HomeMy WebLinkAboutStaff Report 327-05DISCUSSION
A Request For Proposals (RFP) was conducted with the assistance of the City's benefit broker with
the intent to seek a third-party claims administrator who can reduce claims costs while providing
high quality customer service, as well as being able to administer the City's current "incentive
model" plan design. The City's dental plan has a unique incentive plan design that pays an
increasing share of the treatment cost provided that the indi vidual utilizes the plan once during each
calendar year, recognizing that preventative care will help to control future treatment costs. The
percentage of payment is as follows:
First year of eligibility
Second year of eligibility
Third year of eligibility
Fourth year of eligibility
70%
80%
90%
100%
Two proposals were recei ved from Delta Dental and MetLife. The savings the City would realize by
changing to Delta Dental would be $61,951 each year with a 5% renewal cap for the administrative
fee cost in the third year. The savings the City would realize by changing to MetLife would be
$147,702 annually with a 5% renewal cap for the administrative fee in the second and third year.
Human Resources staff carefully reviewed each firm's qualifications and the recommendation is to
select Delta Dental for its extensive dental network and expected reduction in claims costs. Delta
Dental also has the capability to administer the City's unique "incentive model" plan design. City
employees will also experience a savings in their claim costs when they visit a Delta Dental-
contracted dentist as dentists agree to a lower contracted fee structure. While the savings by
changing to MetLife would be greater, the City has not experienced quality service with MetLife
recently with its long-term disa~ility plan. In contrast, Delta Dental has a superior reputation for
quality customer service and has provided dental administration services for many more years than
MetLife. The City's Purchasing Ordinance allows for selection based on performance rather than
cost.
RESOURCE IMPACT
The expected annual savings for dental administration services and claims cost is $61,951 annUally.
Funds for dental plan administration costs are included in the 2005-2007 Adopted Budget in the
General Benefits and Insurance Internal Service Fund and will be adjusted to reflect the change in
lowered costs.
POLICY IMPLICATIONS
This request does not represent a change in existing policies.
ENVIRONMENTAL REVIEW
This is not a project under the California Environmental Quality Act.
CMR: 327:05 Page 2 of3
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2.6 Every enrolled employee and Dependent meeting the preceding conditions of eligibility
is an Enrollee. However, Delta will not provide Benefits for any employee or his or her
Dependents unless (1) the employee is included on the list of Primary Enrollees
submitted as required by this Article (or any revision or correction of such a list), and
(2) the appropriate payments are made as required by Article 3 of this Contract, for the
months in which Delta provides covered dental services.
2.7 The Contractholder will compile and furnish Delta with an initial report of all Primary
Enrollees,showing their federally aSSigned Social Security numbers, their dates of hire
and location codes. The initial report shall be provided to Delta or prior to the effective
date of this Contract. The Contractholder also agrees to report all persons electing
continued coverage under Article 10, showing their federally assigned social security
numbers and date of election.
2.8 The Contractholder may continue to submit subsequent eligibility reports monthly or
may report only additions or deletions to the initial report. If the report is not updated
by the Contractholder or has not arrived or been processed for the current month, Delta
will extend the last report received to process claims. The extension of the eligibility
report does not waive the requirement that the Contractholder provide an updated
report to Delta each month indicating additions or deletions from any previous report.
The Contractholder shall pay, as set forth in Article 3, all Premiums applicable for
Primary Enrollees reported in the updated report.
2.9 Enrollees are not eligible during a period the Primary Enrollee does not report to work
on a regular basis and is not actively employed as determined by the Contractholder.
Eligibility resumes on the first day of the. month following the return to active
employment if amounts due to Delta for Enrollees have been paid. Eligibility can
continue without interruption if the Contractholder continues to report the employee as
a Primary Enrollee and amounts due to Delta are paid on the employee's behalf.
2.10 A Primary Enrollee absent from work due to a leave of absence governed by the "Family
and Medical Leave Act of 1993" (P.L. 103-3) will not be subject to Section 2.10.
2.11 A Primary Enrollee absent from work due to a leave of absence governed by the
"Uniformed Services Employment and Re-employment Rights Act of 1994" (P.L. 103-
353) will not be subject to Section 2.10. Such Primary Enrollee shall have the right to
continue coverage for up to 24 months while he or she is on military leave. If the
Primary Enrollee elects this continued coverage, he or she must submit the payments
necessary to the Contractholder.
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(g) Sealant Benefits include the application of sealants only to permanent first
molars through age eight and second molars through age 15 if they are without
caries (decay) or restorations on the occlusal surface. Sealant Benefits do not
include the repair or replacement of a sealant on any tooth within two years or
its application.
(h) Direct composite (resin) restorations are Benefits on anterior teeth and the facial
surface of bicuspids. Any other posterior direct composite (resin) restorations are
optional services and Delta's payment is limited to the cost of the equivalent
amalgam restorations.
(i) Crowns, Inlays, Onlays or Cast Restoration are Benefits on the same tooth only
once every five years while the patient is an Enrollee under any Delta plan,
unless Delta determines that replacement is required because the restoration is
unsatisfactory as a result of poor quality of care, or because the tooth involved
has experienced extensive loss or changes to tooth structure or supporting
tissues since the replacement of the restoration.
(j) Prosthodontic appliances that were provided under any Delta plan, including but
not limited to fixed bridges and partial or complete dentures, will be replaced
only after five years have passed, unless Delta determines that there is such
extensive loss of remaining teeth or change in supporting tissues that the
existing appliance cannot be made satisfactory. Replacement of a prosthodontic
appliance not provided under a Delta plan will be made if it is unsatisfactory and
cannot be made satisfactory.
(k) Delta will pay the applicable percentage of the Denti~t's Fee for a standard cast
chrome or acrylic partial denture or a standard complete denture. (A "standard"
complete or partial denture is defined as a removable prosthetic appliance
provided to replace missing natural, permanent teeth and which is constructed
using accepted and conventional procedures and materials.)
(I) If an Enrollee selects a more expensive plan of treatment than is customarily
provided or specialized techniques, an allowance will be made for the least
expensive, professionally acceptable alternative treatment plan. Delta will pay
the applicable percentage of the lesser fee and the patient is responsible for the
remainder of the Dentist's fee. For example: a crown, where an amalgam filling
would restore the tooth, or a precision denture, where a standard denture would
suffice.
(m) Delta will pay for Night Guards or Temporary Tooth Stabilization only if provided
in connection with a documented history of or formal treatment plan for active
periodontal therapy.
