Washington University values the importance of privacy in matters relating to your personal health. Wellness Connection partners with WebMD Health Services to offer you tools and resources that could help you improve your health and well-being. The purpose of this notice is to tell you how the information you provide through those tools and resources will be stored, managed and used.

Washington University Wellness Connection is a voluntary wellness program available to benefits-eligible individuals. 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 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 be asked to complete a biometric screening, which will include a blood test for measuring total cholesterol, HDL, Total Cholesterol/HDL ratio and blood glucose. 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 (Yay! Rewards Program) will receive an incentive of a $75 prepaid VISA card for completing the following wellness activities before December 31, 2018: 1) WebMD Health Assessment (HRA); 2) an on-site biometric/wellness screening conducted by Quest Diagnostic Services or the Quest Physician Results Form; 3) and at least two (2) WebMD Health Coaching sessions. Employees who complete these activities before June 30, 2018 will earn an additional $25 prepaid VISA card. Although you are not required to complete the HRA or participate in the biometric screening, only employees who do so will receive “Yay! Rewards”

If you are unable to participate in any of the health-related activities 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 Wellness Connection at wellnessconnection@wustl.edu or by calling 314-935-3654.

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 the WebMD Health Coach program and the Washington University weight management and smoking cessation programs. 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 Washington University Wellness Connection may use aggregate information it collects to design a program based on identified health risks in the workplace, Wellness Connection 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 individual(s) who will receive your personally identifiable health information is your WebMD Health Coach 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. All information you submit through the WashU WebMD Portal is stored by WebMD Health Services. Washington University and Wellness Connection will not have access to any individual personal health information you provide through the Portal. WebMD will analyze the information provided through the Portal and provide Wellness Connection with reports summarizing its analysis. These reports will not identify any individual personal health information. Reports will not be generated for groups that contain data from fewer than 50 people. WebMD reports only allow analysis by School – not the department level. The University will use the information it receives from WebMD to better understand the health and wellness needs of employees and to design targeted programs to meet those needs. The University and Wellness Connection will not be able to associate your name or employee ID with your personal health information and will not have access to general health information that contains data from fewer than 50 people. WebMD reports only allow analysis by School – not the department level. In addition, none of your personal health information will be disclosed to a third-party vendor without your consent.

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.

Participation in Wellness Connection programs and use of the WashU WebMD Portal is completely voluntary and you will always have a choice about which program or tools you decide to engage. If you have questions or concerns about your participation, please contact Wellness Connection at 314-935-3211 or email wellnessconnection@wustl.edu.