HomeMy WebLinkAboutRFP - P989 EMPLOYEE ASSISTANCE PROGRAMSSA January 2005
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SERVICES AGREEMENT
THIS AGREEMENT made and entered into the day and year set forth below by and
between THE CITY OF FORT COLLINS, COLORADO, a Municipal Corporation, hereinafter
referred to as the "City" and APS Healthcare Northwest, Inc., hereinafter referred to as "Service
Provider" or “APS”.
WITNESSETH:
In consideration of the mutual covenants and obligations herein expressed, it is agreed
by and between the parties hereto as follows:
1. Scope of Services. The Service Provider agrees to provide services in
accordance with the Scope of Services attached hereto as Exhibit "A", consisting of two (2)
page[s], and incorporated herein by this reference.
3. Time of Commencement and Completion of Services. The services to be
performed pursuant to this Agreement shall be initiated within ten (10) ???? days following
execution of this Agreement. Services shall be completed no later than December 31, 2006.
Time is of the essence. Any extensions of the time limit set forth above must be agreed upon in
a writing signed by the parties.
4. Contract Period. This Agreement shall commence January 1, 2006, and shall
continue in full force and effect until December 31, 2006, unless sooner terminated as herein
provided. In addition, at the option of the City, the Agreement may be extended for additional
one year periods not to exceed four (4) additional one year periods. Renewals and pricing
changes shall be negotiated by and agreed to by both parties. The Denver Boulder Greeley
CPIU published by the Colorado State Planning and Budget Office will be used as a guide.
Written notice of renewal shall be provided to the Service Provider and mailed no later than
ninety (90) days prior to contract end.
5. Delay. If either party is prevented in whole or in part from performing its
obligations by unforeseeable causes beyond its reasonable control and without its fault or
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negligence, then the party so prevented shall be excused from whatever performance is
prevented by such cause. To the extent that the performance is actually prevented, the Service
Provider must provide written
notice to the City of such condition within fifteen (15) days from the onset of such condition.
6. Early Termination by City/Notice. Notwithstanding the time periods contained
herein, the City may terminate this Agreement at any time without cause by providing written
notice of termination to the Service Provider. Such notice shall be delivered at least fifteen (15)
days prior to the termination date contained in said notice unless otherwise agreed in writing by
the parties. All notices provided under this Agreement shall be effective when mailed, postage
prepaid and sent to the following addresses:
Service Provider City: With Copy to:
APS Healthcare Northwest, Inc. City of Fort Collins City of Fort Collins
Attn:_?????_______________ Purchasing Division Human Resources
3011 Palmer P.O. Box 580 P.O. Box 580
Missoula, MT 59808 Fort Collins, CO 80522 Fort Collins, CO
80522
In the event of early termination by the City, the Service Provider shall be paid for services
rendered to the date of termination, subject only to the satisfactory performance of the Service
Provider's obligations under this Agreement. Such payment shall be the Service Provider's sole
right and remedy for such termination.
7. Contract Sum. The City shall pay the Service provider for the performance of this
Contract, subject to additions and deletions provided herein, such sums, at such times, and under
such conditions as set forth in Exhibit B, “Scope of Coverage, Rates and Payments.”
8. City Representative. The City will designate, prior to commencement of the
work, its representative who shall make, within the scope of his or her authority, all necessary
and proper decisions with reference to the services provided under this agreement. All requests
concerning this agreement shall be directed to the City Representative.
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9. Independent Service provider. The services to be performed by Service Provider
are those of an independent service provider and not of an employee of the City of Fort Collins.
The City shall not be responsible for withholding any portion of Service Provider's
compensation hereunder for the payment of FICA, Workmen's Compensation or other taxes or
benefits or for any other purpose.
10. Personal Services. It is understood that the City enters into the Agreement
based on the special abilities of the Service Provider and that this Agreement shall be
considered as an agreement for personal services. Accordingly, the Service Provider shall
neither assign any responsibilities nor delegate any duties arising under the Agreement without
the prior written consent of the City.
