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ADA Notice Regarding Wellness Program

The above mentioned wellness 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. Your participation in

the program is voluntary; however, incentives may be provided in

exchange for your participation as described above.


The information from the program 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 health 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 the UVA Medical Center (“Medical Center”) may use

aggregate information it collects to design a program based on identified

health risks in the workplace, we will never disclose any of your personal

medical information either publicly or to the Medical Center, 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 wellness program

administrator in order to provide you with services under the wellness



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


 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


 If you have questions or concerns regarding this notice, or about

protections against discrimination and retaliation, please contact the

Corporate Compliance Program--Privacy Office at 434.924.9741.

You will find additional information regarding your rights under HIPAA’s

privacy rules in the Health Plan’s Notice of Privacy Practices, which you

can find at https://www.medicalcenter.virginia.edu/intranet/ccpo/privacy-office/.