(n) Implants are Benefits only when conventional fixed or removable prosthesis
cannot provide clinically acceptable service and the patient will derive
significantly greater benefit from an implant-borne prosthesis.
(0) Covered implant procedures are not benefits unless the dentist requests and
receives predetermination from Delta. A second opinion may be required from a
dentist and at a location selected by Delta before predetermination will be
granted.
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7.4 The process Delta uses to determine or denY'payment for services are distributed to all
Delta Dentists. They describe in detail the dental procedures covered as Benefits, the
conditions under which coverage is provided and the limitations and exclusions
applicable to the plan. Claims are reviewed for eligibility and are paid according to these
processing policies. Delta's Dentist consultants evaluate those claims that require
additional review. If any claims are not covered or if limitations or exclusions apply to
services the Enrollee has received from a Delta Dentist, the Enrollee will be notified by
an adjustment notice on the Notice of Payment or Action. The Enrollee may contact
Delta's Customer Service department for more information regarding Delta's processing
policies.
7.5 Second Opinions. Delta reserves the right to obtain second opinions through regional
consultant members of its quality review committee. This committee conducts clinical
examinations, prepares objective reports of dental conditions, and evaluates treatment
that is proposed or has been proposed.
Delta will authorize such an examination prior to treatment when necessary to make a
Benefits determination in response to a request for a predetermination of treatment cost
by a Dentist. Delta will also authorize a second opinion after treatment if an Enrollee
has a complaint regarding the quality of care provided. Delta will notify the Enrollee and
the treating Dentist when a second opinion is necessary and appropriate, and direct the
Enrollee to the regional consultant selected by Delta to perform the clinical examination.
When Delta authorizes a second opinion through a regional consultant Delta will pay for
all charges.
The Enrollee may otherwise obtain second opinions about treatment from any Dentist
they choose, and claims for the examination may be submitted to Delta for payment.
Delta will pay such claims in accordance with the Benefits of the plan.
A copy of Delta's formal policy on second opinions is available from Delta's Customer
Service department, upon request.
7.6 For services provided by a Dentist who is not a Delta Dentist, Delta will not pay more
than the lesser of the fees entered on the claim form reporting such services to Delta or
the Prevailing Fees, multiplied by the applicable percentage specified in Article 4 for
such service. However, if the Dentist discounts, waives, rebates or does not use good
faith efforts to collect some portion of the fees entered on the claim form from the
Enrollee, Delta will not pay more than the applicable percentage specified in Article 4 of
the lesser of (1) the fees entered on the claim form, reduced by the portion discounted,
waived, rebated or not collected, or (2) the Prevailing Fees, reduced by the portion
discounted, waived, rebated or not collected.
7.7 Delta will pay a Delta Dentist directly for services provided by that Dentist. Contracts
between Delta Dental of California and its Delta Dentists provide that, in the event Delta
fails to pay the Dentist, the Enrollee will not owe the Dentist for any sums owed by
Delta.
7.8 Delta will pay an Enrollee directly for services provided by a Dentist who is not a Delta
Dentist, and those payments are not assignable. The Enrollee is liable to the Dentist for
payment to the Dentist for the cost of the service. In addition, Delta will pay for services
from dental school clinics by students of dentistry or instructors who are not licensed by
the state of California. In the event Delta fails to pay the Dentist who has not contracted
with Delta as a Delta Dentist, the Enrollee may be liable to the Dentist for the cost of
the service.
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The California Department of Managed Health Care is responsible for regulating health
care service plans. If the Enrollee has a grievance against the health plan, they should
first telephone Delta, the plan, at 1-800-765-6003 and use Delta's grievance process
before contacting the department. Utilizing this grievance procedure does not prohibit
any potential legal rights or remedies that may be available an Enrollee. If the Enrollee
needs' help with a grievance involving an emergency, a grievance that has not been
satisfactorily resolved by the plan, or a grievance that has remained unresolved for
more than 30 days, the Enrollee may call the department for assistance. Enrollees may
also be eligible for an Independent Medical Review (IMR). If the Enrollee is eligible for
IMR, the IMR process will provide an impartial review of medical decisions made by a
health plan related to the medical necessity of a proposed service or treatment,
coverage decisions for treatments that are experimental or investigational in nature and
payment disputes for emergency or urgent medical services. The department also has a
toll-free telephone number (1-888-HMO-2219) and a TDD line (1-877-688-9891) for
the hearing and speech impaired. The department's Internet Web site
(http://www.hmohelp.ca.gov) has complaint forms, IMR application forms and
instructions online.
An IMR has limited application to a dental program. Enrollees may request an IMR only
if the dental claim concerns a life-threatening or seriously debilitating condition(s) and
is denied or modified because it was deemed an experimental procedure.
If the group health plan is subject to the Employee Retirement Income Security Act of
1974 (ERISA), the Enrollee may contact the U.S. Department of Labor, Employee
Benefits Security Administration (EBSA) for further review of the claim or if the Enrollee
has questions about the rights under ERISA. The Enrollee may also bring a civil action
under section S02(a) of ERISA. The address of the U.S. Department of Labor is: U.S.
Department of Labor, Employee Benefits Security Administration (EBSA), 200
Constitution Avenue, N.W. Washington, D.C. 20210.
7.12 The Benefits that Delta provides are limited to the applicable percentages of the
Dentist's fees or allowances specified in Article 4. The Contractholder requires the
Enrollee to pay the balance of any such fee or Allowance, known as the "Patient
Copayment," as a method of sharing the costs of providing dental Benefits between the
Contractholder and Enrollees. If the Dentist discounts, waives or rebates any portion of
the Patient Copayment to the Enrollee, Delta only provides as Benefits the Dentist's fees
or allowances reduced by the amount that such fees or allowances are discounted,
waived or rebated.
ARTICLE 8 -OTHER DELTA OBLIGATIONS
8.1 Delta shall encourage Delta Dentists to submit a standardized claim form before
providing service, showing the patient's dental needs and the treatment necessary in
the professional judgment of the Dentist.
Delta shall predetermine, from the claim and other data, what would be payable by
Delta and an Enrollee for the proposed service under the terms of this plan as of the
date of predetermination.
Such predetermination shall not constitute a guaranty or authorization of Benefits under
this Contract, and any actual payment by Delta will depend upon the patient's eligibility
and remaining annual maximum when completed services are reported to Delta.
