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... health information acquired through a wellness program is protected under the HIPAA privacy rule if (1... business associate contract with the plan. ARRA strengthened the privacy rule's business associate... privacy rule allows health plans to disclose health information to employers, subject to certain... of food), and not to the health plan or health insurance coverage offered in connection with such a plan... cessation and weight reduction); and (4) having supportive work policies regarding tobacco use, food choices