11. Acceptance Not Waiver. The City's approval or acceptance of, or payment for
any of the services shall not be construed to operate as a waiver of any rights or benefits
provided to the City under this Agreement or cause of action arising out of performance of this
Agreement.
13. Default. Each and every term and condition hereof shall be deemed to be a
material element of this Agreement. In the event either party should fail or refuse to perform
according to the terms of this agreement, such party may be declared in default thereof.
14. Remedies. In the event a party has been declared in default, such defaulting
party shall be allowed a period of ten (10) days within which to cure said default. In the event
the default remains uncorrected, the party declaring default may elect to (a) terminate the
Agreement and seek damages; (b) treat the Agreement as continuing and require specific
performance; or (c) avail himself of any other remedy at law or equity. If the non-defaulting party
commences legal or equitable actions against the defaulting party, the defaulting party shall be
liable to the non-defaulting party for the non-defaulting party's reasonable attorney fees and
costs incurred because of the default.
15. Binding Effect. This writing, together with the exhibits hereto, constitutes the
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entire agreement between the parties and shall be binding upon said parties, their officers,
employees, agents and assigns and shall inure to the benefit of the respective survivors, heirs,
personal representatives, successors and assigns of said parties.
16. Indemnity/Insurance.
a. The Service Provider agrees to indemnify and save harmless the City, its officers,
agents and employees against and from any and all actions, suits, claims, demands or liability of
any character whatsoever brought or asserted for injuries to or death of any person or persons,
or damages to property arising out of, result from or occurring in connection with the
performance of any service hereunder.
b. The Service Provider shall maintain commercial general liability insurance in the
amount of $500,000 combined single limits, and medical professional liability insurance,
including counseling, with limits of $1 million dollars per occurrence and $2 million dollars
annual aggregate.
c. Without limiting any of the Service Provider's obligations hereunder, the Service
Provider shall provide and maintain commercial general liability insurance coverage naming the
City as an additional insured under this Agreement. The Service Provider before commencing
services hereunder, shall deliver to the City's Director of Purchasing and Risk Management, P.
O. Box 580 Fort Collins, Colorado 80522 one copy of a certificate evidencing the insurance
coverage required from an insurance company acceptable to the City.
17. Entire Agreement. This Agreement, along with all Exhibits and other documents
incorporated herein, shall constitute the entire Agreement of the parties. Covenants or
representations not contained in this Agreement shall not be binding on the parties.
18. Law/Severability. The laws of the State of Colorado shall govern the construction
interpretation, execution and enforcement of this Agreement. In the event any provision of this
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Agreement shall be held invalid or unenforceable by any court of competent jurisdiction, such
holding shall not invalidate or render unenforceable any other provision of this Agreement.
19. Special Provisions. Special provisions or conditions relating to the services to be
performed pursuant to this Agreement are set forth in Exhibit C, consisting of two (2) page[s],
and Exhibit D, consisting of three (3) page[s], attached hereto and incorporated herein by this
reference.
CITY OF FORT COLLINS, COLORADO
a municipal corporation
By:_______________________________
James B. O'Neill II, CPPO, FNIGP
Director of Purchasing and Risk Management
Date:_____________________________
ATTEST:
_________________________________
City Clerk
APPROVED AS TO FORM:
________________________________
Assistant City Attorney
[Insert Corporation's name] or
[Insert Partnership name] or
[Insert individual's name]
Doing business as ____[insert name of business]
By:_______________________________
__________________________________
PRINT NAME
__________________________________
CORPORATE PRESIDENT OR VICE PRESIDENT
Date:_____________________________
ATTEST: (Corporate Seal)
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_____________________________
CORPORATE SECRETARY
Exhibit B - Page 7
EXHIBIT A
SCOPE OF SERVICES
1. EAP General Program Services
City wishes to provide an Employee Assistance Program (EAP) for its employees through which
employees and their dependents are able to obtain appropriate and necessary care, including confidential
counseling, assessment and referral, for substance-abuse, psychological, marital, family, financial,
legal or other personal problems that may interfere with their productivity and general well-being
APS agrees to provide such program to the City and includes the following services:
a) Maximum of Eight (8) 50-minute counseling sessions including an initial evaluation to identify
problems, with follow-up contact as deemed appropriate by the counselor. APS agrees to provide a
maximum of counseling sessions (hours) per incident per year for each eligible employee and their
family members. A counselor may deem it necessary to hold longer sessions to facilitate the needs of
the client. If session length is extended, the number of sessions are reduced to equal a maximum of
counseling hours.
