NOTICE REGARDING THE VANDERBILT UNIVERSITY WELLNESS PROGRAM
The Vanderbilt University Medical Center Health Plus is a voluntary wellness program available to Vanderbilt University employees and employees' spouses. 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 and your spouse/partner choose to participate in the wellness program you will 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 will also have the opportunity to complete a biometric screening, which will include height, weight, body mass index, blood pressure, and/or body composition. Non-fasting blood glucose and cholesterol are offered periodically. You and your spouse 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 and who are paying for Vanderbilt University Health Plan benefits can earn a Wellness Credit incentive of up to $240 for the corresponding year of insurance coverage by completing the Go for the Gold program, which includes actions in addition to completing the HRA and biometric screening. Any Wellness Credits earned will be applied to your Health Plan Account pre-tax and can be used to offset deductible and co-insurance costs. Although you are not required to complete the HRA or participate in the biometric screening, only employees who do so and who are enrolled in Vanderbilt University Health Plan coverage will receive any Wellness Credits for the corresponding year of insurance coverage. Employees who are not enrolled in health plan coverage are encouraged to participate in Go for the Gold to help maintain or maximize their health and well-being, but are not eligible for the Wellness Credit.
If you are unable to participate in the Go for the Gold activities required to earn a Wellness Credit 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 the Health Plus office at PMB# 407804, 2700 Children's Way, Nashville, TN 37235; phone: 615-343-8943.
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, and may also be used to offer you services through the wellness program, such as wellness coaching, lifestyle, and educational programs. You also are encouraged to share your results or concerns with your own primary care provider.
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 and Vanderbilt University may use aggregate information collected to design programs based on identified health risks in the workplace, Health Plus will never disclose any of your personal information either publicly or to the 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 individuals who will receive your personally identifiable health information are Health & Wellness database administrators, medical director, case manager, and health educators/wellness coaches in order to provide you with services under the wellness 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. For a full description of the Health Plus confidentiality protections, please refer to the Health Plus Confidentiality Policy available on the Health Plus website. 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 the Health Plus office at 615-343-8943.
Vanderbilt University Medical Center's Health Plus is committed to your privacy and understands that information about you and your health is personal and private. We are committed to protecting your personal health information.
Change in Policy:
Vanderbilt University's self-insured medical Health Plan will have access to the Health Risk Assessment information. This is a change from the previous policy that health information is not provided to any insurance provider. However, the sharing of the information is limited to the Vanderbilt medical insurance self- insured product, the Vanderbilt University's Health Plan. Neither Health Plus nor the Health Plan will provide information at the level of the individual to any other insurance company including life insurance companies, automobile insurance companies, any outside companies, or any Vanderbilt departments, managers, or supervisors. Other than this exception, neither Health Plus nor the Health Plan will disclose information except as required by law.
Use of Information by Health Plus:
Health Plus uses anonymous group data to plan and prioritize programs and services to meet the health needs of the Vanderbilt University's employee population, therefore helping to develop a culture of wellness. All analysis, including program and cost-effectiveness evaluation, will be done using aggregate data (your data combined with those of other participants which does not personally identify you or other individuals).
Health Plus will use the list of participants who have completed the yearly Health Risk Assessment to give eligible participants Vanderbilt wellness benefits such as the Go for the Gold Wellness Credit.
The primary purpose of the Health Risk Assessment and the Go for the Gold Program is to help individuals identify health risks and learn how to maintain or improve health. Health Plus will provide information on available resources and other benefits to those with health risks.
In addition, a list of participant names of Vanderbilt employees successfully completing Start! Physical Activity Program challenges will be used to distribute prizes.
Use of Information from the Go for the Gold Program by the Vanderbilt Health Plan:
Vanderbilt University is self-insured for medical insurance, referred to as "The Health Plan". The Health Plan will now have access to all Health Risk Assessment information beginning November 1, 2012. The Health Plan will only use the data in aggregate at the population level and not for personally identifying you or other individuals. All data that is evaluated by the Health Plan is done with strict adherence to HIPAA guidelines and to Federal laws. All personally-identifiable member information in the database is hidden from the Health Plan, and no individual, or groups of individuals, can be personally identified within the aggregate data at any time. The data will be used at an aggregate level for:
- Evaluating the need for, and planning of, Health Plan-sponsored programs, as dictated by the overall wellness of our member population
- Evaluating existing programs offered to the Health Plan members and their families for effectiveness
- Identifying the need for health plan improvement and development efforts based on overall member wellness and member utilization
- Understanding wellness changes among our member population in an effort to keep health coverage premiums as low as possible for the Plan members
Health Plus partners with Wellsource, Inc to provide the Health Assessment:
Wellsource, Inc. and Health Plus are committed to complying with the Standards for Privacy of Individually Identifiable Health Information under the Health Insurance Portability and Accountability Act (HIPAA) of 1996.
If you have questions or concerns about your privacy, please contact or call Health Plus at (615) 343-8943.