West Clermont Local School District
Administrative Guidelines
 

4419 - EMPLOYEE WELLNESS PROGRAM

The Board of Education sponsors a voluntary Wellness Program that is designed to promote health and prevent disease. The Program is available to all employees, regardless of whether they participate in the District’s health insurance program.

The Wellness Program is a Participatory Program that strives to improve the health of, or prevent disease in, participating individuals.

As addressed below, because the Wellness Program includes measurement, testing, screening, and/or collection of health-related information, the Program will provide participants with results, follow-up information, or advice designed to improve the participants’ health.

A component of the Wellness Program involves employees participating in a health risk assessment (HRA) that involves the employees answering disability-related questions (i.e., completing a medical questionnaire) and/or undergoing a medical examination, such as biometric screening for risk factors (e.g., high blood pressure or cholesterol, diabetes, etc.).

To participate in the HRA, an employee must provide prior knowledge, voluntary and written authorization, to permit the Program to collect the medical information. The authorization form will describe the confidentiality protections and restrictions on the disclosure of genetic information.

As stated above, the Wellness Program is strictly voluntary. As such, employees are not required to participate, the District will not deny coverage under any of its group health plans or particular benefits packages within a group health plan for nonparticipation, and the District will not limit the extent of benefits (except as provided herein) for employees who do not participate. Additionally, the District will not take any adverse employment action or retaliate against, interfere with, coerce, intimidate, or threaten an employee based upon his/her participation or nonparticipation in the Program or failure to achieve certain health outcomes.

The Program is designed so that it is not overly burdensome, does not involve unreasonably intrusive procedures, or does not require employees to incur significant costs for medical examinations.

All medical information gathered as part of the Wellness Program will be kept confidential in accordance with the Americans with Disabilities Act (ADA).

The District will provide participating employees with a clear, understandable written notice that (1) describes the type of medical information that will be obtained and the specific purposes for which the medical information will be used, and (2) describes the restrictions on the disclosure of the employee’s medical information, the District representative or other parties with whom the information will be shared, and the methods that the District will use to protect the medical information so that it is not improperly disclosed.

The Board only receives information collected by the Wellness Program in aggregate form that does not disclose, and is not reasonably likely to disclose, the identity of specific individuals.

Furthermore, no employee or spouse of an employee is required to agree to the sale, exchange, sharing, transfer, or other disclosure of medical information (except to the extent permitted by Federal law and regulations to carry out specific activities related to the Wellness Program), including information about the manifestation of disease or disorder of the employee’s family members, or otherwise waiving the protections afforded by the Americans with Disabilities Act (ADA) and/or Genetic Information Nondiscrimination Act (GINA) as a condition for participating in the Wellness Program or earning an incentive for participating.

The Wellness Program does not discrimination on the basis of disability. As such, employees will not be denied access to the Wellness Programs on the basis of disability and will be provided reasonable accommodations (e.g., adjustments or modifications) that allow them to participate regardless of any disability.

Approved 2/27/17

© Neola 2016