b) A plan of assistance, including referral to outside agencies, for employees and their dependents
who seek assistance through the EAP. Dependents, also referred to as eligible family members, are
those individuals living with the employee or eligible for coverage under the employee’s health
insurance policy maintained through the Employer. Fees incurred by any employee or family member
at agencies other than APS are not included in the EAP coverage and are the full responsibility of the
employee or eligible family member.
a) Twenty-four hour, seven-day per week, toll-free telephone crisis counseling.
There must be a short response time to initial phone call. APS must have the resources to be
able to schedule an appointment for non-crisis situation within three (3) business days. five (5)
days. If it is an emergency situation, APS must have the resources to schedule an appointment
immediately.
within twenty-four (24) hours.
b) Follow-Up
APS must have a system in place to provide effective 100% follow-up with employees and their
dependents who have utilized the EAP to ensure that the services provided were appropriate
and effective.
c) Internet Access.
APSHelpLink is a life management tool to help with behavioral health
problems, child and elder care concerns, and work-life issues. Self–help tools help individuals
clarify problems and plan ways to resolve them independently.
d) Enhanced Web-Based Child and Eldercare Services.
Child/eldercare specialist performs the intake. Client can also choose to do the intake through the
website or an EAP counselor. Members receives five (5) pre-screened resources and fulfillment
packages sent by priority mail.
Exhibit B - Page 8
e) Standard Utilization Reports
Submitted regularly (as specified in 2 b) of this Exhibit). The reports will not indicate the
names of employees using the service. The frequency of reporting is specified below.
f) Promotion of the EAP by making the following available:
(1) Annual orientation for employees and supervisors, and annually thereafter as requested
by Employer; Act as a resource for training information and referrals. Possibly visit City
worksites to become familiar with employees and City functions.
(2) Employee brochures and/or wallet-sized cards for current and new employees with EAP
phone number and process for using the services distributed at orientation sessions.
(3) Supervisor manuals provided for distribution.
(4) EAP promotional materials provided to City, as needed, for distribution to the
employee’s family (promotional materials may be in the form of electronic payroll
inserts, newsletters, articles, informational posters or brochures).
(5) Posters displaying a toll-free hotline telephone number to reach an EAP counselor 24
hours per day.
(6) Additional services which the parties may agree to as outlined below.
h) APS shall, at its sole expense, provide all supplies, equipment, and personnel necessary for its
performance as required herein. City employees must have access to qualified therapists,
alcohol/drug abuse programs, financial and legal resources, support groups, etc. within City’s
geographic area.
2. EAP Program Services Specific to City
APS agrees to the following stipulations as to level of service:
a) Number of Sessions
Provide a maximum of eight (8) counseling sessions (hours) per incident per year for employees
and their dependents.
b) Standard Utilization Reports
Provide City with Standard Utilization Reports on a quarterly basis. Occasionally, City may
request special (non-standard) reports from APS. The formats, frequency, and price for the
custom reports are specified in Exhibit C, “Special Provisions.”
3. Additional Services to City
a) EAP services providedto employees during COBRA period at no extra cost.
b) Annual Employee Orientation and Supervisory Training at no extra cost.
4. Optional Services
Exhibit B - Page 9
Provided on a fee-for-service basis at the request of the City .
Services Description Fees Expenses
Topical
Training
Topical Training, also called “Brown Bag
Lunch” Programs, are brief (typically one-hour)
introductions to relevant and timely topics. The
City may select from a list of topics or request a
custom-developed program. Training is held in
the workplace or at a specified site.
