Independence Blue Cross Website Privacy Policy and Independence Website Terms and Conditions of Access
This section provides the details of Independence Blue Cross’s (”Independence’s“) Website Privacy Policy and Independence’s Website Terms and Conditions of Access and Use. Please read this Website Privacy Policy ("Privacy Policy") in its entirety to understand how Independence will handle the privacy of personal information that you provide through the Website or through the use of the online Independence Web portals. Independence may use and disclose the information that you provide through this Website or through the Web portals or certain data regarding claims paid on your behalf ("Claims Data") only for purposes permitted or required by law, for purposes described in this Website Privacy Policy, or for purposes which you might authorize. You may change website access rights and permissions available through the Independence web portal as described later in this Website Privacy Policy. Independence also has developed Terms and Conditions of Access and Use describing your responsibilities when using this Website and/or the Independence Web portals. Please read the Website Privacy Policy and the Terms and Conditions of Access and Use carefully. You will be asked to accept the Website Privacy Policy and the Terms and Conditions of Access and Use before using this Website. Independence may change this Privacy Policy and the Conditions of Access and Use from time to time to address new functionality or changes to this Website or to the Independence Web portals, or to address new issues that require changes to this Privacy Policy. Accordingly, please refer back to the Privacy Policy and the Conditions of Access and Use posted at this Website periodically for such changes.
Independence Website and Independence Web Portal Privacy Policy
Welcome to the Independence Blue Cross ("Independence") Website. Our publicly-accessible Websites and the Web Portals accessible therein are designed to make it easier for users to manage their health information and learn about the services, programs and products provided by Independence, its affiliates and subsidiaries. If you are currently an individual who has Independence coverage ("Member"), or a provider, broker, or group that does business with Independence, you also may choose to register for one of Independence's Web portals. A web "portal" is a website that allows two-way interaction where Independence can collect information from the user or provide information to the user. After registering for access to the Member Portal website for example, this website allows you access to information about your benefits and programs/services that are available to you as a member of Independence. Other information available to you can include two years of claims information, health & wellness programs, health content, access to your member ID cards, referral information, etc. As with all online resources, we appreciate that users accessing our websites are concerned about the privacy of personal information. This Privacy Policy discloses Independence's policy for collecting, using and disseminating information through its Websites and Web portals. Please note that this Privacy Policy is distinct from Independence's Notice of Privacy Practices ("the Independence Notice"), which is a special notice required by a federal privacy law known as "the HIPAA Privacy Rule." The Independence Notice describes how Independence uses "individually identifiable health information" collected by Independence - both online and offline - to provide services to you and to administer the various programs that Independence administers. You can request a copy of the Independence Notice of Privacy Practices by calling the Customer Service number on the back of your identification card or going to https://www.ibx.com/privacy-policy/hipaa-privacy to view an online version of the Notice. Together, this Privacy Policy and the Independence Notice describe how Independence uses your individually identifiable health information and personal information collected through this Website. Information you provide to Independence in an offline setting is covered by the Independence Notice, but is not covered by this Privacy Policy unless otherwise specified in this Policy.
1. The Independence Personal Health Record web portal
Your personal health record ("PHR") is your online resource where you can manage and monitor your health information. This information is provided to you within your member website account where the information is private and in a secure location. The information in your PHR is confidential for you to access unless you are under the age of 18 at which time the policy holder (Subscriber) on the contract has access to the PHR of dependents under the age of 18. Independence does not review the contents of your PHR, except as may be necessary to provide online access (for example, we may incidentally review your data while fixing a technical issue) or as required by law. Your PHR information is updated automatically for you and a version of your PHR can be printed and shared with your health care providers if you choose to do so.
The PHR content and management
Independence uses personally identifiable information contained in medical and pharmacy claims and certain lab tests and results submitted to Independence from doctors, hospitals, labs, pharmacies and other providers (collectively, "Claims Data") to create your PHR that will be available to you. Independence will add this Claims Data to your PHR periodically. You also may add information, such as notes, comments, and prior medical history, into your PHR at any time. The content of the PHR does not include claims data relating to what we refer to as "sensitive health conditions." "Sensitive health condition" Claims Data is claims information concerning conditions such as mental or behavioral health, HIV/AIDS, sexually transmitted diseases, substance abuse, or genetic testing.