Delta shall advise Delta Dentists to notify the patient of all information provided by
Delta in the predetermination.
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ARTICLE 9 -TERMINATION AND RENEWAL
9.1 This Contract may be terminated for the following causes:
(a) By Delta, if the Contractholder fails (1) to give Delta a list of all Primary
Enrollees, as required under Article 2, or (2) to permit the inspection of the
Contractholder's records as called for under' Article 2,' provided the
Contractholder has been duly notified of such failure (and billed for amounts
due, if applicable) and at least 15 days have elapsed since the date of
notification.
(b) By either the Contractholder or Delta, upon expiration of a Contract Term.
9.2 If Delta terminates this Contract under paragraph 9.1 (a), all Benefits end and Delta is
released from all further obligations of this Contract, effective the last day of the month
in which written notice of termination is given. The Contractholder will remain liable to
Delta for the full amount of all Dentist's Statements paid or otherwise discharged by
Delta pursuant to this Contract, including claims discharged by Delta pursuant to this
paragraph, plus $8.01 per Primary Enrollee per month of such amount as provided in
paragraph 3.1, less amounts actually paid by the Contractholder to Delta.
9.3 A party choosing to terminate this Contract at the end of a Contract Term must give at
least 30 days written notice of termination to the other party. If Delta wants to change
the administration or Benefits effective at the beginning of the next Contract Term,
Delta will give at least 60 days advance written notice of such changes to the
Contractholder. Such an advance notice will have the effect of a notice of termination as
of the end of the Contract Term, unless the Contractholder agrees to the new Contract
provisions.
9.4 If the Contractholder notifies Delta in writing of its intention to terminate this Contract
as of any date other than the end of the Contract Term, such termination will be treated
as termination under paragraph 9.1(a).
9.5 If this Contract is terminated for any cause, Delta is not required to predetermine
services beyond the termination date or to pay for services provided after such
termination date, except for the completion of Single Procedures begun while this
Contract was in effect which are otherwise Benefits under this Contract.
9.6 All Benefits end for all Enrollees, when this Contract ends, and Delta will not provide
any right to continuation, renewal or reinstatement of Benefits to such persons in that
event.
9.7 Delta must notify the Contractholder in writing of any termination by Delta under
paragraph 9.1, and the Contractholder shall promptly mail a copy of such notice to each
Primary Enrollee and provide Delta with proof of mailing and the date.
9.8 Open Enrollment Periods will coincide with CalPers open enrollment each year.
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ARTICLE 10 .,. OPTIONAL CONTINUATION OF COVERAGE
10.1 . The federal Consolidated Omnibus Budget Reconciliation Act (or COBRA, pertaining to
certain employers having 20 or more employees) and the California Continuation
Benefits Replacement Act (or Cal-COBRA, pertaining to employers with two to 19
employees), both require that continued health care coverage be made available to
"Qualified Beneficiaries" who lose health care coverage under the group plan as a result
of a "Qualifying Event." Enrollees may be entitled to continue coverage under this plan,
at the Qualified Beneficiary's expense, if certain conditions are met. The period of
continued coverage depends on the Qualifying Event and whether the Enrollee is
covered under federal COBRA or Cal-COBRA.
10.2 DEFINITIONS
The meaning of key terms used in this Article are shown below and apply to both
federal and Cal-COBRA.
Qualified Beneficiary means:
1. Enrollees who are enrolled in the Delta plan on the day before the Qualifying
Event, or
2. A child who is born to or placed for adoption with the Primary Enrollee during the
period of continued coverage, provided such child is enrolled within 30 days of
birth or placement for adoption.
Qualifying Event means any of the following events which, except for the election of
this continued coverage, would result in a loss of coverage under the dental plan:
Event 1: The termination of employment (other than termination for gross
misconduct), or the reduction in work hours, by the Primary Enrollee's
employer;
Event 2: The death of the Primary Enrollee;
Event 3: Divorce or legal separation from the Primary Enrollee;
Event 4: A dependent child ceaSing to meet the description of dependent child;
Event 5: As to dependents only, a Primary Enrollee becoming entitled to Medicare.
10.3 PERIODS OF CONTINUED COVERAGE UNDER FEDERAL COBRA
Qualified Beneficiaries may continue coverage for 18 months following the occurrence
Qualifying Event 1.
This 18-month period can be extended for a total of 29 months, provided:
1. A determination is made under Title II or Title XVI of the Social Security Act that
an individual is disabled on the date of the Qualifying Event or became disabled
at any time during the first 60 days of continued coverage; and
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2. Notice of the determination is given to the employer during the initial 18 months
of continued coverage and within 60 days of the date of the determination.
This period of coverage will end on the first of the month that begins more than 30 days
after the date of the final determination that the disabled individual is no longer
disabled. The Primary Enrollee must notify the employer/administrator within 30 days of
any such determination.
If, during the 18-month continuation period resulting from Qualifying Event 1, the
Primary Enrollee's Dependents experience Qualifying Events 2, 3, 4 or 5, they may
choose to extend coverage for up to a total of 36 months (inclusive of the period
continued under Qualifying Event 1).
The Primary Enrollee's Dependents may continue coverage for 36 months following the
month in which Qualifying Events 2, 3, 40r 5 occur.
Under federal COBRA law only, when an employer has filed for bankruptcy under Title
II, United States Code, Benefits may be substantially reduced or eliminated for retired
employees and their Dependents, or the surviving spouse of a deceased retired
employee. If this Benefit reduction or elimination occurs within one year before or one
year after the filing, it is considered a Qualifying Event. If the Primary Enrollee is a
retiree, and has lost coverage because of this Qualifying Event, he or she may choose to
continue coverage until his or her death. The Primary Enrollee's Dependents who have
lost coverage because of this Qualifying Event may choose to continue coverage for up
to 36 months following the Primary Enrollee's death.
lOA PERIODS OF CONTINUED COVERAGE UNDER CAL-COBRA (groups of 2 -19)
In the case of Cal-COBRA, Delta will act as the administrator. Notification and premium
payments should be made directly to Delta. Notifications and payments should be
delivered by first-class mail, certified mail, or other reliable means of delivery.
Individuals who are eligible for coverage under the federal COBRA law are not eligible
for coverage under Cal-COBRA. The employer must notify Delta in writing within 30
days of the date when the employer becomes subject to COBRA.
