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Notice Regarding Union College’s Wellness Program

Union’s “Wellness Program” is a voluntary wellness program available to all employees. The program is administered according to federal rules, permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease, including the Americans with Disabilities Act of 1990, the Genetic Information Nondiscrimination Act of 2008, and the Health Insurance Portability and Accountability Act, as applicable, among others.  If you choose to participate in the wellness incentive part of the program, you will be asked to complete either a biometric screening or annual physical, which will include a blood test to determine the following measures: blood glucose (screening for prediabetes, diabetes), total cholesterol, LDL, HDL, Triglycerides and to certify your smoke/tobacco free status (or demonstrate participation in a smoking cessation program).   If you choose to participate in the “Life Points” part of the program you will need to complete a health risk assessment or "HRA" that asks a series of questions about your health-related activities and behaviors and also asks whether you have or have had certain medical conditions (e.g., cancer, diabetes, or heart disease).   Additional incentives of up to $365 per family may be available through the “Life Points” program for employees and their family members who participate in certain health-related activities (please refer to the www.CDPHP.com website for specific Life Points qualifying activities).  If you are unable to participate in any of the health-related activities to earn an incentive, you may be entitled to a reasonable accommodation or an alternative standard.  You may request a reasonable accommodation or an alternative standard by contacting Gwen Pulvirent, Associate Director of Human Resources, pulvireng@union.edu or x. 6304, Human Resources - 17 South Lane.

You are not required to participate in the Wellness Incentive program or the Life Points program.  As such, you are not required to complete the HRA or to participate in the blood test or other medical examinations or to certify your smoke/tobacco-free status.   However, only employees who choose to participate and complete the requirements of the wellness incentive part of the program will receive a 10% wellness incentive toward the cost of their medical insurance for the remainder of the plan year and only employees who complete the HRA and participate in the Life Points program will be entitled to up to $365 in annual Life Point awards. 

The information from your HRA and the results from your biometric screening will be used to provide you with information to help you understand your current health and potential risks. Upon completion of the HRA and/or biometric screening, CDPHP resources will be recommended to aid members in maintaining and improving their health based upon their individual responses.  The information may also be beneficial to you for participating in programs or utilizing services through the wellness program, such as BMI measures from biometric screenings may be used to reach members via outreach campaigns to raise member awareness of weight management resources available as a value added benefit through CDPHP, or for your voluntary participation in the various wellness classes, webinars or special programs.  You are also encouraged to share your results or concerns with your own doctor.

Protections from Disclosure of Medical Information

We are required by law to maintain the privacy and security of your personally identifiable health information. Although the wellness program (administered through the Capital District Physician’s Health Plan (CDPHP)) and Union College may use aggregate information it collects to design a program based on identified health risks in the workplace, CDPHP will never disclose any of your personal information either publicly or to Union College, except as necessary to respond to a request from you for a reasonable accommodation needed to participate in the wellness program, or as expressly permitted by law. Medical information that personally identifies you that is provided in connection with the wellness program will not be provided to your supervisors or managers and may never be used to make decisions regarding your employment.

Your health information will not be sold, exchanged, transferred, or otherwise disclosed except to the extent permitted by law to carry out specific activities related to the wellness program, and you will not be asked or required to waive the confidentiality of your health information as a condition of participating in the wellness program or receiving an incentive. Anyone who receives your information for purposes of providing you services as part of the wellness program will abide by the same confidentiality requirements.  The only individual(s) who will receive your personally identifiable health information, such as Individual results from the biometric screenings (BMI, Blood Pressure, LDL Cholesterol), is your indicated Primary Care Physician.  .

All medical information obtained through the wellness program will be maintained separate from your personnel records.  Information stored electronically will be encrypted, and no information you provide as part of the wellness program will be used in making any employment decision. Appropriate precautions will be taken to avoid any data breach, and in the event of a data breach involving information you provide in connection with the wellness program, we will notify you immediately.

You may not be discriminated against in employment because of the medical information you provide as part of participating in the wellness program, nor may you be subjected to discrimination or retaliation if you choose not to participate.

If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact Eric Noll, Chief HR Officer, nolle@union.edu or x. 6108 at Human Resources -17 South Lane.