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Policies on Use and Disclosure of PHI 1 . Use and Disclosure Defined The County and the Plan will use and disclose PHI only as permitted under HIPAA. The terms use and " disclosure " are defined as follows : • Use. The sharing, employment, application, utilization, examination, or analysis of individually identifiable health information by any person working _for or within Indian River County, Human Resources Department or other affected County Departments or by a Business Associate , Business Associates of the Plan or the County are as follows : • Blue Cross Blue Shield of Florida, Merco/Medco , Symetra Life Insurance Company, Crowne Consulting Group , _Bradman/UniPsych Companies , The Flex Company of America, UnumProvident, Allstate Workplace Division, Guardian Life Insurance , American Dental Plan, and Assistant County Attorney. • Disclosure. For information that is protected health information, disclosure means any release , transfer, provision of access to , or divulging in any other manner of individually identifiable health information to persons not employed by or working within Indian River County, Human Resources Department . or : other affected departments of the County. 2 . Workforce Must Comply With County ' s Policy and Procedures All members of the County' s workforce (described at the beginning of this Policy and referred to herein as " employees ") must comply with this Policy and with the County' s use and disclosure procedures, which are set forth in this document . 3 . Access to PHI Is Limited to Certain Employees The following positions will have access to PHI on behalf of the County or its use in Plan Administration and will be limited to information necessary to initiate the function : • Benefits/Payroll Administrator, Human Resources Administrator, Director of Human Resources , who perform functions directly on behalf of the group health plan, and • The POCs will have access to PHI on behalf of the County for its use in plan administrative functions, as well as during the scope and course of . their job related duties . The positions named or described in both of these two categories . These employees with access may use and disclose PHI for plan administrative functions, as well as during the scope and course of their job related duties, and they may disclose PHI to other employees with access for plan administrative functions (but the PHI disclosed must be limited to the minimum amount necessary to perform the plan administrative function) . Employees with access may not disclose PHI to employees (other than employees with access) unless an 8