Qualified Beneficiaries may continue coverage for 36 months following the month in
which Qualifying Events 1, 2, 3, 4 or 5 occur.
If, during the 36-month continuation period resulting from Qualifying Event 1, the
Qualified Beneficiary is determined under Title II or Title XVI of the Social Security Act
to be disabled on the date of the Qualifying Event or became disabled at any time
during the first 60 days of continuation coverage; and notice of the determination is
given to the employer during the initial period of continuation coverage and within 60
days of the date of the social security determination letter, the Qualified Beneficiary
may continue coverage for a total of 36 months following the month in which Qualifying
Event 1 occurs.
This period of coverage will end on the first of the month that begins more than 30 days
after the date of the final determination that the disabled individual is no longer
disabled. The Qualified Beneficiary must notify the employer or administrator within 30
days of any such determination.
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5. The individual first obtains coverage for dental benefits, after the date of the
election of continued coverage, under another group health plan (as an
employee or dependent) which does not contain or apply any exclusion or
limitation with respect to any pre-existing condition of such person, if that pre-
existing condition is covered under this plan;
6. Entitlement to Medicare.
The employer or Primary Enrollee shall notify Delta or the administrator within 30 days
of the occurrence of any of the above events. Once continued coverage terminates, it
cannot be reinstated.
10.8 TERMINATION OF THE EMPLOYER'S DENTAL CONTRACT
If the dental contract between the employer and Delta terminates prior to the time that
the continuation coverage would otherwise terminate, the employer shall notify a
Qualified Beneficiary (either 30 days prior to the termination or when all Enrollees are
notified whichever is later) of that person's ability to elect continuation coverage under
the employer's subsequent dental plan, if any. The employer must notify the successor
plan of the Qualified Beneficiaries receiving continuation coverage so they may be
notified of how to continue coverage under that plan.
The continuation coverage will be provided only for the balance of the period that a
Qualified Beneficiary would have remained covered under the Delta plan had such plan
with the former employer not terminated. The continuation coverage will terminate if a
Qualified Beneficiary fails to comply with the reqUirements pertaining to enrollment in,
and payment of premium to the new group benefit plan within 30 days of receiving
notice of the termination of the Delta plan.
10.9 OPEN ENROLLMENT CHANGE OF COVERAGE
A Qualified Beneficiary may elect to change continuation coverage during any
subsequent open enrollment period, if the employer has contracted with another plan to
provide coverage to its active employees. The continuation coverage under the other
plan will be provided only for the balance of the period that a Qualified Beneficiary
would have remained covered under the Delta plan.
ARTICLE 11-GENERAL PROVISIONS
11.1 No agent has authority to change this Contract or waive any of its provIsions. No
change in this Contract is valid unless approved by an executive officer of Delta and
included in this Contract by written amendment.
11.2 The provisions of this Contract are severable. If any portion of this Contract or any
Amendment of it is determined to be illegal, void or unenforceable by any arbitrator,
court or other competent authority, all other provisions of this Contract will remain in
effect.
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APPENDIX B
CODE ON DENTAL PROCEDURES AND NOMENCLATURE
NOTE: All the listed procedures may not be benefits under the terms of your contract. Refer to
your contract for your specific benefits.
D0100 -D0999 DIAGNOSTIC
Clinical oral evaluations
D0120 Periodic oral evaluation
D0140 Limited oral evaluation -problem focused
D0150 Comprehensive oral evaluation -new or established patient
D0160 Detailed and extensive oral evaluation -problem focused, by report
D0170 Re-evaluation -limited, problem focused (established patient; not post-operative
visit)
D0180 Comprehensive periodontal evaluation -new or established patient
Radiographs/diagnostic imaging (including interpretation)
D02l0 Intraoral -complete series (including bitewings)
D0220 Intraoral -periapical first film
D0230 Intraoral -periapical each additional film
D0240 Intraoral -occlusal film
D0250 Extraoral -first film
D0260 Extraoral -each additional film
D0270 Bitewing -single film
D0272 Bitewings -two films
D0274 Bitewings -four films
D0277 Vertical bitewings - 7 to 8 films
D0290 Posterior -anterior or lateral skull and facial bone su'rvey film
D03l0 Sialography
D0320 Temporomandibular joint arthrogram, including injection
D0321 Other temporomandibular joint films, by report
D0322 Tomographic survey
D0330 Panoramic film
D0340 Cephalometric film
D0350 Oral/facial photographic images
Tests and examinations
D04l5 Collection of microorganisms for culture and sensitivity
D04l6 Viral culture
D0421 Genetic test for susceptibility to oral diseases
D0425 Caries susceptibility tests
D0431 Adjunctive pre-diagnostic test that aids in detection of mucosal abnormalities
including premalignant and malignant lesions, not to include cytology or biopsy
procedures
D0460 Pulp vitality tests
D0470 Diagnostic casts
Oral pathology laboratory
D0472 Accession of tissue, gross examination, preparation and transmission of written report
D0473 Accession of tissue, gross and microscopic examination, preparation and transmission
of written report
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Resin-based composite crown, anterior 02390
02391
02392
02393
02394
Resin-based composite -one surface, posterior
Resin-based composite -two surfaces, posterior
Resin-based composite -three surfaces, posterior
Resin-based composite -four or more surfaces, posterior
Gold foil restorations
02410 Gold foil -one surface
02420 Gold foil -two surfaces
02430 Gold foil -three surfaces
Inlay I onlay restorations
02510 Inlay -metallic -one surface
02520 Inlay -metallic -two surfaces
02530 Inlay -metallic -three or more surfaces
02542 Onlay -metallic -two surfaces
02543 Onlay -metallic -three surfaces~
02544 Onlay -metallic -four or more surfaces
02610 Inlay -porcelain/ceramic -one surface
02620 Inlay -porcelain/ceramic -two surfaces
02630 Inlay -porcelain/ceramic -three or more surfaces
02642 Onlay -porcelain/ceramic -two surfaces
02643 Onlay -porcelain/ceramic -three surfaces
02644 Onlay -porcelain/ceramic -four or more surfaces
02650 Inlay -resin-based composite -one surface
02651 Inlay -resin-based composite -two sUrfaces
02652 Inlay -resin-based composite -three or more surfaces
02662 Onlay -resin-based composite -two surfaces
02663 Onlay -resin-based composite -three surfaces
02664 Onlay -resin-based composite -four or more surfaces
Crowns -single restorations only
. 02710 Crown -resin-based composite (indirect)
02712 Crown -3/4 resin-based composite (indirect)
02720 Crown -resin with high noble metal
02721 Crown -res'in with predominantly base metal
02722 Crown -resin with noble metal
02740 Crown -porcelain/ceramic substrate
02750 Crown -porcelain fused to high noble metal
02751 Crown -porcelain fused to predominantly base metal
02752 Crown -porcelain fused to noble metal
02780 Crown -3/4 cast high noble metal
02781 Crown -3/4 cast predominantly base metal
02782 Crown -3/4 cast noble metal
02783 Crown -3/4 porcelain/ceramic
02790 Crown -full cast high noble metal
02791 Crown -full cast predominantly base metal
02792 Crown -full cast noble metal
02794 Crown -titanium
02799 Provisional crown
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Endodontic retreatment
D3346 Retreatment of previous root canal therapy -anterior
D3347 Retreatment of previous root canal therapy -bicuspid
D3348 Retreatment of previous root canal therapy -molar
Apexification/ recalcification procedures
D3351 Apexification/recalcification -initial visit (apical closure/calcific repair of perforations,
root resorption, etc.)
