Who Knows Your Secrets? Part 4: Someone’s Snooping in Your Medicine Cabinet!
Of course, insurance companies aren’t only interested in damage claims for your home and car. They also want to take your temperature, so to speak, as a prospective health insurance customer, so they track your health and medical claims history, including some things that might surprise you.
MIB–NOT THE “MEN IN BLACK” BUT JUST AS POWERFUL!
The Medical Information Bureau (MIB) is the biggest weigh station along your health-related paper trail. If these Men In Black namesakes seem vaguely familiar to you, it might be because we referenced them last year, when we talked about medical identity theft.
The MIB compiles and maintains records concerning individual health insurance, as well as disability, long-term care, and life insurance. Your MIB report includes all the information you would have reported when filling out an application to purchase insurance. It also includes whatever data the insurance company can obtain from your doctors, nurses, midwives, hospitals and other healthcare providers–anything that references any kind of medical condition that insurance companies would consider important or “significant”.
According to the Privacy Rights Clearinghouse, the MIB has over 230 numerical codes to indicate specific medical conditions, to which their computer algorithms assign a risk value.
Your MIB report might include information regarding blood pressure, diabetes, asthma, obesity or ongoing reproductive issues, obtained from your insurance company directly via your health care providers but there also may be behavioral data that your insurance company learned of obliquely (perhaps as a result of an emergency room visit). This means that they might collect information about you regarding anything from smoking to participation in extreme sports like bungee jumping or hang gliding.
Depending on the depth of collection and reportage, an MIB report might even contain data regarding a poor driving record or drug-related criminal activity not involving drug use. (Paper Doll can imagine how being a drug kingpin might put one at risk for all sorts of molten lead-related injuries). And from all of this collected data, your insurance risk is determined.
Not everyone has a current MIB file. In general, you will only have a file if you applied for health-related insurance (including disability, long-term care and life insurance) within the last seven years, and only if you applied as an individual; if you applied as a member of a group (i.e., you got a new job and signed up for insurance through work), it doesn’t show up in your MIB file. You also won’t be likely to have an MIB report if you haven’t had any kind of “significant” medical condition in the last seven years, where a “condition” could be an illness, injury, pregnancy, etc.
In theory, insurance company databases should be a good thing. As with the CLUE and A-PLUS reports, MIB’s database exists to help insurance companies detect and eliminate fraud on insurance applications; for example, if there’s a discrepancy between someone’s self-report of no history drug abuse and a previous notation about such things in a medical record, the MIB should catch it.
Again, in theory, keeping accurate information keeps corporate costs down by purging fraud and abuse out of the system, which should keep costs lower for us as consumers. In actuality, however, none of the agencies compiling and reporting on our various medical and behavioral paper trails are perfect. Inaccuracies in our reports, whether the result of unintentional keystroke errors or medical identity theft, mean that we not only might end up paying more (possibly more than we can afford) for health insurance premiums, it could make it hard to get insurance at all–current indeterminate health care reform legislative activities notwithstanding!
Thus, as with our credit, banking and other insurance reports, it’s essential to know if the MIB has a file on us, and if so, what’s in that medicine cabinet of records.
To get a copy of your MIB consumer file (if you have one), call 866-692-6901, toll-free. Canadian residents can request free MIB reports by calling 416-597-0590 (long distance charges apply) or by downloading a Request for Disclosure Form in English or French.
To learn more about requesting your file, visit the MIB web site.
PRESCRIPTION DATABASES–ASSUMING FACTS NOT IN EVIDENCE
The MIB aren’t the only ones who know what’s going on in your health history. IntelliScript and MedPoint maintain databases solely about patients’ prescription drug purchase histories, develop a pharmacy risk score, and report the data to insurance companies. The higher the score, the higher the potential cost for the insurance company to cover the patient. Officially, the pharmacy risk score isn’t personal; the companies say the scores represent an expected risk for any particular group (evaluating variables such as age, gender, and specific pharmaceutical-use histories). As with the MIB reports, the IntelliScript and MedPoint reports generally come into play when you try to purchase private health, disability, long-term care or life insurance.
