UnitedHealth Group has been committed to genetic privacy and to compliance with state and federal laws that impose restrictions on the use of genetic information by group health plans and insurance companies. The enactment of GINA will have a minimal impact on UnitedHealthcare since it has not been our practice to rely on genetic information for underwriting purposes.
GINAs primary impact on UnitedHealthcare will be to reinforce existing policies and procedures within our organization. In addition, UnitedHealthcare will revise its notice of privacy practices to inform and assure covered persons that their genetic information will be protected to the fullest extent of the law. At the same time, efforts are also underway to review the need for revisions to our certificates of coverage and our summary plan descriptions to make certain that our customers and their covered individuals understand UnitedHealthcare's commitment to genetic privacy.
Recently, there has been a nationwide discussion around the GINA and its impact on wellness program offerings. GINA generally prohibits the improper use of genetic information (which is defined to include family history) in health insurance and employment. Regulations published on Oct. 7 prohibit offering premium reductions or other incentives to encourage individuals to take Health Assessments if those Health Assessments include questions on family medical history. The regulations will be effective on or after Dec. 7. GINA legislation has prompted UnitedHealthcare to remove Health Assessment questions that inquire about family medical history effective Thursday, Oct. 29.
GINA Legislation Details
Health Assessment
UnitedHealthcare provides the University of Michigan Health Management Research Center (HMRC) Health Assessment on the health and wellness portal available via myuhc.com®. Working with OptumHealthSM and the University of Michigan, steps have been taken to remove the family history items from the Health Assessment given that: 1) UnitedHealthcare believes Health Assessment incentives are an important part of engaging a consumer, 2) UnitedHealthcares ability to provide Health Assessment incentive programs are restricted if family medical history items are included on the Health Assessment, and 3) family medical history items have a minimal impact on the wellness score and other calculated fields for the Health Assessment.
The family medical history questions from the online Health Assessment have been removed effective Oct. 29. In addition, future Health Assessment reports generated for time periods prior to this effective date will not include responses from these questions.
For the paper Health Assessment, the University of Michigan HMRC will suppress any family medical history responses received until the questions are removed from the paper forms. Members will receive additional instructions in their assessment packet advising them they should refrain from answering these questions; if they respond to these questions, their responses will not be analyzed.
UnitedHealthcare customers currently undergoing open enrollment are advised to seek legal advice regarding any planned internal communications and may want to consider including disclaimers informing members that the family medical history questions are not required to be answered in order to obtain a premium reduction or incentive. In addition, UnitedHealthcare has not provided, and will continue to refrain from providing, individual response data to employers or health plans.
Personal Health Record
UnitedHealthcare believes that the Personal Health Record (PHR) available via myuhc.com is an individual's opportunity to record, track and manage their personal health history. As such, UnitedHealthcare respects an individual member's desire to use the PHR as a vehicle for capturing this data and will continue to offer members the ability to voluntarily include their family medical history in order to develop a complete medical record.
UnitedHealthcare will include disclaimers on the family medical history section of the PHR. The disclaimers will inform the member that entering their family medical history information is voluntary and completion of the family medical history section is not required in order to qualify for any incentives tied to the PHR, nor is the information shared with the member's employer or health plan.
