Short answer: No. Health information an employer holds in its employment records, in its role as employer, is excluded from HIPAA’s definition of protected health information, even if the same employer sponsors a health plan.
HIPAA’s definition of protected health information expressly excludes individually identifiable health information in employment records held by a covered entity in its role as employer. A doctor’s note an employee hands HR to support a leave request is an employment record, not plan information.
That does not make it free to share. The ADA’s confidentiality rules and state law govern medical information an employer collects as an employer, so it still belongs in a separate, restricted file.
The line that matters is the source and role: the same diagnosis is PHI when it comes from the health plan’s claims, and an employment record when the employee hands it to HR to support a leave. Plan information may never be pulled into employment decisions.