Privacy Impact Assessment Summary - Interim Federal Health Program (IFHP) Claims Administration Services for Health Management Branch, Citizenship and Immigration Canada (CIC)

Health Management Branch (HMB) is responsible for the management and delivery of the IFHP. The Program provides emergency and essential health care coverage to eligible persons who demonstrate financial need. Individuals in the following groups may be eligible for health care services: refugee claimants, resettled refugees, detainees and victims of trafficking in persons and in-Canada dependents of these groups. Health care services are provided to IFHP clients by provincially recognized providers who are paid for their services by submitting claims to the claims administrator.

Claims administration for the IFHP is provided under contract by a private sector claims administrator which distributes Program information, verifies client and service eligibility against IFHP services/benefits standards, processes and adjudicates claims and reimburses providers for services to clients. The claims administrator issues the payments to providers directly (the client is not responsible for payment), produces data records, and provides statistical reports and feedback to HMB.

As the contract with the current claims administrator is coming to an end, the HMB will issue a Request for Proposals (RFP) in order to obtain the services of a claims administrator. The services the claims administrator will deliver include all operations required to receive, adjudicate, pay, track and report on claims submitted by service providers.

Personal Information collected can be divided into three groupings. For clients, data collected includes name, address, telephone number, client number, Refugee code, eligibility date, eligibility code, date of birth, marital status, gender , and date of death, if applicable. For service providers, data collected includes: name, address, telephone number, fax number, email address, provider number, provider’s specialty, financial information required for payments and record of complaints. Additional data is collected for claims processing and payments, including: claim identifier, prior approval/pre-determination and accompanying details, diagnosis code and description, procedure code and description, payment amounts and explanation, and notes.

This PIA Report identified a number of privacy risks that can be mitigated or eliminated. These privacy risks generally deal with completing documentation to comply with the Privacy Act and Treasury Board Secretariat policy requirements.

Privacy issues to be addressed include documenting the accountability of the Program Manager, purpose for collecting personal data (including updated PIB) and security procedures, ensuring the claims administrator is compliant with Privacy requirements, and ensuring records are destroyed according to the retention schedule.

The IFHP is managed within the Health Management Branch at CIC. HMB sets policy, provides program oversight and has overall responsibility for program management.

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