Contents within: (i) the PHR are not a complete medical record and do not include all services, tests, products or medical advice that you may have received, or constitute the official medical record of such services, tests, products or medical advice; (ii) the PHR is not intended to be medical advice or instructional for medical diagnosis or treatment or to suggest or recommend a course of treatment; and (iii) any lab test results received by Independence from labs and loaded into the PHR are unofficial records of test results. The Independence Claims Data is provided to you for informational purposes only.
The PHR furnished on the Independence website is not intended to replace personal consultation with a qualified health care professional. Once you accept the Independence Website Terms and Conditions, Claims Data submitted to Independence will automatically be loaded into your PHR. Claims Data will be uploaded into your website account once the information has been processed by Independence.
Although the online version of the PHR you can access will remain unchanged, you have the option to show or hide specific information when you print out your PHR to share with your family and/or health care provider. The most useful PHR is the one that is the most complete and user-friendly, so that it can help you keep track of your health care services you may have received and get services that are necessary. In the event that you are no longer an Independence Member, you may access your Independence PHR for a period of six (6) months after your coverage termination date. Independence will not have access to claims information provided by hospitals, physicians, labs and other providers when you are no longer an Independence Member. The claims information you will have access to once your coverage is terminated with Independence will be only those claims incurred during your effective dates of coverage with Independence.
Access rights
Upon registration to the website, a Personal Health Record will begin to display within your website experience. If you are the Subscriber on the account, you will have access to view a PHR for any dependents on the contract under the age of 18. The PHR is a value-added service offered to our members. You have the option to remove the PHR from displaying within your member portal website experience. If you would like to remove the PHR from displaying, you can go to the Account Settings page which is located as a link on the top navigation. There is a header titled Preferences and a section titled Personal Health Record. Here you can select No, do not display my Personal Health Record, then select the Save button. The next time you log into your account, the Personal Health Record will be removed from display. The removal of this functionality is in regards to your website experience only. Please note, if you are the Subscriber on the contract, you may remove the PHR from displaying on your account to access for all dependents on the contract that are under the age of 18.
2. Collection of personal information from site visitors to Independence’s Website
When you visit www.ibx.com (including the Independence Web portal) or when you visit one of our other websites, Independence may collect and/or track: (1) your home server domain names, your email address, your type of computer, the files downloaded, the search engine used, operating system, and type of web browser; (2) the email addresses of visitors who communicate with Independence via email; (3) information knowingly provided by the visitor in online forms, surveys, email, contest entries, and other online submissions (including demographic and personal profile data), and (4) aggregate information on pages accessed by a visitor. To better serve you, we use "cookies" to customize your browsing experience. Cookies are simple text files stored by your browser, and they provide a method of distinguishing among visitors to our sites. We use "cookies" to store a randomly generated tag on your computer so that when you revisit our sites, we may recognize the visitor by the Internet cookie and customize the visitor's experience accordingly. The cookies created on your computer by using our sites do not contain personally identifiable information. You may refuse a cookie, or delete the cookies file from your computer at any time by using any one of a number of widely available methods. However, you should be aware that if you disable the "cookies" feature of your browser, you may not be able to use the portals within our site. When a visitor performs a search on our Website, we may record information identifying the Visitor or linking the visitor to the search performed. Independence also may record limited information for every search request and use that information only to solve technical problems with the service and to calculate overall usage statistics.
3. Use of online personal data collected through Independence’s Website
When you access the Member Portal Website, you may choose to give Independence online personal information about you. "Online personal information" is any information or data you provide through this website that is individually identifiable, such as a name, address, postal address, email address, birth date, phone number, race, ethnicity, language, gender identity, sexual orientation information, and other personal information including health information that you voluntarily provide to Independence. It also may include other information that we collect about you that is associated with your name or address, such as your email address. You will be asked to provide your email address to us during the registration process. And if you email us, the email address used will be collected and saved.
