Rules published on May 17, 2016, under the Americans with Disabilities Act (ADA) require employers that offer wellness programs, such as Vitality, that collect employee health information to provide a notice to employees informing them what information will be collected, how it will be used, who will receive it, and what will be done to keep it confidential, John Hancock will not receive any of your personal health information. Certain reports with aggregate data only (no personal identifiers) will be provided to the Company. This data will be used to develop future health education and prevention programs with the health plans. Please find the required notice below:
NOTICE REGARDING WELLNESS PROGRAM
The Vitality Employee Wellness Program (the “Wellness Program”) is a voluntary wellness program available to all U.S. domiciled benefits-eligible employees of John Hancock. The 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 of 1996, as amended, as applicable, among others. If you choose to participate in the Wellness Program you will be asked to complete a Vitality Health Review or “VHR,” which is a health risk 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 may also complete a biometric screening, which will include a blood test that measures your Body Mass Index (BMI), blood pressure, blood glucose and cholesterol levels. You are not required to complete the VHR or to participate in the blood test or other medical examinations.
Eligible employees who choose to participate in the Wellness Program will receive an incentive of $600 in wellness credits for achieving Gold Vitality Status.
Additional incentives of up to $408 may be available for employees who participate in certain health-related activities resulting in Vitality Bucks or achieve certain health outcomes resulting in Vitality Points. Additional savings of up to $600 are available through Vitality’s HealthyFood program. 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 think you might be unable to meet a standard for a reward (reward can include avoidance of a surcharge) under this Wellness Program, you might qualify for an opportunity to earn the same reward by different means. Vitality's Personal Pathways have been designed to provide all members with a reasonable alternative standard and member-specific alternatives, which will be provided by Vitality, as advised by your healthcare professional to earn health-contingent points. If you feel that you are medically unable to satisfy the requirements or the provided reasonable alternative standard needed to earn points, please download and complete the medical waiver form and submit it to Vitality. The Medical Waiver Form can be found on the Power of Vitality Website. If you have any questions or require assistance you can contact a Vitality Specialist at 877-224-7117.
The information from your VHR 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 Personal Pathways. 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 John Hancock may use aggregate information it collects to design a program based on identified health risks in the workplace, Vitality 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 are Quest Diagnostics Representatives and Vitality representatives 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.
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 Christina Wiskow at 617-572-4299.