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.

Effective Date: FEBRUARY 1, 2026

Vision Plan of America (“VPA”) is committed to protecting the privacy and confidentiality of your medical, vision, and other personal health information.  This Notice of Privacy Practices (“NOPP”) describes how Vision Plan of America may use and disclose your Protected Health Information (“PHI”), your rights with respect to your PHI, and our legal duties regarding your PHI.

For purposes of this Notice, “PHI” means individually identifiable health information that VPA creates, receives, maintains, or transmits in connection with your coverage, benefits, payment, health care operations, or other plan activities.  PHI may include information about your eligibility, enrollment, claims, authorization requests, grievances, appeals, benefits, payment, and vision care.  Your optometrist or other treating provider generally maintains your clinical vision records.  VPA may maintain or receive portions of those records when needed for payment, authorization, quality review, grievance and appeal review, regulatory oversight, or other activities permitted or required by law.

VPA does not sell your PHI.  We will not use or disclose your PHI except as described in this Notice, as permitted or required by law, or as authorized by you in writing.

Our Legal Duties

VPA is required by law to:

  • Maintain the privacy and security of your PHI;
  • Provide you with this Notice of our legal duties and privacy practices;
  • Follow the terms of the Notice currently in effect;
  • Notify you following a breach of unsecured PHI, as required by law; and
  • Comply with applicable federal and California privacy laws, including HIPAA, the Confidentiality of Medical Information Act, and other laws applicable to California health care service plans.

We may change the terms of this Notice at any time.  Any revised Notice will apply to all PHI that we maintain, including PHI created or received before the revised Notice is issued.  If we make a material change to this Notice, we will make the revised Notice available as required by law, including by posting it on our website if we maintain a website for customer service or benefit information.  You may request a paper copy of the current Notice at any time.

How Vision Plan of America May Use and Disclose Your PHI Without Your Written Authorization

VPA may use and disclose your PHI without your written authorization for the following purposes, subject to applicable legal limitations.

Treatment

Although VPA is a health plan and generally does not provide treatment directly, we may disclose PHI to health care providers involved in your care when permitted by law.  For example, we may disclose eligibility, coverage, authorization, or benefit information to your optometrist or another provider to assist with your vision care.

Payment

We may use and disclose PHI for payment and coverage activities.  These activities may include determining eligibility and benefits, collecting premiums, processing claims, coordinating benefits, obtaining, or providing authorization for covered services, reviewing medical necessity or coverage, issuing explanations of benefits, and conducting related billing, collection, and data processing activities.

For example, VPA may use PHI to determine whether a requested vision service is covered, whether a copayment applies, or whether an optometrist has obtained any required authorization for services.

Health Care Operations

We may use and disclose PHI for health care operations, which are activities necessary to operate VPA and administer your benefits.  These activities may include quality assessment and improvement, credentialing and reviewing the qualifications of participating providers, auditing provider offices, reviewing provider performance, conducting compliance and fraud, waste, and abuse activities, responding to member inquiries, handling grievances and appeals, conducting legal and regulatory activities, and managing our business.

For example, VPA may review records maintained by a participating optometrist to determine whether copayments are being charged correctly, whether covered services are being provided appropriately, or whether the provider is complying with applicable contractual and legal requirements.

Business Associates and Delegated Entities

We may disclose PHI to persons or entities that perform services on our behalf, such as claims administrators, data processing vendors, utilization management vendors, auditors, consultants, attorneys, accountants, compliance vendors, or other contractors.  We require these persons or entities to protect PHI and use or disclose it only as permitted by law and by their agreements with us.

Communications With You

We may use your PHI to contact you about your benefits, claims, coverage, authorizations, grievances, appeals, or other plan-related matters.  We may also contact you about treatment alternatives, health-related benefits, services, or programs that may be available to you.

Plan Sponsors and Employers

If you are enrolled through an employer or other group health plan sponsor, VPA will not disclose your PHI to your employer or plan sponsor except as permitted by law.  For example, we may disclose enrollment or disenrollment information, summary health information, information you authorize us to disclose, or other information permitted by HIPAA, California law, or applicable plan documents.

We may also disclose information in limited employment-related circumstances when health care services were provided at the specific prior written request and expense of the employer and the disclosure is permitted by law, such as information relevant to a grievance, arbitration, lawsuit, or information describing work-related functional limitations, without disclosing the medical cause unless authorized or required by law.