$150 per hour of
training.
$45 per hour of
custom program
development
travel and
expenses
included
CISD Critical Incident /Stress Debriefing $250 per hour
per staff person
travel and
expenses
included
DoT
Substance
Abuse
Evaluations
$700 per
evaluation
Conflict
Resolution
$150 per session
hour
travel and
expenses
incurred
Customized
literature and
promotional
items
City may desire to add City’s name and/or logo
to APS’s literature and promotional items or may
desire to create custom literature and
promotional items.
Incremental cost
to APS plus 10%
admin. fee
EXHIBIT B
SCOPE OF COVERAGE, RATES AND PAYMENTS
Exhibit B - Page 10
1) Number of Employees Covered
City agrees to provide APS with a detailed list of employees and their geographic area of
employment at the inception of the Agreement. APS shall provide services pursuant to this Agreement
to all employees in the geographic areas to which both parties agree as indicated below or in the
attachment if the below space is not adequate:
Employee Location Employee Count
Total
Unless other arrangements are made by City and APS, City agrees to quarterly provide APS with
an accurate and updated number of employees and their locations for the purpose of calculating fees
owed to APS. These counts and locations shall be provided to APS by mail or facsimile 15 days prior to
the end of the billing cycle. The updated number of eligible employees will be indicated on the next
month’s invoice.
2) Rates
01/01/2006 – 12/31/2006 $2.22
01/01/2007 – 12/31/2007 $
01/01/2008 – 12/31/2008 $
City shall compensate APS at a rate of $2.22 per employee per month for services provided by
APS which are included in the Agreement. Renewals and pricing changes shall be negotiated by and
agreed to in writing by both parties at the time of renewal. The parties agree that the rate is firm and not
subject to any refunds, rebates, or other changes unless agreed to in writing and specified in Exhibit C,
“Special Provisions.”
3) Payments
City will pay APS on a monthly basis in advance of the service period.
Exhibit A - Page 11
EXHIBIT C
SPECIAL PROVISIONS
1. Special Provisions:
a) Professional Qualifications. Services pursuant to this Agreement shall be provided by
qualified, clinical professionals able to perform their assignments without conflict of interest. APS, in
its sole discretion, shall provide such professional services either from its employees or by retaining
qualified professionals as independent contractors to provide services under this Agreement. If
independent contractors are utilized, APS shall nevertheless be solely responsible for ensuring that
services are provided by such independent contractors as required by this Agreement.
b) Legal Compliance. APS shall be required to obtain, at its sole expense, all necessary
licenses and permits. Both APS and City agree to comply with all applicable local, state, and federal
laws, rules, and regulations prohibiting discrimination or otherwise regulating the terms and conditions
of employment.
c) Confidentiality. City agrees that all participation by its employees and their dependents
in programs hereunder is confidential. APS shall not disclose to City any information with respect to
program participants obtained by APS pursuant to their participation in programs hereunder, except with
the written consent of those participants or as required by law. APS shall have exclusive control over
the direction and guidance of the professionals rendering services under this Agreement. APS agrees to
keep confidential all City information obtained in the course of delivering services. Disclosure or use of
PHI per terms and conditions set forth in Exhibit D, "HIPAA Health Information Privacy and
Security" .
d) City's Rights Respecting Employees. In entering into this Agreement, City is not
relinquishing any of its rights and obligations to control any aspects of the employment relationship
between City and participants in programs hereunder. APS agrees that the programs it provides for City
hereunder will not be made available as a sanctuary of disciplinary immunity for employees of City.
City agrees that APS shall bear no responsibility with respect to City's decisions or actions concerning
discipline or termination of its employees.
e) APS Proprietary Data and Materials. City agrees that all publications furnished by
APS pursuant to this Agreement shall remain APS's sole property and City will do nothing to interfere
with or appropriate APS's proprietary rights therein. At the termination of this Agreement, City agrees
to return all such materials remaining unused to APS. Further, City agrees that it will not appropriate
for its own use the systems or knowledge acquired from APS hereunder. City agrees to keep
confidential and not to disclose to any such person or entity, except the employees of City and others
entitled to such disclosure by law, the information and/or management reports or systems utilized by
APS in discharging its responsibilities.
f) City’s Obligations. City agrees to cooperate with APS as necessary for APS to perform
under this Agreement including, at a minimum, distributing promotional literature provided by APS to
employees and their family members and providing an individual to act as a liaison.
