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Wellness Program Notice

Wellness programs are 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 program, depending on the type of program, you may be asked to complete a voluntary health risk assessment or "HRA" that asks a series of questions about your health-related activities and behaviors and whether you have or had certain medical conditions (e.g., cancer, diabetes, or heart disease). You may also be asked to complete a biometric screening, which will include a blood test for diabetes, cholesterol levels and heart disease. You are not required to complete the HRA or to participate in the blood test or other medical examinations.

However, employees who choose to participate in the wellness program, depending on the type of program, may receive a product, gift card or cash equivalent (i.e., premium deduction, deductible buy-down) incentive for completing the actions stated above. Although you are not required to participate in any activities of the program, only employees who do so will receive the corresponding incentive.

Additional incentives, depending on the type of program, may be available for employees who participate in certain health-related activities (i.e., health and fitness challenges, digital coaching modules and seminars) or achieve certain health outcomes. If you are unable to participate in any of the health-related activities or achieve any of the health outcomes required to earn an incentive, you may be entitled to a reasonable accommodation or an alternative standard, though physician documentation of the need for such an accommodation or alternative standard are required. You may request a reasonable accommodation or an alternative standard by contacting the toll-free Healthspace Navigator Line at 1-888-236-8581.

The information from your HRA and the results from your biometric screening will be used to provide you with feedback to support you in understanding your health and to reduce potential risks. In some instances, this information may also be used to offer you services through the wellness program, such as disease management programs. You also are encouraged to share a copy of your results with your own doctor so that you can work together on a good plan for improving or maintaining your health.

Protections from Disclosure of Medical Information

We maintain the privacy and security of your personally identifiable health information as required by law. Although the HCIactive wellness program may provide aggregate information it collects to your health plan or employer, HCIactive will never disclose any of your personal information either publicly or to your employer without your consent or as expressly permitted by law. If your employer sponsors an ERISA health program, information shared is limited to what is needed for payment or operations of the health program. Medical or personal information that personally identifies you will not be provided to your supervisors or managers and can 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 benefit plan or 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 has passed training and abides by the same confidentiality requirements. The only individuals who will receive your personally identifiable health information are health coaches, Healthspace Navigators and data management professionals in order to administer your program.

In addition, 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 a data breach occurs involving information you provide in connection with the wellness program, we will notify you immediately.

If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact HCIactive at 1-888-236-8581.