The wellness program at your company is voluntary and is available to all employees. The program is administered according to federal law permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease. These laws include 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 may be asked to complete a voluntary health assessment or "PHA" that asks a series of questions about your health-related activities and behaviors. You are not required to complete the PHA. Employees with the company’s health insurance who choose to participate in the wellness program will receive the incentive described by your employer. Only employees who work with an approved health coach will qualify for this incentive.

Additional incentives may be available for employees who participate in certain wellness program activities. If you are unable to either complete an activity, a reasonable accommodation will be made for you so you can achieve an alternative standard. You may request a reasonable accommodation or an alternative standard by contacting Darren Swartz at health@phs-ohio.com.

The information from your 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 various services through the wellness program. You also are encouraged to share your results or concerns with your own doctor.

Protections from Disclosure of YOUR Information

We are required by law to maintain the privacy and security of your personally identifiable health information. Although the wellness program and your employer may use aggregate information it collects to design a program based on identified health risks in the workplace, the wellness program will never disclose any of your personal information to your employer, except as necessary to respond to a request from you for a reasonable accommodation needed to participate in the wellness program. However, information that personally identifies you that is provided in connection with the wellness program will not be provided to your supervisors or managers and will never be used to make decisions regarding your employment.

Your health information will not be 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 who may receive your personally identifiable health information, and only after you provide your permission, is a 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 (except for the information provided to employee on their personal USB drive), 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 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 whatsoever regarding this notice or the wellness program, please contact Darren Swartz at health@phs-ohio.com.

I have had the opportunity to ask questions and freely agree to the terms as expressed.



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