What is Interoperability and what does it mean for you?
According to the Centers for Medicare and Medicaid Services (CMS), interoperability aims to give people access to their health information when they need it most and in a way they can best use it. CMS is putting this into action with many of the programs it oversees, including Medicare Advantage through a new regulation aimed at improving patient access to and interoperability of health plan information.
As a SCAN member, this means you will have the option to access your health information in a new way. This is part of a decades-long initiative to better connect and share important information that can also help researchers and public health agencies to better understand and meet the nation’s health challenges.
Put simply, this regulation requires that health plans enable patients through independent third-party applications (apps) on computers and mobile devices, and with your authorization, to access your health information maintained by SCAN.
Interested in learning more? See the frequently asked questions below.
Disclaimer: SCAN does not necessarily maintain your entire medical record. Additional information should be sought from your healthcare provider(s).
Understanding Interoperability
How does this new regulation change how I get my health information?
Interoperability allows you to access your electronic health information through a third-party application (app) of your choice, which you can then view on a personal computer or mobile device.
What is the benefit of this regulation?
The regulation puts patients at the center of their care and allows providers a seamless ability to access and use health information from different sources.
Public health agencies and researchers will use the information to learn, develop, and deliver better care.
How can I access my health information through a third-party application?
First, you must have a SCAN online member account. If you don’t have one yet, register here.
Then you will need to download a third-party app. See the section “Choosing a Third-Party App” to find the list of third-party apps that have already completed a registration process with SCAN and have met our security measures. The application will get your health information electronically from SCAN and make it available for you to view in the third-party app.
Who do I call at SCAN if I have a question about third-party application access?
For questions about how to get and set-up a third-party app, call SCAN Healthtech: 1-833-437-0555.
For general questions, contact SCAN Member Services by phone or by secure message in your SCAN online member account. (Click here to log in to your account; click here to sign up for a SCAN online member account – you will need one if you decide to take part in interoperability.)
Choosing a Third-Party Application
What third-party apps have been registered with SCAN Health Plan?
Find the most up-to-date list of registered third-party apps here:
- Mpowered Health
- OneRecord
- MoveMyHealthData
- CommonHealth
- Crescendo Health
- Omega
- b.well Connected Health
- LifeWallet
- Flexpa
- CLICQ
Disclaimer: SCAN is not affiliated with and does not control or endorse third-party applications (apps). Use of third-party applications is at your own risk.
Can I use a third-party app that has not been registered with SCAN Health Plan?
You can download any third-party app, but it will not be able to access your health data until it has completed a registration process with SCAN. If the app doesn’t meet our security standards, we won’t share your health information.
How do I give the third-party app the access to my health information?
Once you’ve chosen and downloaded a third-party app, you will be directed to sign into your SCAN online member account using your SCAN username and password. Once you have successfully logged in, a screen will appear asking you to give the third-party app access to your health data.
Is there a cost associated with downloading and using a third-party app?
There could be. Before you download the third-party app, it should tell you the cost(s), if any.
Is there any risk to the security and privacy of my health information if I use a third-party app?
Once your health information has been transmitted to the third-party app it is no longer protected by the Health Insurance Portability and Accountability Act of 1996 (HIPAA). SCAN is not affiliated with and does not control or endorse any third-party applications, nor does SCAN review these applications’ privacy and security practices. Please review our Privacy Policy for further information.
Third-party apps are subject to the Federal Trade Commission (FTC) Act. If you think a third-party app has used your health information in ways you did not authorize, you can file a complaint with the FTC.
Using a Third Party Application
Why am I asked to log into my online SCAN member account every 90 days?
We ask you to verify every 90 days that you are still using the app, in order to reduce the risk of sharing your health information with a third-party app you no longer use.
Can my personal representative share my health data with a third-party app?
Personal representatives are not allowed to login to your online member account. Your Power of Attorney or Legal status of caregiver is not captured nor verified by SCAN.
What do I do if I have two insurance plans and would like to share my health data from both health insurance companies to a third-party app?
If you have more than one active health insurance plan (e.g. Primary and Secondary Insurance), you would have to give permission to share your health data to both health plans.
For SCAN, once you’ve chosen and downloaded a third-party app, you will be directed to sign into your online member account and acknowledge consent to provide access to your health data.
For your other health insurance company, you would have to follow their consent process to share your health data with a third-party app.
What if I want to stop using a third-party app? What is the process? Will my information automatically be deleted?
You can delete the app from your device(s), but you will need to review the third-party app’s privacy policy and practices to understand how your information will be treated.
SCAN automatically stops sharing your information if you haven’t used the app in 90 days.
Protecting Your Health Information
What should I consider before giving a third-party app access to my health information?
It’s important to take an active role in protecting your health information. You should look for an easy-to-read privacy policy that clearly explains how the third-party app will use your data. If a third-party app does not have a privacy policy, we recommend you do not use it.