D3352 Apexification/recalcification -interim medication replacement (apical closure/calcific
repair of perforations, root resorption, etc.)
D3353 Apexification/recalcification -final visit (includes completed root canal therapy ...;..
apical closUre/calcific repair of perforations, root resorption, etc.)
Apicoectomy/ periradicular services
D3410 Apicoectomy/periradicular surgery -anterior
D3421 Apicoectomy/periradicular surgery -bicuspid (first root)
D3425 Apicoectomy/periradicular surgery -molar (first root)
D3426 Apicoectomy/periradicular surgery (each additional root)
D3430 Retrograde filling -per root
D3~50 Root amputation -per root
D3460 Endodontic endosseous implant
D3470 Intentional reimplantation (including necessary splinting)
Other endodontic procedures
D3910 Surgical procedure for isolation of tooth with rubber dam
D3920 Hemisection (including any root removal), not including root canal therapy
D3950 Canal preparation and fitting of preformed dowel or post
D3999 Unspecified endodontic procedure, by report
04000 -04999 PERIODONTICS
Surgical services (including usual post-operative care)
D4210 Gingivectomy or gingivoplasty -four or more contiguous teeth or bounded teeth
spaces per quadrant
D4211 Gingivectomy or gingivoplasty -one to three contiguous teeth or bounded teeth
spaces per quadrant
D4240 Gingival flap procedure, including root planing -four or more contiguous teeth or
bounded teeth spaces per quadrant
D4241 Gingival flap procedure, including root planing -one to three contiguous teeth or
D4245
D4249
D4260
bounded teeth spaces per quadrant
Apically positioned flap
Clinical crown lengthening -hard tissue
Osseous surgery (including flap entry and closure) -'-four or more contiguous teeth or
bounded teeth spaces per quadrant
D4261 Osseous surgery (including flap entry and closure) -one to three contiguous teeth or
D4263
D4264
D4265
D4266
D4267
D4268
D4270
D4271
bounded teeth spaces per quadrant
Bone replacement graft -first site in quadrant
Bone replacement graft -each additional site in quadrant
Biologic materials to aid in soft and osseous tissue regeneration
Guided tissue regeneration -resorbable barrier, per site
Guided tissue regeneration -nonresorbable barrier, per site (includes membrane
removal)
Surgical revision procedure, per tooth
Pedicle soft tissue graft procedure
Free soft tissue graft procedure (including donor site surgery)
5
D6070 Autment supported retainer for porcelain fused to metal FPD (predominantly base
metal)
D6071 Autment supported retainer for porcelain fused to metal FPD (noble metal)
D6072 Abutment supported retainer for cast metal FPD (high noble metal)
D6073 Abutment supported retainer for cast metal FPD (predominantly base metal)
D6074 Abutment supported retainer for cast metal FPD (noble metal)
D6075 Implant supported retainer for ceramic FPD
D6076 Implant supported retainer for porcelain fused to metal FPD (titanium, titanium alloy,
or high noble metal)
D6077 Implant supported retainer for cast metal FPD (titanium, titanium alloy, or high noble
metal)
D6078 Implant/abutment supported fixed denture for completely edentulous arch
D6079 Implant/abutment supported fixed denture for partially edentulous arch
Other implant services
D6080 Implant maintenance procedures, including removal of prosthesis, cleansing of
prosthesis and abutments and reinsertion of prosthesis
D6090 Repair implant supported prosthesis, by report
D6094 Abutment supported crown -(titanium)
D6095 Repair implant abutment, by report
D6100 Implant removal, by report
D6190 Radiographic/surgical implant index, by report
D6194 Abutment supported retainer crown for FPD -(titanium)
D6199 Unspecified implant procedure, by report
06200 -06999 PROSTHODONTICS, FIXED
(Each retainer .andeach pontic constitutes a unit in a fixed partial denture)
Fixed partial denture pontics
D6205 Pontic -indirect resin based composite
D6210 Pontic -cast high noble metal
D6211 Pontic -cast predominantly base metal
D6212 Pontic -cast noble metal
D6214 Pontic -titanium
D6240 Pontic -porcelain fused to high noble metal
D6241 Pontic -porcelain fused to predominantly base metal
D6242 pontic -porcelain fused to noble metal
D6245 Pontic -porcelain/ceramic
D6250 Pontic -resin with high noble metal
D6251 Pontic -resin with predominantly base metal
D6252 Pontic -resin with noble metal
D6253 Provisional pontic
Fixed partial denture retainers -iniaysl onlays
D6545 Retainer -cast metal for resin bonded fixed prosthesis
D6548 Retainer -porcelain/ceramic for resin bonded fixed prosthesis
D6600 Inlay -porcelain/ceramic, two surfaces
D6601 Inlay -porcelain/ceramic, three or more surfaces
D6602 Inlay -cast high metal, two surfaces
D6E?03 Inlay -cast high metal, three or more surfaces
D6604 Inlay -cast predominantly base metal, two surfaces
D6605 Inlay -cast predominantly base metal, three or more surfaces
D6606 Inlay -cast noble metal, two surfaces
D6607 Inlay -cast noble metal, three or more surfaces
D6608 Onlay -porcelain/ceramic, two surfaces
9
07856 Myctcmy
07858 Jcint reccnstructicn
07860 Arthrctcmy
07865 Arthroplasty
07870 Arthrccentesis
07871 Ncn-arthrosccpic lysis and lavage
07872 Arthrcsccpy -diagncsis, with .or withcut bicpsy
07873 Arthrcsccpy -surgical: lavage and lysis .of adhesicns
07874 Arthrcsccpy -surgical: disc repcsiticning and stabilizaticn
07875 Arthrcsccpy -surgical: syncvectcmy
07876 Arthrcsccpy -surgical: discectcmy
07877 Arthrosccpy -surgical: debridement
07880 Occlusal crthctic device, by repcrt
07899 Unspecified TMO therapy, by repcrt
Repair of traumatic wounds
07910 Suture .of recent small wcunds up tc 5 cm
Complicated suturing (reconstruction requiring delicate handling of tissues and wide
undermining for meticulous closure)
07911 Ccmplicated suture -up tc 5 cm
