects against deceptive acts.  For example, if an app shares personal data without permission.  This is even though the privacy policy says it will not do so.

For more information:

• The FTC has information about mobile app privacy and security for consumers on their websites
• For apps subject to HIPAA, the HHS.gov website has information about HIPAA patient rights and who is obligated to follow HIPAA
• The HHS.gov website also has HIPAA FAQs for Individuals

Q: What are my rights when it comes to my data collected on this app?
A: We suggest that you request a Notice of Privacy Practices from the app provider to understand your rights.

Q: What should I do if my data has been shared, stolen, or improperly used?
A: We suggest that you request a Notice of Privacy Practices from the app provider.  This is so that you can understand how they respond to a privacy and security incident. You have the right to file a complaint with enforcement agencies including the Office for Civil Rights (OCR) and the Federal Trade Commission (FTC).

Most apps will not be covered by HIPAA. They will instead be covered by the Federal Trade Commission (FTC) and the protections provided by the FTC Act. The FTC Act protects against deceptive acts.  For example, if an app shares personal data without permission.  This is even though the privacy policy says it will not do so.

For more information:

• To learn more about filing a complaint with OCR under HIPAA, visit the HHS.gov website
• Individuals can file a complaint with OCR using the OCR complaint portal 
  
• Individuals can file a complaint with the FTC using the FTC complaint assistant

Q: How will the app use my data?
A: The purpose of the app is for you to see your health data in one place.  We suggest that you request a Notice of Privacy Practices to understand how the app will use your data.

Q: Can the app share my data with third parties?
A: We suggest that you request a Notice of Privacy Practices from the app provider to understand if the app will share your data with third parties

Q: Does the app delete my data after I stop using it?
A: We suggest that you request a Notice of Privacy Practices from the app provider.  This is so that you can understand what happens to your data after you stop using the app.

Q: How do I stop sharing my data?
A: The best way to stop sharing data is through the app or by contacting the app’s support. If this doesn’t work, call Trillium Community Health Plan member services.

Q: Will this app sell my data for advertising or research?
A: We suggest that you request a Notice of Privacy Practices from the app provider.  This is so you can understand if the app will share your data with third parties for advertising or research.

Q: How does this app collect and respond to user complaints?
A: App providers may respond to complaints in different ways. We suggest that you ask your app provider this question.

Q: Will my data be stored in a de-identified or anonymized form?
A: We suggest that you request a Notice of Privacy Practices from the app provider.  This is so you can understand how the app stores your data.

Q: What security measures does this app use to protect my data? Will they inform me if an incident occurs?
A: We suggest that you request a Notice of Privacy Practices and additional information on security practices from the app provider.  This is so you can understand how they handle a security incident.

Q: How can I limit this app’s use and release of my data?
A: We suggest that you request a Notice of Privacy Practices from the app provider.  This is so you can understand how to limit the use and release of your data.