2. Procedures upon Termination:
Exhibit A - Page 12
a) Generally. Upon termination of this Agreement, APS shall deliver to City final reports
of City's program hereunder. City shall deliver to APS all unused proprietary materials. The
confidentiality and nondisclosure provisions of this Agreement shall survive termination and shall
remain binding upon each party. City shall pay APS for fees earned on a pro-rata basis for all services
provided prior to termination. APS shall refund fees prepaid by City on a pro-rata basis applicable to
post-termination periods.
b) Existing Clients. City acknowledges that at the time of termination, some of its
employees or their dependents may be active cases receiving services from APS and it may be unethical
and/or illegal to terminate such services without providing further treatment for such clients. Prior to
the termination date, APS shall furnish City with a list of the number of active cases which fall into this
category, together with certification that it has examined the nature of the active cases and that further
treatment is recommended. City shall allow APS to continue to provide such services on reasonable
payment terms acceptable to APS or to make other clinically acceptable arrangements for continued
services.
Exhibit A - Page 13
EXHIBIT D
HIPAA HEALTH INFORMATION PRIVACY & SECURITY
A. Obligations and Activities of the Business Associate (Great-West Life & Annuity
Insurance Company APS Healthcare Northwest, Inc.).
1. Business Associate agrees to not use or disclose Protected Health Information
other than as permitted or required in the Administrative Services Agreement of which this
Appendix is a part or as required by law.
2. Business Associate agrees to use appropriate safeguards to prevent use or
disclosure of the Protected Health Information other than as provided for by this Appendix.
3. Business Associate agrees to mitigate, to the extent practicable, any harmful
effect that is known to Business Associate of a use or disclosure of Protected Health Information
by Business Associate in violation of the requirements of this Appendix.
4. Business Associate agrees to report to the Plan Sponsor (City of Fort Collins,
Colorado) any use or disclosure of the Protected Health Information not provided for by this
Appendix of which it becomes aware.
5. Business Associate agrees to ensure that any agent, including a subcontractor,
to whom it provides Protected Health Information received from, or created or received by
Business Associate on behalf of the Plan Sponsor agrees to the same restrictions and
conditions that apply through this Appendix to Business Associate with respect to such
information.
6. Business Associate agrees to make internal practices, books, and records,
including policies and procedures and Protected Health Information, relating to the use and
disclosure of Protected Health Information received from, or created or received by Business
Associate on behalf of, the Plan Sponsor available to the Plan Sponsor, or to the Secretary, in a
time and manner or designated by the Secretary, for purposes of the Secretary determining the
Plan Sponsor's compliance with the Privacy Rule.
7. Business Associate agrees to document such disclosures of Protected Health
Information and information related to such disclosures as would be required for the Plan
Sponsor to respond to a request by an Individual for an accounting of disclosures of Protected
Health Information in accordance with 45 CFR § 164.528.
8. Business Associate agrees to provide to the Plan Sponsor or an Individual, in a
reasonable time and manner, information collected in accordance with Section A.7. of this
Provision, to permit Plan Sponsor to respond to a request by an Individual for an accounting of
disclosures of Protected Health Information in accordance with 45 CFR § 164.528.
B. Permitted Uses and Disclosures by Business Associate
1. Except as otherwise limited in this Appendix, Business Associate may use or
disclose Protected Health Information on behalf of, or to provide services to, the Plan Sponsor
for the following purposes, if such use or disclosure of Protected Health Information would not
violate the Privacy Rule if done by the Plan Sponsor or the minimum necessary policies and
procedures of the Plan Sponsor: performing plan administration functions, obtaining premium
bids from insurance companies or other health plans for providing insurance coverage under or
on behalf of the group health plan, or modifying, amending, or terminating the group health plan.