07912 Ccmplicated suture -greater than 5 cm
Other repair procedures
07920 Skin graft (identify defect ccvered, Iccaticn and type .of graft)
07940 Ostecplasty -fcr crthcgnathic defcrmities
07941 Ostectcmy -mandibular rami
07943 Ostectcmy -mandibular rami with bcne graft; includes .obtaining the graft
07944 Ostectcmy -segmented .or subapical -per sextant .or quadrant
07945 Ostectcmy -bcdy cfmandible
07946 LeFcrt I (maxilla -tctal)
07947 LeFcrt I (maxilla -segmented)
07948 LeFcrt II .or LeFcrt III (cstecplasty .of facial bcnes fcr midface hypcplasia .or retrusicn)
-with cut bcne graft
07949 LeFcrt II .or LeFcrt III -with bcne graft
07950 Ossecus, cstecpericsteal, .or cartilage graft .of the mandible .or facial bcnes -
07953
07955
07960
07963
07970
07971
07972
07980
07981
07982
07983
07990
07991
07995
07996
07997
07999
autcgencus .or ncnautcgencus, by repcrt
Bcne replacement graft f.or ridge preservaticn -per site
Repair .of maxillcfacial scft and/cr hard tissue defect
Frenulectcmy (frenectcmy .or frenct.omy) -separate prccedure
Frenulcplasty
Excisicn .of hyperplastic tissue -per arch
Excisicn .of periccronal gingiva·
Surgical reducticn .of fibrcus tubercsity
Sialclith.otcmy
Excisicn .of salivary gland, by repcrt
Sialcdcchcplasty
Clcsure .of salivary fistula
Emergency trachectcmy
. Ccrcncidectcmy
Synthetic graft -mandible .or facial bcnes, by rep.ort
Implant -mandible fcr augmentati.on purpcses (excluding alveclar ridge), by repcrt
Appliance remcval (nct by dentist whc placed appliance), includes remcval .of archbar
Unspecified .oral surgery procedure, by repcrt
13
Professional visits
09410 House/extended care facility call
09420 Hospital call
09430 Office visit for observation (during regularly scheduled hours)
performed
09440 Office visit -after regularly scheduled hours
09450 Case presentation, detailed and extensive treatment planning
Drugs
09610 Therapeutic drug injection, by report
09630 Other drugs and/or medicaments, by report
Miscellaneous services
09910 Application of desensitizing medicament
no other services
09911 Application of desensitizing resin for cervical and/or root surface, per tooth
09920 Behavior management, by report
09930 Treatment of complications (post-surgical) -unusual circumstances, by report
09940 Occlusal guard, by report
09941 Fabrication of athletic mouthguard
09942 Repair and/or reline of occlusal guard
09950 Occlusion analysis -mounted case
09951 Occlusal adjustment -limited
09952 Occlusal adjustment -complete
09970 Enamel microabrasion
09971 Odontoplasty 1,..2 teeth; includes removal of enamel projections
09972 External bleaching -per arch
09973 External bleaching -per tooth
09974 Internal bleaching -per tooth
09999 Unspecified adjunctive procedure, by report
Note: This Appendix represents codes and nomenclature excerpted from the version of Current
Dental Terminology (COT) in effect at the date of this printing. COT coding and nomenclature
are the copyright of the American Dental Association, and have been accepted as the standard
for data transmission purposes under federal Aqministrative Simplification regulations. For the
purposes of this Appendix, Delta's administration of Benefits, Limitations and Exclusions under
this Contract will at all times be based on the then-current version of COT whether or not a
revised Appendix B is provided. Notes in italic type have been added by Delta Dental for
clarification.
15
III. CONTRACTHOLDER RESPONSIBILITIES
A. Contractholder is responsible for the delivery and accuracy of all Enrollee
eligibility that it, or its employee(s), provide(s) to Delta pursuant to this
Agreement. Any errors or delays shall be adjusted as set forth in Article 3 of the
Contract. Contractholder is responsible for any and all hardware, software, or
any other equipment, application or transmission capability to access the Delta
website. Contractholder shall be responsible for the selection of its Internet
access provider (lAP) or Internet service provider (ISP) and shall hold Delta, and
its computer processing subsidiary, Deltanet, Inc. (Deltanet), harmless for any
and all transmission or update delays, failures or errors caused by
Contractholder's acts or omissions or caused by the ISP's acts or omissions.
B. Contractholder agrees, and shall require its employees to agree, to strictly
maintain the confidentiality of the logon ides) and password(s) and to provide
them only to those employees who will transmit or update Enrollee eligibility
pursuant to this Agreement. Delta will provide a logon id and password that is
specific to each Contractholder employee who will be permitted to update
eligibility through this web access. Contractholder and each such employee may
not transfer a logon id or password to another employee. Contractholder agrees
to hold Delta and Deltanet, harmless for any and all potential breaches of
(:onfidentiality resulting from or arising out of the transmission or update of
Enrollee eligibility information through Internet connections. Contractholder shall
indemnify Delta and Deltanet from and against any liability 'or loss Delta or
Deltanet may incur by reason of any covenant, condition or warranty contained
in the Contract relating to confidentiality or the interception of transmission over
the Internet by unknown third parties except for any such breach caused by
Delta's or Deltanet's error or omission.
C. Contractholder agrees to install and implement any desktop upgrades and/or
configuration changes necessary to continue to update Enrollee eligibility
information pursuant to this Agreement.
IV. DELTA RESPONSIBILITIES
A. Upon receipt of the Executed Agreement, Delta will provide the logon ides) and
password(s) necessary for Contractholder to access the eligibility update section
of Delta's website.