Independence may use the online personal information for a number of different reasons, including editorial and feedback purposes, providing information about Independence benefit products or offerings and promotions, performing a statistical analysis of visitor usage, product development, content improvement, to protect our rights or property, or to customize the content and layout of our site. Aggregate data that does not identify individual users may be used for internal purposes or provided to third party vendors for program access capabilities. Personally identifiable information that visitors voluntarily provide to Independence, online or offline, may be added to our databases and used for future communications, which may include Website updates, new health care products and services, the confirmation of transactions through the portals, upcoming events, or health reminders, and for other purposes in accordance with applicable state and federal law. Online personal information may or may not be individually identifiable health information that is also protected by the federal HIPAA privacy law ("the HIPAA Privacy Rule"). Where online personal information also constitutes individually identifiable health information under the HIPAA Privacy Rule, the provisions of this Privacy Rule also will govern Independence's permitted uses and disclosures of the online personal information. Independence does not use race, ethnicity, language, gender identity and sexual orientation information for underwriting, rate setting, denial of services, coverage or benefits determinations.
4. Disclosure of online personal data collected through the Independence Website to third parties
Unless otherwise authorized by a visitor, Independence will not sell, rent, license, or disclose personally identifiable information collected through the Independence Website to unaffiliated third parties. Under the HIPAA Privacy Rule, however, Independence is permitted to disclose individually identifiable health information to business associates who perform various functions or provide services on their behalf. To perform these functions or to provide services, business associates will receive, create, maintain, use, or disclose individually identifiable health information that has been provided to or made available to the business associate by Independence, but only after the business associates agrees to sign a business associate agreement designed to safeguard your information. Independence has contracted with certain third-party vendors to serve as its business associate to provide services in connection with Independence's Web portals. Except as set forth above, Independence will not release personally identifiable information to any party unless required to do so by government authorities or legal process in accordance with applicable law, in order to protect our rights or property, or in conjunction with an acquisition of all or part of our company. Laws that permit disclosure of your personally identifiable information as part of healthcare operations might include activities such as Wellness Programs.
5. Health Information Exchanges
We share your health information electronically through certain Health Information Exchanges ("HIEs"). An HIE is a secure electronic data sharing network. In accordance with applicable federal and state privacy and security requirements, regional health care providers participate in HIEs to exchange patient information in real-time to help facilitate delivery of health care, avoid duplication of services, and more efficiently coordinate care. As a participant in HIEs, Independence shares your health information we may have received when a claim has been submitted for services you have received among authorized participating providers, such as physicians, hospitals, and health systems for the purpose of treatment, payment and health care operations as permitted by law.
During an emergency, patients and their families may forget critical portions of their medical history which may be very important to the treating physician who is trying to make a quick, accurate diagnosis in order to treat the sick patient. Independence through its participation in an HIE makes pertinent medical history, including diagnoses, studies, lab results, medications and the treating physicians we may receive on a claim available to participating emergency room physicians while the patient is receiving care. This is invaluable to the physician, expediting the diagnosis and proper treatment of the patient. Your providers who participate with an HIE, and also submit health information with the HIE, will have the ability to access your health information through the HIE and send records to your treating physicians. Through direct requests to the HIE, we will receive various types of protected health information such as pharmacy or laboratory services, or information when you have been discharged from a hospital which may be used to coordinate your care, provide case management services, or otherwise reduce duplicative services and improve the overall quality of care to our members. All providers that participate in HIEs agree to comply with certain privacy and security standards relating to their use and disclosure of the health information available through the HIE.
As an Independence member, you have the right to opt-out which means your health information will not be accessible through the HIE. Through the regional HIE (Patient Opt-Out Form) or the State HIE (https://www.dhs.pa.gov/contact/DHS-Offices/Pages/eHealth-HIE%20for%20Citizens.aspx) consumers or providers can access an online, fax, or mail form permitting patients to remove themselves (opt out) or reinstate themselves (opt back in) to the exchange It will take approximately one business day to process an opt-out request. If you choose to opt-out of the HIE, your health care providers will not be able to access your information through the HIE. Even if you opt-out, this will not prevent your health information from being made available and released through other means (i.e. fax, secure email) to authorized individuals, such as network providers for paying claims, coordinating care, or administering your health benefits in accordance with the law and in the normal course of conducting our business. For more information on HIEs, please go to http://www.dhs.pa.gov.