Exhibit A - Page 14
2. Except as otherwise limited in this Appendix, Business Associate may use
Protected Health Information to provide data aggregation services to the Plan Sponsor as
permitted by 42 CFR § 164.504(e)(2)(i)(B).
3. Business Associate may use Protected Health Information to report violations of
law to appropriate Federal and State authorities, consistent with § 164.502(j)(1).
C. Obligations of Plan Sponsor
1. Plan Sponsor shall notify Business Associate of any restriction to the use or
disclosure of Protected Health Information that the Plan Sponsor has agreed to in accordance
with 45 CFR § 164.522, to the extent that such restriction may affect Business Associate's use
or disclosure of Protected Health Information.
2. Plan Sponsor shall not request Business Associate to use or disclose Protected
Health Information in any manner that would not be permissible under the Privacy Rule if done
by Plan Sponsor.
D. Termination
1. In addition to the termination provisions set forth in the Administrative Services
Agreement of which this Appendix is a part, the following termination provisions are applicable:
a. Upon the Plan Sponsor's knowledge of a material breach by Business
Associate of this Appendix, the Plan Sponsor shall either:
i. Provide an opportunity for Business Associate to cure the breach
or end the violation and terminate the Administrative Services Agreement of which this Appendix
is a part if Business Associate does not cure the breach or end the violation within the time
specified by Plan Sponsor; or
ii. Immediately terminate the Administrative Services Agreement of
which this Appendix is a part if Business Associate has breached a material term of this
Appendix and cure is not possible; or
iii. If neither termination nor cure are feasible, the Plan Sponsor shall
report the violation to the Secretary.
E. Effect of Termination
1. Except as provided in paragraph (2) of this section E, upon termination of the
Administrative Services Agreement of which this Appendix is a part, for any reason, Business
Associate shall return or destroy all Protected Health Information received from the Plan
Sponsor, or created or received by Business Associate on behalf of the Plan Sponsor. This
provision shall apply to Protected Health Information that is in the possession of subcontractors
or agents of Business Associate. Business Associate shall retain no copies of the Protected
Health Information.
2. In the event that Business Associate determines that returning or destroying the
Protected Health Information is infeasible, Business Associate shall provide to the Plan Sponsor
notification of the conditions that make return or destruction infeasible. Upon the Plan Sponsor's
agreement that return or destruction of Protected Health Information is infeasible, Business
Associate shall extend the protections of this Appendix to such Protected Health Information
and limit further uses and disclosures of such Protected Health Information to those purposes
that make the return or destruction infeasible, for so long as Business Associate maintains such
Protected Health Information.
Exhibit A - Page 15
F. Miscellaneous
1. The Parties agree to take such action as is necessary to amend this Appendix
from time to time as is necessary for Plan Sponsor to comply with the requirements of the
Privacy Rule and the Health Insurance Portability and Accountability Act of 1996, Pub. L. No.
104-191.
2. The respective rights and obligations of Business Associate under Section E of
this Provision shall survive the termination of the Administrative Services Agreement of which
this Appendix is a part.
3. Any ambiguity in this Appendix shall be resolved to permit the Plan Sponsor to
comply with HIPAA.
G. Security Standards
1. Business Associate agrees that it will implement policies and procedures to
ensure that its creation, receipt, maintenance, or transmission of electronic protected health
information ("ePHI") on behalf of Plan Sponsor complies with the applicable administrative,
physical, and technical safeguards required to protect the confidentiality and integrity of ePHI
under the Security Standards 45 CFR Part 164.
2. Business Associate agrees that it will ensure that agents or subcontractors agree
to implement the applicable administrative, physical, and technical safeguards required to
protect the confidentiality and integrity of ePHI under the Security Standards 45 CFR Part 164.
3. Business Associate agrees that it will report security violations to the Plan
Sponsor.