You should be able to easily find answers to these types of questions in the privacy policy:
- What health data do they collect?
- Will they collect non-health related data from my device, such as my location?
- Will my data be stored in a de-identified or anonymized form?
- How will they use my health data?
- Will they disclose my data to other third-parties?
- Will they sell my data for any reason, such as advertising or research?
- Will they share my data for any reason? If so, with whom? For what purpose?
- How can I limit their use and disclosure of my data?
- What security measures do they use to protect my data?
- What impact could sharing my data have on others, such as my family members?
- How can I access my data and correct inaccuracies in data they retrieve?
- Do they have a process for collecting and responding to user complaints?
- If I no longer want to use their app or let them have access to my health information, how do I terminate access to my data?
- What is their policy for deleting my data once I terminate access? Do I have to do more than just delete the app from my device?
- How do they inform users of changes or updates to their privacy policies?
If the third-party app’s privacy policy does not clearly answer these questions, you should reconsider downloading and using the app. Instead, choose third-party apps with strong privacy and security standards to protect your health information.
How will my health information be used by the third-party app?
This can vary depending on the application. Please review the third-party app’s privacy policy and any applicable Terms of Use to find out how your health information will be used.
Can I limit and/or exclude what type of my health information is shared with a third-party app?
No, not under current regulations. Remember, you do not have to agree to share your health information with any third-party apps. It will not happen until you download an app and then take another step that gives SCAN permission to share your information.
How many years’ worth of my health information will be shared with a third-party app?
Any data you have stored with SCAN after Jan. 1 2016 will be made available to the third-party app, upon your consent. The only exception would be if you have discontinued enrollment with SCAN and reenrolled after a certain period of time; if this is the case, only the data from the previous 5 years stored with SCAN will be made available.
Definitions & Details
What is HIPAA?
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) is a federal law that required the creation of national standards to protect sensitive patient health information from being disclosed without the patient’s consent or knowledge.
Who is considered a HIPAA (Health Insurance Portability and Accountability Act of 1996) covered entity?
Here are some examples of HIPAA covered entities (this list is not exhaustive):
A Health Care Provider – including:
- Doctors
- Clinics
- Psychologists
- Dentists
- Chiropractors
- Nursing Homes
- Pharmacies
A Health Plan – including:
- Health insurance companies
- HMOs
- Company health plans
- Government programs that pay for health care, such as Medicare, Medicaid, and the military and veterans’ health care programs
If you would like to find out more about HIPAA and what it covers, please click here.
Are third-party apps covered by HIPAA (Health Insurance Portability and Accountability Act of 1996)?
Most third-party apps will not be covered by HIPAA and will instead fall under the jurisdiction of the Federal Trade Commission (FTC) and the protections provided by the FTC Act. The FTC Act, among other things, protects against deceptive acts. For example, if the app says it will not share personal information without permission and then does so, that would fall under the FTC.
To read more about the FTC and mobile app privacy and security click here.
Corrections & Complaints
What if I see mistakes in the health information being shown in the third-party app?
First, check with the third-party app to see if there was an error on their end. If it is not their mistake, contact SCAN Member Services:
By Secure Message: Send a secure email through your SCAN online member account – create one here or log in to your account here.
By Phone: 1-800-559-3500 (TTY:711)
What if I want to change information from my personal health record that SCAN creates or maintains?
If you’d like to make changes to your health information, please contact Member Services:
By Secure Message: Send a secure email through your SCAN online member account – create one here or log in to your account here.
By Phone: 1-800-559-3500 (TTY:711)
Member Services can either email or mail you the “Request to Amend PHI (Protected Health Information)” form to complete. Any requests must be completed in writing and submitted to SCAN’s Privacy Office. Once SCAN has received your written request, it will be acted upon within 30 days. You will receive a written response on the outcome.
What do I do if I believe my data has been used inappropriately by a third-party app?
If you believe a third-party app has violated your privacy rights, you can file a complaint with the FTC at https://reportfraud.ftc.gov/#/.
What do I do if I think a HIPAA-covered entity has violated my privacy?
HIPAA falls under the Office for Civil Rights (OCR). To learn more about filing a complaint with OCR, visit: https://www.hhs.gov/hipaa/filing-a-complaint/index.html
Individuals can also file a complaint with OCR using the OCR complaint portal: https://ocrportal.hhs.gov/ocr/smartscreen/main.jsf
When would I make a complaint to SCAN?
You can make a complaint to SCAN if you believe we have violated your privacy rights, or you disagree with a decision SCAN made about access to your health information. To make a complaint, send a letter describing the situation to:
SCAN Health Plan Attention: Privacy Officer
3800 Kilroy Airport Way, P.O. Box 22616
Long Beach, CA 90801-5616
Or email PrivacyOffice@scanhealthplan.com, or fax to 1-562-308-3689.
If you need help filing a complaint, call the SCAN Health Plan Privacy Office at 1-562-997-3134 or 1-855-895-7226.