6. Wellness programs and health support programs
Wellness and health support programs are intended to help Members to improve their overall health. The health and wellness programs offered via the Member Portal website are subject to change as we work to enhance and improve certain programs/tools. They are not intended to replace professional medical advice. Information on member participation in these programs may be used by Independence for aggregate reporting and outreach purposes. When appropriate, Independence may share protected health information (or "PHI") with third-party vendors with which Independence has a contract to administer benefits or provide health support services as Independence's business associate. Such vendors are required to sign a business associate agreement with Independence to maintain the privacy of protected health information as required by law. Independence also may share information with treating providers to improve the health care of members. Providers also must follow all legal confidentiality requirements for PHI. In addition, when appropriate, we may confirm your enrollment in these programs or in certain preventive health activities, but not your individual responses or final results, with your employer or health and welfare fund ("fund"), for the purpose of an incentive program or corporate wellness planning. For example, we may inform your employer or fund that you completed a "Health Risk Assessment or Wellness Profile" but will not disclose your answers or the status of your health. We may inform your employer or fund that you attended 10 sessions of a weight management program for example, but not disclose whether you lost any weight. Your individual responses also will not be shared with your employer or fund or their broker/consultant.
7. Links from Independence Blue Cross Websites to other websites
Independence Websites occasionally include links to other organizations’ websites for your convenience in locating health-related information, services, and products. Please be advised that when you link to these other sites, you are leaving Independence's Website and that these other sites are maintained by organizations over which Independence may have no control. Accordingly, a link on any of these sites does not constitute endorsement of the content, viewpoint, policies, products, or services provided or advertised on that site by Independence. These other third party sites may have their own terms and conditions and privacy policies or no policy at all. Once you link to a website not maintained by Independence, you are subject to any terms and conditions of that site, including, but not limited to any privacy policy. The Independence Privacy Policy and the Terms and Conditions of Access and Use do not apply to the sites of such other third parties. Independence does not guarantee that you will receive an alert that you are leaving an Independence Website and linking to other third-party websites. It is your responsibility to determine when you have left an Independence Website. Certain products, services or treatments referred to on other sites that have a link on our site, may not be covered under certain plans offered by Independence. Members should refer to their benefits contract for complete details of the terms, limitations, and exclusions of coverage. In addition, certain providers may not be network providers. Please refer to our provider directory or call Customer Service by phone at 800-ASK-BLUE (800-275-2583) to make certain the professional listed is a network provider. Certain health information and tools accessible to registered members on the Member portal website may be provided in combination with third party vendors from which Independence licenses or purchases services. These third party sites may have an additional Privacy Policy that governs the collection, use and disclosure of any PHI provided through its website. The third party websites are maintained by organizations over which Independence exercises no control, and accordingly, Independence disclaims any responsibility for the content, the accuracy of information, and/or quality of products or services provided by or advertised in these third-party sites. URLs are presented for informational purposes only. Certain services/treatments referred to in third-party sites may not be covered by all benefits plans. Members should refer to their benefits contract for complete details of the terms, limitations, and exclusions of their coverage.
8. Security measures
Independence has implemented numerous security features to prevent the unauthorized release of or access to personal information. The Independence web portals use 256-bit High Grade Advanced Encryption to help keep information secure. However, despite these and other security measures implemented by Independence, no security process is completely foolproof. We will continually assess our security procedures and modify them to protect your information and we ask that our visitors take the appropriate measures to protect their information. If you register for one of our Web Portals, you will have the opportunity to receive or create a password to access view or submit personal information. Visitors who register to use a Web Portal should not divulge their password to anyone, and Independence will never ask for your password in an unsolicited phone call or email. When you are finished with applications that are password-protected, you should exit the application by selecting the "Log out" button. You should be aware that the confidentiality of any communication or material transmitted to/from Independence via this site or email cannot be guaranteed. Independence is not responsible for the security of information transmitted via the Internet.
9. Access to and ability to correct online personal data
Upon request via regular mail or email, Independence provides visitors a summary of any personally identifiable information retained by Independence regarding the visitor. You will also be able to see personal information retained by Independence through the Member Portal Website. Members may seek to modify, correct, change, or update information that Independence has collected. Having any updates/changes made can be done so by contacting us via regular mail or email or by calling customer service. Some members may also be able to update certain information via the Member portal website. Although you may provide individually identifiable health information on this Website, the information is not a medical record, and is not, under the HIPAA Privacy Rule, considered information we maintain in a designated record set. Such information, however, will be treated as PHI, as discussed in this Privacy Policy and in Independence's Notice.