Required by Law

We may use or disclose PHI when required to do so by federal, state, or local law, provided the use or disclosure complies with applicable legal requirements.

Public Health and Safety

We may disclose PHI for public health activities, such as preventing or controlling disease, injury, or disability; reporting adverse events; or other public health activities authorized or required by law.

Abuse, Neglect, or Domestic Violence

We may disclose PHI to appropriate authorities if we reasonably believe you may be a victim of abuse, neglect, or domestic violence, or as otherwise permitted or required by law.

Health Oversight Activities

We may disclose PHI to health oversight agencies for activities authorized by law, such as audits, investigations, inspections, licensing, disciplinary actions, civil or administrative proceedings, or other oversight activities.  For example, we may disclose PHI to the California Department of Managed Health Care or other regulators when required or permitted by law.

Judicial and Administrative Proceedings

We may disclose PHI in response to a court order, administrative order, subpoena, discovery request, or other lawful process, subject to applicable legal requirements and limitations.

Law Enforcement

We may disclose PHI for law enforcement purposes when permitted or required by law, such as in response to a court order, warrant, subpoena, or other lawful request.

Coroners, Medical Examiners, and Funeral Directors

We may disclose PHI to coroners, medical examiners, or funeral directors as permitted or required by law.

Serious Threat to Health or Safety

We may use or disclose PHI when necessary to prevent or lessen a serious and imminent threat to the health or safety of a person or the public, consistent with applicable law and ethical standards.

Workers’ Compensation

We may disclose PHI as authorized by and to the extent necessary to comply with workers’ compensation or similar laws.

Parents, Guardians, and Personal Representatives

We may disclose PHI to a parent, guardian, conservator, or other personal representative as permitted or required by law.  In some circumstances, minors and other protected individuals may have the right to control access to certain information, including information related to sensitive services.

Research, De-Identification, and Limited Data Uses

We may use or disclose PHI for research or for de-identification, limited data set, or similar purposes when permitted by law and subject to applicable safeguards.

Substance Use Disorder Records, if Applicable

To the extent VPA creates, receives, or maintains substance use disorder treatment records protected by 42 CFR Part 2, those records receive additional federal confidentiality protections.  Such records generally may not be used or disclosed in a civil, criminal, administrative, or legislative proceeding against you unless permitted by your written consent or by a court order that complies with applicable law.  Where required, disclosures of Part 2-protected records made with your consent must include the required Part 2 notice or an explanation of the scope of your consent.  VPA will comply with applicable Part 2 requirements if such records are received or maintained by the Plan.

Uses and Disclosures That Require Your Written Authorization

VPA must obtain your written authorization for uses and disclosures of PHI that are not otherwise permitted or required by law or described in this Notice.

Your written authorization is generally required for:

  • Uses and disclosures of PHI for marketing purposes, except as permitted by law;
  • Any sale of PHI, except as permitted by law;
  • Uses and disclosures of psychotherapy notes, to the extent Vision Plan of America maintains such notes and an exception does not apply;
  • Uses and disclosures of substance use disorder counseling notes, to the extent VPA maintains such notes and a separate consent is required; and
  • Other uses and disclosures not described in this Notice or otherwise permitted or required by law.

You may revoke an authorization at any time by submitting a written revocation to VPA, except to the extent we have already relied on the authorization before receiving your revocation or as otherwise permitted by law.

Your Rights Regarding Your PHI

You have the following rights regarding PHI that VPA maintains about you.  Some rights may be subject to legal limitations.

Right to Inspect and Obtain a Copy

You have the right to inspect and obtain a copy of PHI about you that VPA maintains in a designated record set, such as enrollment, payment, claims, case management, or other records used to make decisions about you.  If the information is maintained electronically and you request an electronic copy, we will provide access in the electronic form and format requested if readily producible, or in another agreed-upon electronic format.

VPA may not maintain all clinical records about your care.  Your optometrist or other treating provider may maintain separate treatment records, and you may need to request those records directly from that provider.

Right to Request an Amendment

You have the right to request that we amend PHI about you if you believe it is incorrect or incomplete.  We may deny your request in certain circumstances, such as if we did not create the information or if we determine the information is accurate and complete.  If we deny your request, you may submit a written statement of disagreement as permitted by law.

