O-AT-KA Milk Products Cooperative, Inc.

It is the policy of the OATKA Milk Products Cooperative Inc. the “Plan” to protect and maintain the confidentiality of protected health information (“PHI”) by complying with the HIPAA Privacy Rules and all other applicable federal and state laws relating to the confidentiality of PHI It is also the policy of this Plan to respect the rights of Participants (which include the employee or former employee and any person, such as his or her dependents, who may be covered by the Plan) regarding their PHI which includes, but is not limited to, their right of access to their PHI.

Towards that end, the Plan will do the following:

Develop and implement specific privacy policies and procedures, collectively referred to as the “HIPAA Compliance Plan.”
Communicate to the Plan’s workforce regarding the HIPAA Privacy Rules, the HIPAA Compliance Plan requirements, and obligations of the workforce under the HIPAA Compliance Plan
Monitor and assess the effectiveness of the HIPAA Compliance Plan
Modify the HIPAA Compliance Plan as necessary to maintain and improve the effectiveness of the HIPAA Compliance Plan.
Establish and maintain communication channels so that members of the workforce and Participants are able to communicate effectively with the Plan regarding the effectiveness of the HIPAA Compliance Plan and their rights and obligations under the HIPAA Compliance Plan.
Discipline, when necessary, any member of the workforce that violates the HIPAA Compliance Plan.
Document the Plan’s discharge of its obligations under its HIPAA Compliance Plan.
Make certain that neither the Plan nor any other individual or entity retaliates in any way against any member of the workforce or any Participant who may choose to comply with or take the benefit of the HIPAA Compliance Plan.

Plan Administrators: Rosemary Olow
Privacy Officers: Judy Rogers/Lori Lukasik