10. Collection of online personal data from children
Subscribers are able to view their dependent(s) account information for those child dependents on their contract that are under the age of 18. Access regarding the health of their children occurs immediately after a Subscriber registers for an account. No longer permitted to register on this Website is any person that is under the age of 18. This includes a dependent on a contract that is under the age of 18 as well as a person (child) under the age of 18 allowed to register in order to have access to their own account. Independence does not direct children under the age of 18 years to access this Website or knowingly collect personal contact information from children under 18. Adults should not assist minors in accessing this Website. When a user enters their personal demographic information on our Website during our registration process, the user is confirming that he or she is of the age of 18 years and older. To the extent that Independence is able to determine the age of users by their submissions to or communications with Independence's Website, Independence will not knowingly (1) collect or post information from individuals under age 18 without their parent’s or guardian’s consent, or (2) provide any personally identifying information collected from children, regardless of its source, to any third party for any purpose whatever unless otherwise permitted by law. No information collected through Independence’s Website from users who identify themselves as children will knowingly be used for any direct marketing or promotional purposes. If there are no age restrictions on a contest that requires registration, and if a child wins, notification and prizes will be sent to the parents or guardians identified in the initial registration process.
11. Independence Blue Cross’s right to contact visitor
Independence reserves the right to contact Website visitors regarding account status and changes to the Member handbook, the Privacy Policy, or any other policies or agreements relevant to those who visit the Website.
12. Independence Blue Cross’s right to change Privacy Policy
Independence reserves the right to change this Website Privacy Policy at any time. Consequently, you should refer back to this Privacy Policy regularly as it might be changed from time to time. When updates have been made, existing registered members will be asked to accept the revised terms and conditions in order to access their Member portal website account. If the member does not re-accept the revised terms and conditions, the member will not be allowed to access the website until they do re-accept.
13. Access to member website information
Plan representatives may access your Independence Blue Cross member website and other relevant account information to provide customer service requested by you in situations where the provision of customer service would require the Plan representatives to access your Independence Blue Cross member website and other relevant account information for quality control purposes related specifically to confirming that accounts were setup correctly and that your member information is displaying correctly.
TERMS AND CONDITIONS OF ACCESS AND USE
Independence Blue Cross ("Independence") provides you with access to its Website and Member Portal (collectively, the "Portal"), subject to the following Terms and Conditions of Access and Use ("Terms and Conditions"). We may update these Terms and Conditions at any time and without notice. Unless stated otherwise, changes will be effective when they are posted on our website at www.ibxpress.com. The Terms and Conditions are in addition to those policies and procedures that are posted on our website at www.ibxpress.com under the Legal Information section and under our Website Privacy Policy, which are incorporated herein by reference. By logging on to the Portal, activating your password and creating user identification, you agree to be bound by these Terms and Conditions as well as the policies and procedures posted on our Website under the Legal Information section, under our Website Privacy Policy and our HIPAA Notice of Privacy Practices. If you do not wish to be bound by these Terms and Conditions, policies and procedures posted on our Website under the Legal Information section, Independence's Website Privacy Policy and Independence's HIPAA Notice of Privacy Practices, you should disconnect from this Website immediately.
1. The content of the portal is not intended in any way to be a substitute for professional medical advice. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition. Neither the content nor any other service offered by or through the portal is intended to be relied on for medical diagnosis or treatment. Never disregard medical advice or delay in seeking it because of something you have read on the portal! In an emergency, call 911 or call your local emergency assistance number.
2. Independence reserves the right to terminate access to the Portal at any time and for any reason. Your access will be terminated after 6 months when your benefits are no longer provided by Independence and its subsidiaries or affiliates. Independence reserves the right at any time to modify or discontinue, temporarily or permanently, the Portal (or any part thereof) with or without notice. You agree that Independence will not be liable to you or to any third party for any modification, suspension or discontinuance of the Portal.
3. Independence has created certain security procedures, including the use of passwords and user identification numbers, to assist in keeping your information confidential. You agree to provide us with accurate, current and complete information about yourself as requested and to maintain and promptly update your information to keep it accurate, current and complete.
4. You are responsible for maintaining the confidentiality of the password and are responsible for all activities that occur under your password. You agree to immediately notify Independence of any unauthorized use of your password or other breach of security, and to exit from your account at the end of each session by selecting the Log out button. Independence cannot and will not be liable for any losses and/or damages arising from your failure to comply with these provisions. Except where expressly authorized by law, you certify that you are not using another person's password or user identification to access the Portal. You agree not to falsely state or otherwise misrepresent your affiliation with a person or entity to obtain access to a Portal. You also agree not to copy or disseminate, electronically or otherwise, personal or confidential information found on the Portal.