H. Definitions
1. "Protected Health Information" shall have the same meaning as the term
"protected health information" in 45 CFR § 164.501, limited to the information created or
received by Business Associate from or on behalf of the Plan Sponsor.
2. "Secretary" shall mean the Secretary of the Department of Health and Human
Services or his designee.
Exhibit A - Page 16
(WILL DELETE AND REPLACE WITH ABOVE EXHIBIT D )
EXHIBIT E
BUSINESS ASSOCIATE AGREEMENT
1. In rendering the services described herein, APS may create, receive from or transmit to
Customer individually identifiable health information pertaining to Customer’s covered
persons, which is "protected health information" ("PHI") within the meaning of the
regulations promulgated pursuant to the Health Insurance Portability and Accountability Act
("HIPAA") and codifed at 45 CFR Part 160 and Part 164 (the "HIPAA Privacy Rule") as
amended from time to time, and/or non-public personal information within the meaning of
the Gramm Leach Bliley Act and applicable state law and/or regulations (“NPPI”).
2. APS agrees not to use or disclose PHI or NPPI which has not been deidentified except: in
conjunction with the services described in the Services Agreement; as covered entities are
permitted by the HIPAA Privacy Rules; to provide data aggregation services related to the
health care operations of the Customer; to deidentify the PHI as is consistent with Section
164.514(b) of the Privacy Rule; to fulfill APS’s present or future legal responsibilities, or for
APS's proper management or administration. APS agrees to report to the Customer any use
or disclosure of the PHI or NPPI not provided for in this Section.
3. APS agrees to use appropriate safeguards to prevent the use or disclosure of PHI and NPPI
which are contrary to the uses or disclosures authorized herein.
4. APS agrees to enter into agreements imposing requirements equivalent to those set forth in
this Addendum on any agents or subcontractors utilized in providing the services set forth in
the Services Agreement who receive PHI or NPPI.
5. APS will make its internal practices, books, and records relating to the use and disclosure of
PHI received from, or created on behalf of, the Customer available to the Secretary of the
Federal Department of Health and Human Services for purposes of determining the
Customer’s compliance with the HIPAA Privacy Regulation.
6. APS will, at termination of the Services Agreement, if feasible, return or destroy all PHI
received from, or created by APS on behalf of, the Customer which APS and/or its
subcontractors or agents still maintain in any form, and, if feasible, will not retain any copies
of such information. If such return or destruction is not feasible, APS will extend the
protections of Sections 2-5 to the PHI and limit further uses and disclosures to those
purposes that make the return or destruction of the PHI infeasible and cause its agents and
subcontractors to do likewise.
7. Effective April 14, 2003, within twenty (20) days of a request by the Customer for access to
PHI about an individual contained in a Designated Record Set (as such Set is then defined by
the HIPAA regulations), APS shall make available to the Customer such PHI for so long as
Exhibit A - Page 17
such information is maintained in the Designated Record Set as set forth in 45 C.F.R.
§ 164.524. The Parties shall cooperate with each other in developing methodologies to
identify and/or summarize those portions of the Designated Record Set that may be
applicable to Customer’s covered persons who agree to receiving their PHI in such a manner.
The Customer shall pay APS its reasonable copying costs in preparing copies of such PHI for
any and all of these purposes. In the event any of Customer’s covered persons request access
to PHI directly from APS, APS shall, as soon as reasonably possible, forward such request to
Customer. Any responses to or denials of access to the PHI requested shall be the
responsibility of Customer.
8. Effective April 14, 2003, within forty-five (45) days of receipt of a request from the
Customer for the amendment of an individual’s PHI or a record regarding an individual
contained in a Designated Record Set, APS shall, to the extent required by 45 C.F.R.
§ 164.526, incorporate any such amendments to the PHI.
9. Effective April 14, 2003, within forty-five (45) days of receipt from the Customer of a
request for information necessary for the Customer to respond to a request for an accounting
of disclosures pertaining to an individual serviced pursuant to this Agreement, APS shall
furnish the Customer information as to those disclosures of PHI, if any, which are subject to
the accounting provided for in 45 C.F.R. § 164.528.