B. Delta will provide Contractholder with a description of a standard desktop
configuration that Contractholder must utilize to access, transmit and update
eligibility information to Delta through Delta's website. In no event shall Delta be
responsible to provide Contractholder with any hardware, software, ISP or any
other equipment, application or transmission capability.
C. Delta shall not be liable to Contr'actholder for any indirect, special, incidental,
exemplary or consequential damages (including, without limitation, lost profits)
related to this Agreement or resulting from Contractholder's access to or inability
to access Delta's website, or the eligibility update section of the website, arising
from any cause of action whatsoever, including contract, tort, warranty, strict
liability, or negligence, even if Delta has been notified of the possibility of such
damages.
2
APPENDIX D
HIPAA BUSINESS ASSOCIATE AGREEMENT: GROUP HEALTH PLAN
CITY OF PALO ALTO
DELTA GROUP #2795
RECITALS
Whereas, the administrative simplification provisions of the Health Insurance Portability and
Accountability Act of 1996 and related regulations require that contracts between covered
entities and entities known as business associates comply with enumerated standards and
requirements;
Whereas, the Contractholder executes this Business Associate Agreement on behalf of the
Group Health Plan; .
Whereas, Delta's administration of the group dental program makes Delta a business associate
of the Group Health Plan as described or defined under HIPAA;
Whereas, the purpose of this Business Associate Appendix is to satisfy the HIPAA standards
and requirements;
Now therefore, in consideration of the mutual promises below, the Contractholder, the Group
Health Plan and Delta agree as follows:
SECTION 1 -DEFINITIONS
1.1 "HIPAA" shall mean the administrative simplification provisions of the Health Insurance
Portability and Accountability Act of 1996 and related regulations, Title 45 Parts 160
and 164 of the Code of Federal Regulations, as amended from time to time.
1.2 "Protected Health Information" (PHI) shall have the same meaning as defined in HIPAA
and shall apply to those individuals who are eligible and/or enrolled in the Group Health
Plan's dental benefit program administered by Delta.
1.3 Terms used, but not otherwise defined, in this Business Associate Appendix shall have
the same meaning qS those terms have in HIPAA.
SECTION 2 -BUSINESS ASSOCIATE AGREEMENT
2.1 The provisions of this Section 2 control over any provision in this Contract that conflicts
with this Section 2.
1
e. Contractholder's Uses and Disclosures :Contractholder shall use and disclose PHI
only in compliance with HIPAA and for the purpose of providing plan
administration functions to the Group Health Plan. Plan administrative functions
are defined as administration functions performed by the plan sponsor of a group
health plan on behalf of the group health plan and excludes functions performed
by the plan sponsor in connection with any other benefit or benefit plan of the
plan sponsor.
2.3 Appropriate Safeguards. Delta agrees to use appropriate safeguards to prevent its use
or disclosure of PHI other than as provided for by this Business Associate Appendix.
2.4 Mitigation. Delta agrees to mitigate, to the extent practicable, any harmful effect that is
known to Delta of a use or disclosure of PHI by Delta in violation of the requirements of
this Business Associate Appendix.
2.5 Reporting of Disclosures of PHI. As soon as practical after discovery, Delta shall report
to the Group Health Plan, or its designate, any use or disclosure of PHI by Delta not
provided for in this Business Associate Appel1dix of which Delta becomes aware.
2.6 Agents and Contractors. Delta shall ensure that any Delta agent or subcontractor to
whom Delta discloses PHI agrees, in writing, to be bound by the same restrictions and
conditions that apply to Delta through this Business Associate Appendix.
2.7 Access to and Availability of PHI. Delta shall, in accordance with HIPAA and as
appropriate:
a. Provide access to . the requested PHI within Delta's or its agent's or
subcontractor's possession. The Group Health Plan shall as soon as practicable
forward to Delta any requests the Group Health Plan receives from the
individual. Delta shall be responsible for responding to the Group Health Plan or
individual who sent the request to Delta. If the response is to be sent to the
,Group Health Plan, Delta shall send the PHI to the Group Health Plan within 15
days of Delta's receipt of the request.
b. Amend, notify appropriate recipients of any amendment, and incorporate any
amendment to the requested PHI within Delta's possession or its agent's or
subcontractor's. The Group Health Plan shall as soon as practicable forward to
Delta any requests the Group Health Plan receives from the individual. Delta
shall be responsible for responding to the Group Health Plan or individual who
sent the request to Delta. If the response is to be sent to the Group Health Plan,
Delta shall send the response to the Group Health Plan within 45 days of Delta's
receipt of the request.
c. Provide an accounting of ·disclosures of PHI as required by HIPAA. The Group
Health Plan shall as soon as practicable forward to Delta any requests the Group
Health Plan receives from the individual. Delta shall be responsible for
responding to the Group Health Plan or individual who sent the request to Delta.
Delta agrees to track, and request that its agents or subcontractors track, all
such disclosures of PHI that would be required to respond to a request for
accounting of disclosures of PHI as required by HIPAA. If the response is to be
sent to the Group Health Plan, Delta shall send the accounting to the Group
Health Plan within 45 days of Delta's receipt of the request.
3
c. In the event of any termination of this Business Associate Appendix, Delta shall
return or destroy all PHI that Delta still maintains in any form and shall retain no
copies. If return or destruction is not feasible because such PHI is necessary to
fulfill Delta's legal responsibilities or other management and administrative
purposes, Delta shall retain the PHI and shall continue to protect the
confidentiality of PHI as required by this Business Associate Appendix. Delta shall
limit any use or disclosure of PHI to those purposes that make the return or
destruction of PHI infeasible. Delta agrees to require that any PHI in the
possession of its agents or subcontractors retained, returned or destroyed, as
applicable.
d. The following sections shall survive termination of this Agreement: 2.7, 2.8,
2.10, 5.2 and 5.3.
2.11 Notice of Privacy Practices. The Contractholder represents and warrants that the Group
Health Plan's notice of privacy practices shall not, subject to HIPAA's requirement, limit
or restrict Delta's use or disclosure of PHI as necessary for Delta to perform the services
described in the Contract.
