UNC Wellness Notice

Well provides a voluntary wellness program available to all employees of the University of North Carolina Health Care System (“UNC HCS”) who are eligible for, or are enrolled in, the Network Health Plan. 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, as delivered via the Well applications (the “Well Apps.”) you may elect to participate in various actions that award you rewards points or other incentives. You may also 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. Additionally, you may be asked questions about the last time you visited your primary care provider.

 

You are not required to participate in or complete particular actions or interactions within the applications, including the HRA .  However, employees who choose to participate in the wellness program will receive a a reduction in their medical plan premiums if they earn the requisite number of points in the Well platform and confirm (through claims history or attestation) that they have completed a visit with their primary care provider during a certain period of time, as specified by Well based on authorization from UNC HCS. Although you are not required to complete any such actions, only employees who do so will receive a premium reduction.

Other incentives including the receipt of additional rewards points may be available for employees who engage with the Well applications. If you are unable to participate in any health-related activities or achieve any of the health outcomes that may be required 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 Cheryl Villani at Cheryl.villani@unchealth.unc.edu.

The information you elect to provide to Well directly through your engagement with their applications or through your medical and pharmacy claims history 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 support for goal setting associated with health and wellness initiatives, engagement with relevant content and resources, and/or guided coaching. 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 the wellness program and UNC HCS may use aggregate information it collects to design a program based on identified health risks in the workplace, Well will not disclose your personal information either publicly or to your employer, except in limited circumstances to enable the provision of services to you, 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 may access your personally identifiable health information are those persons at Well who require such access 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.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. Notwithstanding these precautions, you should be aware that regardless of the safeguards in place, there is always a risk that your data could be used or disclosed other than as intended.  If you are concerned about sharing your medical information through the wellness program, you can always undergo a screening directly with your physician, or you can forgo a screening entirely.  It’s important to balance the health benefits of regular healthcare screenings though against these privacy risks.    

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 Cheryl Villani at Cheryl.villani@unchealth.unc.edu.For more information about the way Well manages the data you agree to provide, please visit https://www.well.co/privacy.