Privacy

Notice Regarding Wellness Program

The Nuvance Health Wellness Program Vitive Health™ is a voluntary wellness program available to all full time, part time and per diem employees of either Western Connecticut Health Network or Health Quest who are not governed by a collective bargaining agreement. 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 program you will be asked to complete a voluntary health assessment or “assessment” 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 will also be asked to complete a biometric screening, which will include a blood test consisting of a 38 panel blood screening, a comprehensive metabolic panel (CMP), a complete blood count (CBC), a full lipid profile and an A1c test. It will also include taking your blood pressure (BP), waist and body mass index (BMI). The assessment and biometric screening are both administered by Sterling Wellness, Nuvance Health’s program vendor. You are not required to complete the assessment or to participate in the blood test or other medical examinations.

However, employees who choose to participate in the wellness program and who are enrolled in the Nuvance Health plan in 2021 will receive a $400 incentive credit towards your annual health plan premium for completing a Health Assessment (questionnaire) and Health Screening (biometric screening) by October 22, 2022. Although you are not required to complete the assessment or participate in the biometric screening, only those who do so will receive the $400 credit toward their 2021 health plan premium (unless they are hired on or after September 1, 2020). Additional incentives of up to $200 may be available for employees who participate in certain health-related activities sponsored by Nuvance Health (e.g. events, seminars, fitness activities, eCourses and challenges).

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. If you require a Reasonable Accommodation due to a qualifying disability as defined by the Americans with Disabilities Act “ADA” as amended, “ADA AA” and the Rehabilitation Act of 1973, as amended “Rehabilitation Act,” please contact Sterling Wellness at 1.800.838.0337 for options available to you. They will work with you to find a wellness program with the same reward that is right for you in light of your health status.

The information from your assessment 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, and may also be used to offer you services through the wellness program, such as a personalized results report, immediate intervention outreach, condition management coaching, opt-in health coaching and an interactive web portal including online challenges and eCourses. You also are 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 Sterling Wellness and The Nuvance Health Wellness Program Vitive Health™ may use aggregate information it collects to design a program based on identified health risks in the workplace, Sterling Wellness will never disclose any of your personal information either publicly or to your employer, 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 is the health management team at Sterling Wellness, including its RNs, MDs, health coaches, and Reasonable Alternative Standard Administrators in order to provide you with services under the Program. Any other disclosure of your personal health information must be authorized by you in writing.

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.

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 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 Nuvance Health Benefits Hotline at benefits@nuvancehealth.org or (203) 739-8181.