2.12 Security Rule Provisions. Delta will comply with the following provisions by April 21,
2005, or such other applicable compliance date. For purposes of this section, "electronic
protected health information" (ePHI) shall have the same meaning as defined in HIPAA
and shall apply to those individuals who are eligible and/or enrolled in the Group Health
Pian's dental benefit program administered by Delta.
a. Delta shall implement administrative, physical, and technical safeguards that
reasonably and. appropriately protect ·the confidentiality, ·integrity, and
availability of the ePHI that it creates, receives, maintains, or transmits on behalf
of the Group Health Plan.
b. Delta shall ensure that any agent, including a subcontractor, to whom Delta
provides ePHI agrees to implement reasonable and appropriate safeguards to
protect ePHI.
c. As soon as practical after discovery, Delta shall report to the Group Health Plan
any Security Incident of which Delta becomes aware.
d. Delta agrees to authorize termination of this Business Associate Appendix and
the Contract as described in Section 2.11, above, by the Sponsor/Contractholder
if the Sponsor/Contractholderhas knowledge that Delta has violated a material
term of this Business Associate Appendix.
SECTION 3 -DISCLOSURE TO PLAN CONTRACTHOLDER
This Section 3 applies if the Contractholder will receive non~enrollment PHI and if this Contract
is the group health plan document that must be amended to permit disclosure of non-
enrollment PHI to the Contractholder.
3.1 Amendment of the Contract. Delta and Contractholder agree to amend this Contract as
set forth in this section to allow the Group Health Plan and/or Delta to disclose non-
enrollment PHI to the Contractholder.
5
c. Agents and Subcontractors. Contractholder shall ensure that any agent or
subcontractor that will have access to PHI from Contractholder agrees to be
bound by the same restrictions, terms and conditions that apply to
Sponsor/Contractholder pursuant to this Business Associate Appendix.
d. Employment-Related Actions and Decisions. The Contractholder shall not use or
disclose PHI for employment-related actions or decisions or in connection with
any other benefit plan of the Sponsor/Contractholder.
e. Reporting of Disclosures of PHI. Contractholder shall, as soon as possible after
becoming aware of an actual or suspected disclosure of PHI in violation of this
Business Associate Appendix by Sponsor/Contractholder, its officers, directors,
employees, subcontractors or agents or by a third party to which
Sponsor/Contractholder disclosed PHI pursuant to this Business Associate
Appendix, report any such disclosure to the Group Health Plan.
f. Access to and Availability of PHI. Contractholder shall timely and in compliance
with HIPAA requirements:
i. Make available to the Group Health Plan or Delta, as appropriate, the
requested PHI to respond to an individual's request for access to PHI.
ii. Provide to the Group Health Plan or Delta, as appropriate, the requested
PHI to respond to a request for amendment and shall incorporate any
amendment received from the Group Health Plan or Delta.
iii. Make available to the Group Health Plan or Delta, as appropriate, the
requested PHI to respond to an individual's request for an accounting of
disclosures of PHI. The Sponsor/Contractholder agrees to track all
disclosures of PHI that would be required to respond to a request for
accounting of disclosures of PHI as required by HIPAA.
g. Availability of Contractholder's Internal Practices, Books and Records.
Contractholder agrees to make its internal practices, books and records relating
to the use and disclosure of PHI received from the Group Health Plan or Delta
available to the Secretary of Health and Human Services for purposes of
determining the Group Health Plan's and Contractholder's compliance with the
HIPAA privacy standards.
h. Return or Destruction of PHI. Contractholder shall return or destroy all PHI
received from the Group Health Plan or its agent that the Contractholder
maintains in any form and shall retain no copies when such PHI is no longer
needed for the purpose for which the disclosure was made. If return or
destruction is not feasible, Contractholder shall continue to protect the
confidentiality of PHI as required by this Business Associate Appendix and limit
any use or disclosure of PHI to those purposes that make the return or
destruction of PHI infeasible.
7
SECTION 5 -GENERAL
5.1 Amendment to Business Associate Appendix. Contractholder and Delta agree to amend
this Business Associate Appendix as necessary to comply with federal or state laws or
regulations relating to the administrative simplification provisions of HIPAA.
5.2 Indemnification by Delta. Delta agrees to indemnify, defend and hold harmless the
Group Health Plan, or the Contractholder on the Group Health Pian's behalf, and their
employees, directors, officers, subcontractors, agents or other members of its
workforce~ each of the foregoing hereinafter referred to as "Indemnified Party," against
all actual and direct losses suffered by the Indemnified Party and all liability to third
parties arising from or in connection with Delta's breach of sections 2 or 3 of this
Business Associate Appendix. Accordingly, on demand, Delta shall reimburse any
Indemnified Party for any and all actual and direct losses, liabilities, fines, penalties,
costs or expenses (including reasonable attorneys' fees) which may for any reason be
imposed upon any Indemnified Party by reason of any suit, claim, action, proceeding or
demand by any third party which results from Delta's breach hereunder. Delta's
obligation to indemnify any Indemnified Party shall survive the expiration or termination
of this Business Associate Appendix for any reason.
5.3 Indemnification by Group Health Plan or Sponsor/Contractholder. The Group Health
Plan, or the Contractholder on the Group Health Plan's behalf, agrees to indemnify,
defend and hold harmless Delta and its employees, directors, officers, subcontractors,
agents or other members of its workforce, each of the foregoing hereinafter referred to
as "Indemnified Party," against all actual and direct losses suffered by the Indemnified
Party and all liability to third parties arising from or in connection with the Group Health
Pian's or Sponsor/Contractholder's breach of Sections 2, 3 or 4 of this Business
Associate Appendix. Accordingly, on demand, the Group Health Plan or
Sponsor/Contractholder shall reimburse any Indemnified Party for any and all actual
and direct losses, liabilities, fines, penalties, costs or expenses (including reasonable
attorneys' fees) which may for any reason be imposed upon any Indemnified Party by
reason of any suit, claim, action, proceeding or demand by any third party which results
from the Group Health Plan's or Contractholder's breach hereunder. The obligation to
indemnify any Indemnified Party Shall survive. the expiration or termination of this
Business Associate Appendix for any reason.
5.4 Interpretation. This Business Associate Appendix shall be interpreted to allow the
parties to comply with HIPAA, provided, however, that nothing herein shall be construed
to grant rights beyond those provided under HIPAA or applicable law.
5.5 No Third Party Beneficiary. Nothing express or implied in this Business Associate
Appendix is intended to confer, nor shall anything in this Business Associate Appendix
confer, upon any person other than the parties to this Business Associate Appendix and
their respective successors and aSSigns, any rights, remedies, obligations or liabilities
whatsoever.
9
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