NOTICE REGARDING WELLNESS PROGRAM (EEOC) 

The City of Tucson Wellness Program is a voluntary wellness program available to all employees. 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 may be asked to complete a voluntary health risk assessment or “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 be asked to complete a biometric screening. You are not required to complete the assessment or to participate in biometric screening. 

This is an entirely voluntary program; however, employees who choose to participate in the wellness program may receive an incentive of a monetary amount or a wellness prize item that will be identified and communicated during any and all health campaigns. Incentives may include a Premier Rewards Card that may be available for employees who participate in certain health-related activities such as: Cigna Telephonic Health Coaching, Preventive Care, on-site wellness activities, and more. 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. You may request a reasonable accommodation or an alternative standard by contacting the Benefits team at 520-791-4597. 

The information from your assessment 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 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 City of Tucson may use aggregate information collected to design programs based on identified health risks in the workplace, the City of Tucson Wellness program will never disclose any of your personal information either publicly or to your 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 (are) the Cigna wellness team and possibly Cigna health coaches and nurses 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 the Benefits team at 520-791-4597. 

IMPORTANT INFORMATION ABOUT THE WELLNESS PROGRAM (HIPAA Nondiscrimination notice) 

The City of Tucson Wellness Program is voluntary and is designed to promote health or prevent disease. The term “Wellness Program” includes both:

• ways that we help individuals identify and reduce health risk factors, like elevated blood pressure or excess weight, along with 
• ways to help individuals with chronic conditions, like diabetes, take better care of their condition, for example by working with a coach through your medical insurance to encourage you to take the medication the doctor prescribes for your chronic condition. 

The City’s Wellness Program also offers incentives for participation (such as for completing a Health Risk Assessment questionnaire), and you may receive incentives if you positively change behavior (including but not limited to maintaining or losing excess weight, increasing activity, and maintaining or working toward healthy BMI and cholesterol). Only employees enrolled as a primary subscriber in one of the City’s medical plan options under active employee insurance (not retiree insurance) at the City have the opportunity to qualify for wellness program incentives. Incentives are able to achieved at least once a year; receiving incentives may be raffle-based and not guaranteed. The time commitment required to achieve incentives in our City Wellness Program is reasonable. 

The wellness program incentives have been reviewed and in accordance with law, do not exceed 30% of the total cost of employee-only coverage under the plan (including employee & employer contributions). 

If you think you might be unable to meet a standard for a certain reward under our Wellness Program, you might qualify for an opportunity to earn the same reward by a different means. If an individual has physical disabilities or a medical condition such that it is unreasonably difficult or medically inadvisable due to their medical condition to satisfy the standards of the City’s Wellness Program, then reasonable alternative standards will be made available upon request. If the individual’s personal doctor states that the alternative is not medically appropriate, a more accommodating alternative will be provided. 

Contact the Benefits Office (520-791-4597) for information about the City’s Wellness Program and for information on reasonable alternative standards and accommodations. We will work with you and, if you wish, we will work with your doctor, to find a Wellness Program standard with the same reward that is right for you in light of your health status