Right to an Accounting of Disclosures

You have the right to request an accounting of certain disclosures of your PHI.  The accounting will not include all disclosures, such as disclosures made for treatment, payment, or health care operations, disclosures made to you, disclosures made pursuant to your authorization, or other disclosures excluded by law.

Right to Request Restrictions

You have the right to request restrictions on certain uses and disclosures of your PHI.  VPA is not required to agree to all requested restrictions, except where required by law.  If we agree to a restriction, we will comply with it unless the information is needed for emergency treatment or another legal exception applies.

Right to Confidential Communications

You have the right to request that VPA communicate with you confidentially, including by using an alternative mailing address, email address, telephone number, or other communication method, as permitted by law.  VPA will accommodate reasonable requests as required by HIPAA and California law.

Under California law, a health care service plan must permit subscribers and enrollees to request confidential communications and must accommodate requests in the requested form and format if readily producible, or at alternative locations.  A confidential communication request applies to communications that disclose medical information or provider name and address related to receipt of medical services by the individual requesting the confidential communication.  A confidential communication request remains valid until you revoke it or submit a new request.  VPA will implement confidential communication requests within the timeframes required by California law.  Protected individuals may exercise their exclusive right to the privacy of their protected healthcare information by rights granted under Civil Code Section 56.107.

Requests for alternate confidential communication methods may be made by:

  • Calling the Plan at (213) 384-2600 or toll free at (800) 400-4872 Dial 711 for hearing impaired assistance
  • Emailing the Plan at info@visionplanofamerica.com
  • Writing to the Plan at 3250 Wilshire Blvd #1610 Los Angeles, CA 90010

Requests received electronically or telephonically shall be implemented within seven (7) calendar days.  Confidential communication requests received by first class mail shall be implemented within fourteen (14) days of receipt.  In addition, the Plan shall acknowledge receipt of confidential communications requests and advise members and their dependent enrollees of the status of implementation of the requests if the member or dependent enrollee contacts the Plan.

Rights Related to Sensitive Services

If you are a protected individual receiving sensitive services, VPA will direct communications regarding your receipt of sensitive services directly to you as required by California law.  We will not disclose medical information related to sensitive services to the policyholder, primary subscriber, or other Plan members without your express written authorization, except as permitted or required by law.

“Sensitive services” means all health care services related to mental or behavioral health, sexual and reproductive health, sexually transmitted infections, substance use disorder, gender affirming care, and intimate partner violence, obtained by a patient at or above the minimum age specified for consenting to the service.  The Plan does not require a protected Dependent to receive the primary subscriber’s authorization to receive any “sensitive services.”  Furthermore, any Dependent may at any time request that any confidential communication between the Plan, the Provider and the protected Dependent be communicated (via post, telephone, or electronically) to an alternate mailing address, email address, or telephone number other than that listed as the primary member’s contact information as described above in the “Right to Confidential Communications” section.

Right to Receive Notice of a Breach

You have the right to receive notice if we discover a breach of your unsecured PHI, as required by law.

Right to a Paper Copy of This Notice

You have the right to receive a paper copy of this Notice at any time, even if you agreed to receive the Notice electronically.

How to Exercise Your Rights

To exercise any of your rights described in this Notice, please contact:

Vision Plan of America
Attn: Member Services
3250 Wilshire Boulevard, Suite 1610
Los Angeles, California 90010
(213) 384-2600 or toll free at (800) 400-4872)
Dial 711 for Hearing Impaired
info@visionplanofamerica.com
www.visionplanofamerica.com

VPA may require certain requests to be submitted in writing or through an approved electronic process, as permitted by law.

Complaints

If you believe your privacy rights have been violated, you may file a complaint with VPA by contacting:

Vision Plan of America
Attn: Member Services
3250 Wilshire Boulevard, Suite 1610
Los Angeles, California 90010
(213) 384-2600 or toll free at (800) 400-4872
Dial 711 for Hearing Impaired
info@visionplanofamerica.com
www.visionplanofamerica.com

You may also file a complaint with the Secretary of the U.S. Department of Health and Human Services, Office for Civil Rights.

VPA will not retaliate against you for filing a complaint, exercising your privacy rights, or participating in an investigation.

Questions

If you have questions about this Notice or your privacy rights, please contact VPA’s Member Services during regular business hours at (213) 384-2600 or toll free at (800) 400-4872.  Dial 711 for Hearing Impaired.