Wellness programs are required to provide employees with information regarding the voluntary nature of participation in these programs, and information on the collection and handling of employee medical information, among other obligations.  Bennington College is providing this required disclosure to you pursuant to Federal regulations.

The Bennington College 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 will be asked to set a wellness goal and confirm activities you have completed to reach this goal. You may also be asked to complete a biometric screening, which will include a blood test for HDL, and ratio, random glucose screening and lipid panel for total cholesterol. You are not required to set a wellness goal, report on activities completed, or to participate in the blood test or other medical examinations.

However, employees who choose to participate in the wellness program will receive an incentive of a gift card in the amount of $10 for setting a goal and confirming five activities. Although you are not required to take these steps, only employees who do so will receive a gift card.

Additionally, employees who participate in certain health-related activities including biometric screening or attend a Bennington College-sponsored Wellness event, if offered, may be eligible to participate in a raffle for additional incentives.  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 Audry Herbig, Human Resources Generalist at 802-440-4655 or audryherbig@bennington.edu.

The information from your HRA and the results from your biometric screening, should you participate, 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 voluntary educational programs. You also are encouraged to share your results or concerns with your own doctor.

Protections from Disclosure of Medical Information

The College is required by law to maintain the privacy and security of your personally identifiable health information.  Bennington College never receives your individual identifiable health information; the College only receives health information in aggregate.  Although Bennington College may use aggregate information to design a wellness program based on identified health risks in the workplace, the Bennington College will never disclose the aggregate information publicly.  Information may be used, by the College or its agents to respond to a request from you for a reasonable accommodation or as expressly permitted by law.  Medical information that personally identifies you that is collected  in connection with the wellness program will not be provided to Bennington College  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.  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 is required under law to abide by the same confidentiality requirements. The only individual(s) who will receive your personally identifiable health information are a registered nurse, athletic trainer, dietitian, health coach or other medical professional in order to provide you with services under the wellness program.

Medical information received by the College is maintained separate from an employee’s personnel records, information stored electronically will be encrypted.  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.  An employee 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 Audry Herbig, Human Resources Generalist at 802-440-4655 or audryherbig@bennington.edu.