5. You agree that Independence, in its sole discretion, may terminate your password, user identification (or any part thereof) or use of the Portal for any reason, including, for lack of use or if Independence believes that you have violated the Terms and Conditions. You agree that Independence will not be liable to you or any third party for any termination of your access to the Portal.
6. The information provided on the Portal is provided as an accommodation and it is not intended to serve as formal notice or publication as may be required under law or by contract. While Independence uses its best efforts to maintain the accuracy and reliability of information available through the Portal, we cannot guarantee the accuracy for all the member benefit and claims information or that all claims will be displaying. Up to two years of claims history is provided to members. You understand and agree that Independence, except as expressly required by law, assumes no responsibility for the timeliness, deletion or failure to provide any information on the Portal.
7. Independence has agreements with various entities, which we call our "business associates," to provide services in connection with the Portal. Our relationships with business associates are subject to terms of business associate agreements and are based on the type of service they are to provide.
8. Your use of the portal is at your sole risk. The portal is provided on an "as is" and "as available" basis. Independence expressly disclaims all warranties of any kind, whether express or implied, including, but not limited to the implied warranties of merchantability, fitness for a particular purpose and non-infringement. You expressly understand and agree that Independence will not be liable for any direct, indirect, incidental, special, consequential or exemplary damages for any reason resulting from the use of the portal.
9. You agree to release and hold Independence and its subsidiaries and affiliates, and their directors, officers, agents, principals or other partners, and employees, harmless from any claims, demands, damages, losses, liabilities, costs and expenses, including reasonable attorneys' fees, made by any third party due to or arising out of your use of the Portal, your violation of these Terms and Conditions, your communication of inaccurate or incomplete information, and/or your violation of law.
10. Independence will not release and/or disclose personally identifiable information to any party, including our third party vendors, unless required to do so by government or legal authorities or unless such release and/or disclosure is in accordance with applicable law and Independence's Privacy Policy. You understand and agree that the party receiving personally identifiable information may use the personally identifiable information in accordance with applicable law.
11. You understand that you may access the websites of third parties through the Portal. You understand and agree that the websites of third parties will have their own policies and procedures (including a privacy policy) to which you will be subject. These websites are maintained by the third parties that Independence does not control. Independence recommends that you read the policies and procedures (including the privacy policy) of the websites of third parties that you access. These are available on the third party websites as well as accessible to you wherever there is access to our terms and conditions. A separate tab is provided that is separate from the Independence terms and conditions for third party privacy policies that we have access to.
12. In some instances, you will be notified when you leave Independence's Portal and access the websites of third parties. However, Independence does not guarantee that you will receive such a notice before accessing any third party websites. You understand and agree that it is your responsibility to determine when you have accessed the websites of third parties and to be aware when the policies and procedures (including the privacy policy) of third parties are applicable.
13. The Portal may include or provide links to other websites on the Internet including, but not limited to, links to our business associates' web pages. These other websites may provide opinions, recommendations, or other information from various individuals, organizations or companies. In providing links to the websites of third parties, Independence does not investigate the content of such information and does not endorse, guarantee or warrant the accuracy of such information or necessarily subscribe to any such opinions or recommendations. To the extent that you make use of any link to any other website on the internet, you understand and agree your use of the websites of third parties is at your sole risk. The websites of third parties are provided on an "as is" and "as available" basis. You expressly understand and agree that Independence will not be liable for any direct, indirect, incidental, special, consequential or exemplary damages for any reason resulting from your use of the websites of third parties.
14. You understand that Pennsylvania law requires that any person knowingly and with intent to defraud any insurance company or other person files an application for insurance or statement of claim containing any false information or conceals for the purposes of misleading, information concerning any material fact thereto commits a fraudulent insurance act, which is a crime and subjects such person to criminal and civil penalties.
Y0041_HM_118307_C_2024 Website last updated 4/16/2024
Independence Blue Cross offers products through its subsidiaries Independence Assurance Company, Independence Hospital Indemnity Plan, Keystone Health Plan East, and QCC Insurance — independent licensees of Blue Cross and Blue Shield Association.