HUMANA HEALTHCARE SETTLEMENT

If you received a Notice of Privacy Incident regarding the data incident from Humana Inc. (“Humana”) on or around March 1, 2021, you may be eligible for a Class Action Settlement Payment.

A court authorized this notice. This is not a solicitation from a lawyer.

• A Settlement has been reached in a class action lawsuit about a data incident that occurred on between October 12, 2020 and December 16, 2020, which potentially exposed personally identifiable information (“PII”) and/or protected health information (“PHI”) of Humana members (the “Data Incident”).

• Cotiviti, Inc. (“Cotiviti”) helps Humana Inc. (“Humana”) request medical records needed to verify data reported to the Centers for Medicare and Medicaid Services. Cotiviti in turn uses a subcontractor (Visionary) to review the collected medical records. The circumstances giving rise to this case occurred between October 12, 2020 and December 16, 2020, and involved an employee of Visionary who gained access to personally identifiable information (“PII”) and protected health information (“PHI”) of Humana members and shared that information with others in connection with a personal coding business (the “Data Incident”). The exposed information may have included names, partial or full social security numbers, dates of birth, addresses (with city, state, and zip code), phone numbers, email addresses, member identification numbers, subscriber information numbers, dates of service, dates of death, provider names, medical record numbers, treatment information, and actual images (x-rays, photographs, etc.). Subsequently, a lawsuit was filed against Humana and Cotiviti, alleging that they did not take appropriate care to protect Humana members from the Data Incident.

• Humana and Cotiviti deny all of the Plaintiff’s claims in the lawsuit and maintain they did not do anything wrong but have agreed to settle the case to avoid the expense and burdens of litigation.

• The Settlement includes all Persons to whom Humana sent notification that their personal information and/or protected health information may have been or was exposed to unauthorized third parties as a result of the Data Incident.

• The Settlement provides payments to people who submit valid claims for out-of-pocket expenses and lost time that were incurred and plausibly arose as a result of the Data Incident, and for other extraordinary unreimbursed monetary losses and lost time.

• The Settlement also includes two years of credit monitoring and identity theft insurance through IDX. You must submit a claim to receive this benefit.

Your legal rights are affected even if you do nothing.
Read this Notice carefully.

YOUR LEGAL RIGHTS AND OPTIONS IN THIS SETTLEMENT
Submit a Claim	The only way to get a payment and/or credit monitoring. You must submit a claim by November 15, 2022.
Ask to be Excluded	Get no payment. The only option that allows you to sue Humana and Cotiviti over the claims resolved by this Settlement. You must exclude yourself by November 15, 2022. You must exclude yourself by November 15, 2022.
Object	Write to the Court about why you do not like the Settlement. You must object by November 15, 2022.
Do Nothing	Get no payment. Give up rights.

These rights and options – and the deadlines to exercise them – are explained in the Notice.

• The Court in charge of this case still has to decide whether to grant final approval of the Settlement. Payments will only be made after the Court grants final approval of the Settlement and after any appeals are resolved.