What the reports don’t note (and which can only be learned directly from your healthcare practitioner’s notes), is WHY you were prescribed particular medicines at particular dosages, and that can present a problem. Physicians often prescribe medicines for off-label purposes or for alternative reasons: the anti-depressant Prozac can also ameliorate hot flashes in menopausal women, oral contraceptives can fight PMS and PMDD, beta blockers (normally prescribed for hypertension and cardiac care) reduce the incidences of chronic migraines, and so on. Insurance companies make inferences from your IntelliScript and MedPoint drug histories, assuming facts not in evidence.
So, you could be prescribed a medication to improve your quality of life that is more commonly used to combat more serious conditions. However, your report won’t tell prospective insurers that. With your drug prescription and refill history on display, a decision-maker at an insurance company (possibly even a computer, programmed to assign risk factors to prescription meds entered by code), may make flawed assumptions about your medical conditions to assess the risk of underwriting your insurance policy.
HIP, HIP, HIPAA CONCERNS
Flawed inferences regarding prescription purposes? Data entry errors and medical identity theft? What else makes these databases problematic? How about potential violation of HIPAA regulations? The companies claim that personal prescription data is only released with the consumer’s authorization, ostensibly in the form of a small print waiver in a health insurance application form.
However, since neither Milliman nor Ingenix (the parent companies of IntelliScript and MedPoint, respectively) are covered by HIPAA, the HIPAA regulations don’t give the Department of Health and Human Services the authority to directly investigate their activities or hold the companies responsible for what they do with the data they collect. As reported by The Washington Post and other media outlets, there is even fear among the consumer advocacy community that there’s at least potential for IntelliScript and MedPoint to repurpose the collected, aggregate data to help pharmaceutical companies market drugs.
YOUR ROLE AS CONSUMER
Never heard of IntelliScript or MedPoint’s prescription databases before now? Don’t feel bad–most people hadn’t until two years ago, when the Federal Trade Commission successfully sued Milliman and Ingenix, to force them to comply with the Fair Credit Reporting Act. The FTC prevailed in defining them as credit reporting agencies (CRAs) just like Equifax, Telecheck and the other agencies we’ve been discussing in this blog series, because they collect and evaluate consumer report information for the specific purpose of distributing it to third parties–in this case, health-related insurance companies.
So, based on your IntelliScript or MedPoint report, an insurer could increase your health, disability, long-term care or life insurance premiums, deny coverage for certain conditions, or deny coverage altogether. Yikes! But now, if you are denied coverage or charged increased premiums, the Fair Credit Reporting Act gives you a variety of consumer rights to gain access to your reports via your insurance company, and dispute inaccurate information or flawed inferences (if you can figure out, from your report, what inferences were drawn).
And, even if you haven’t experienced what the FCRA calls an adverse action (as we discussed last week), if you’ve applied for individual (not group) health-related insurance, you can request one free report annually, directly from both IntelliScript and MedPoint.
To request your free reports:
- Call IntelliScript at 877-211-4816.
- For information regarding alternate methods of contacting IntelliScript, check out the contact information on the web site.
- Call MedPoint at 888-206-0335 or
- Write to:
MedPoint Compliance
Ingenix, Inc.
2525 Lake Park Blvd
West Valley City, Utah 84120.
For either report, expect to provide detailed information, including your full name, date of birth, the last four digits of your Social Security number and your zip code. Your report will include a copy of any information they’ve collected about you, in addition to a list of the names of all the insurance companies that have requested your report.
Rather than waiting for an adverse action notice to trigger your FCRA rights, be proactive. If you’re thinking of applying for new health insurance, long-term care or disability coverage, or life insurance, plan ahead and order your MIB, IntelliScript and MedPoint reports. If nothing adverse comes up (or nothing at all, in the case of the MIB), great! But if you find flaws or errors, it’s much better to dispute them and have the reports corrected before you try to access urgently-needed coverage.
Third-party electronic collection and analysis of personal medical data is a growing field. Beyond the collection of health care provider notes and pharmaceutical records, companies are already in the process of testing methods for collecting data from commercial labs to add to the insurance industry’s arsenal of risk predictors.
As always, it’s essential for you to be your own best advocate and know who’s following your paper trail.
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